ELD Mandate FAQs – Malfunctions, 7 Days of RODS, Older Model Trucks

It won’t be long until we look back at this time of ramping up to the ELD Mandate nostalgia.

Everyone in the industry wants to get this transition right and not cause themselves any problems when dealing with enforcement.

In the spirit of education, here are some answers to common questions that we’re hearing as fleets and drivers prepare for life after December 2017.

What do I do if the ELD stops working?

If the ELD malfunctions for some reason, you can keep driving. Now, keep in mind there’s a difference between a truck that goes out of service for repair or maintenance and an ELD that goes out of service. We covered that scenario in another post.

If for whatever reason, the ELD stops working, you can use a paper log for 8 days. until the device is repaired. The carrier or vehicle owner is responsible for repairing or replacing the ELD within that time period.

What are the requirements for showing the 7 days of RODS?

The driver has to have a means of showing the RODS for the past seven days of activity. The driver can reconstruct the time on a paper log or retrieve the data from the ELD. That can be a paper print out or a PDF download that is visible on a cell phone or tablet. Or, depending on the service used, a driver can access it through a website on a mobile device or computer — but it must be available in the vehicle on demand by enforcement

Keep in mind, you must also turn in supporting documents (8) for every 24-hour period, which must be turned in within 13 days of generation. These documents include:

  • Dispatch or trip records
  • Bills of lading, itineraries, schedules, or other documents which prove point of origin and ultimate destination
  • Receipts for expenses
  • Mobile communication records sent through fleet management systems
  • Proof of driver compensation — i.e. payroll records, settlement sheets, or similar documents

If a driver submits more than eight documents within a single 24-hour period, the first, last, and six others must be maintained. However, if fewer than eight documents are sent, the carrier must save all of them. These documents must be accessible six months following submission.

Does a 2000 model year truck or older truck need an ELD?

The model year cutoff is based on the fact that most trucks manufactured prior to 2000 do not have an Engine Control Module (ECM) that the ELD connects to for engine data. The truth is that trucks had an ECM starting in about 1996. You are allowed to put an ELD in a truck of model year earlier than 2000 as long as the required engine synchronization data is available, but you are not required to do this.

If the engine model year is older than 2000, the driver is not subject to the ELD rule.

In instances in which the engine model year is 2000 or newer, and the vehicle registration reflects a model year older than 2000, the driver is subject to the ELD rule.

Due to repairs or upgrades, the model year reflected on the vehicle registration may not be the same as the engine model year, which can be the case when a vehicle is rebuilt using a “glider kit.” In this instance, an inspector/investigator should use the model year on the engine to determine if the driver is exempt from the ELD requirements.

Drivers do not have to keep documentation that confirms the vehicle engine model year on the truck, but the motor carrier must maintain that information at its headquarters.

Preparation will be one of the keys to the ELD Mandate a non-event. Trucking companies that prepare ahead of time and get their questions answered will weather the transition just fine.