FMCSA has issued an updated FAQ document for Electronic Logging Devices.

Are transporters of mobile or modular homes considered Driveaway/Towaway operations under Section 395.8 (a)(1)(iii)(A)(2) or (3) and therefore exempt from the ELD rule?

  • No. The transportation of mobile or modular homes does not qualify for an exception under 395.8(a)(1)(iii) (A)(2) because the vehicle driven in transporting the mobile or modular home is not part of the shipment, nor does the transport qualify under 395.8(a)(1)(iii)(A)(3) because the shipment is neither a motor home or recreational vehicle trailer.


  • Will the vehicle location information identify street addresses?

    • No. Vehicle location information is not sufficiently precise to identify street addresses. For each change in duty status, the ELD must convert automatically captured vehicle position in latitude/longitude coordinates into geo-location information that indicates the approximate distance and direction to an identifiable location corresponding to the name of a nearby city, town, or village, with a State abbreviation.

      • For example: trailer park names are not qualifying location descriptions.


  • What is the process for transferring data via web services?

    • If the driver is using a “telematics” ELD with wireless Web services capabilities, the authorized safety official will give the driver a routing code to assist the official in locating the data once transmitted, and the driver will initiate a web transfer to an FMCSA server to be retrieved by the safety official’s software.


  • How many electronic logging device (ELD) accounts can be established by a motor carrier for one of its ELD drivers?

    • A motor carrier must assign only one ELD driver account for each of its drivers required to use an ELD. An ELD must not allow the creation of more than one driver account associated with a driver’s license for a given motor carrier. The motor carrier is also responsible for establishing requirements for unique user identifications and passwords.


  • If a motor carrier adds an owner operator to its fleet after December 18, 2017, and the owner operator operates with a grandfathered AOBRD in their CMV, can the owner operator continue to use its grandfathered AOBRD while employed by the motor carrier?

    • Yes, an owner operator that operates with a grandfathered AORBD and is hired by a motor carrier after December 18, 2017 may continue to operate with its grandfathered AOBRD while employed by the motor carrier.


  • May a motor carrier request an extension to the 8-day period to correct, repair, replace, or service a malfunctioning Automatic On-board Recording Device (AOBRD)?

    • Yes, if the AOBRD malfunction prevents accurate hours-of-service recording. The motor carrier must submit a request to the FMCSA Division Administrator (DA) in the State of the motor carrier’s principal place of business within 5 days of driver notification of malfunction.