Guidance for Reviewing ELD Records During Transition Period

Guidance for Reviewing ELD Records During Transition Period

 

Dear Safety Officials/Inspectors,

This communication provides the information regarding the review of Electronic Logging Device (ELD) records, in light of the Federal Motor Carrier Safety Administration's (FMCSA) recent removal of specific devices from the Registered Devices List. These removals are effective November 18, 2024, due to non-compliance with the minimum requirements established in 49 CFR Part 395, Subpart B, Appendix A.

Because the ELDs (Rollingtrans ELD - ACCURATE ONE & RT ELD Plus - ACCURATE PLUS) were revoked from the list, there may be issues with Uploading ELD Records. Drivers using a device that has been placed on the Revoked Devices List may encounter difficulties uploading ELD records to inspection systems. This is because revoked devices no longer meet FMCSA requirements and are no longer supported by the compliance system.

 

Driver’s Rights During Transition:

 

Drivers and motor carriers are granted a 60-day grace period following the revocation of an ELD to replace it with a compliant device from the FMCSA Registered Devices List. During this period, drivers have the right to transition to paper logs, logging software, or rely on back-up methods to document their Hours of Service (HOS) records. Do Not Issue Citations.

If a driver is found to have been using a revoked ELD during the 60-day transition period, they should not be penalized or cited for the inability to upload ELD records, as this situation arises due to the revocation of the device. Drivers using paper logs, logging software, or the ELD display as a back-up method should be considered compliant during this time.

 

Post-Grace Period Enforcement:

 

After January 17, 2025, drivers who have not replaced revoked devices with compliant ELDs will be considered non-compliant. At that time, citations under 395.8(a)(1) and potential out-of-service (OOS) orders in accordance with the Commercial Vehicle Safety Alliance (CVSA) OOS Criteria may apply.

 

Ensuring Fair and Accurate Inspections:

We encourage all safety officials to exercise discretion during this transitional period to protect drivers’ rights. The inability to upload ELD records due to a revoked device should not result in citations during the 60-day replacement window. If you require further clarification or assistance, please contact (Rollingtrans Customer Service Number: 626-416-5098). Thank you for your cooperation in ensuring a fair and smooth transition for all drivers and motor carriers.

Sincerely,