Electronic Logging Device (ELD) Compliance Checklist

Cross-check the device make, model, and version against the FMCSA registered ELD list at csa.fmcsa.dot.gov/eld. Devices removed from the list (revoked registration) cannot be used after the FMCSA deadline — the carrier has 60 days to replace or revert to paper logs. Common gotcha: Motive, Samsara, and Geotab models all have specific firmware versions tied to registration.

Pull the device-management dashboard (Motive, Samsara, KeepTruckin admin) and export the firmware report. Flag any unit more than two versions behind current. Out-of-date firmware is the most common cause of false ELD malfunction codes flagged at roadside.

Pre-2000 engines without an ECM are exempt (Part 395.8(a)(1)(iii)(A)). Glider kits and rebuilt tractors are the usual edge cases — verify VIN-to-engine match and document the exemption in the unit file if applicable.

Per FMCSA guidance, carriers have 8 days from revocation notice to either revert to paper logs or install a replacement registered ELD. Notify drivers, order replacement hardware, and document the transition timeline in each driver's qualification file.

Part 395.22(h) requires drivers be trained on the ELD before operation. Pull the training log from your LMS (Tenstreet, J.J. Keller, Foley) and verify a signed acknowledgment exists in each DQ file. New hires are the typical gap — confirm pre-dispatch training, not just post-hire.

Every CMV must carry: ELD user manual, instructions for data transfer to safety officials, instructions for malfunction reporting, and a supply of blank driver's record-of-duty-status graph grids for at least 8 days. Missing any one is a roadside violation.

Back-office edits to a driver's log require driver acceptance and an annotation explaining the change. Coaching dispatchers to never push edits without an annotation is the single biggest control against falsification findings during a compliance review.

Trigger a test transfer from one tractor per terminal to the FMCSA eRODS test account. Both web services and email transfer methods are required for registered ELDs — drivers must be able to use whichever a roadside inspector requests.

Pick 5 drivers at random and have them walk through producing the prior 8 days of logs on the device display and initiating a transfer. If drivers fumble the procedure at roadside, the carrier inherits the OOS time — train against the actual workflow inspectors use.

Part 395.22(i) requires back-office retention of ELD records and supporting documents (BOLs, fuel receipts, dispatch records, payroll) for 6 months. Confirm the TMS or ELD vendor archive covers the full window — vendor offboarding mid-contract is a common gap.

File a ticket with the ELD vendor (Motive, Samsara, KeepTruckin, Geotab) referencing the FMCSA eRODS test ID. Track resolution; until both transfer methods pass, drivers must carry blank graph grids and be prepared to display logs at roadside.

Pull the exceptions dashboard for 11-hour driving, 14-hour duty, 30-minute break, and 60/70-hour violations. Patterns matter more than one-off events for CSA HOS Compliance BASIC scoring. Counsel any driver with three or more exceptions in the month.

Unassigned driving (no driver logged in) over 5 minutes must be reviewed and either assigned to a driver or annotated as yard-move/mechanic. Persistent unassigned segments suggest driver-login failures or off-the-books moves — both audit triggers.

Drivers must review and certify (e-sign) each day's RODS. Uncertified-log counts above 5% across the fleet show up in compliance reviews. Run the uncertified-logs report and follow up by name.

Per Part 395.34, drivers must report a malfunction in writing to the carrier within 24 hours; carrier has 8 days to repair or replace. Verify the malfunction-log channel (TMS ticket, email inbox, dispatch radio script) is monitored and the 8-day clock is tracked per incident.

If repair/replacement cannot be completed in 8 days, submit a written extension request to the FMCSA Division Administrator in the state of principal place of business within 5 days of the original deadline. Include the malfunction code, repair attempts, and projected resolution date.

Log into the FMCSA portal and capture this month's HOS Compliance percentile. Trend against the prior 6 months; a 5-point jump or crossing the 65% intervention threshold triggers a deeper driver-by-driver review.

The safety director signs off, captures the current CSA HOS percentile, and lists any open follow-up items. This signed record is the artifact a New Entrant Safety Audit or Compliance Review will ask for first.