FMCSA's Final Mandate Deadline

The last few years have seen a number of FMCSA mandate deadlines, but 2019 marks the final deadline. On December 16, 2019, any carriers and drivers grandfathered in by previous deadlines or exceptions must switch any AOBRD-type devices to certified electronic logging devices (ELDs).

What is an ELD?

ELD stands for “Electronic Logging Device”. Simply put, ELDs are used to replace paper HOS logs by connecting to a vehicle’s engine to monitor its movement, distance, and time of operation.

Features of an ELD:

  • Records driving time automatically
  • Provides accurate recording of driver’s HOS
  • Meets technical specifications of ELD rule
  • Integral synchronization with engine of the commercial motor vehicle (CMV)
Cab-Mate Connect

So, What's the Difference?

Though similar, the main difference to set ELDs apart is that AOBRDs cannot support the electronic data transfer methods outlined in the ELD rule. Besides that, though, there are still a number of other features that differ. Below are some of the other small details that separate AOBRDs from ELDs in the FMCSA’s mandate:

Integral Synchronization Integral synchronization required, but not defined in regulations. Integral synchronization with CMV engine electronic control module (ECM) to automatically capture data including power status, vehicle motion status, miles driven, and engine hours.
Recording Location Information of Commercial Motor Vehicle (CMV) Required for each change of duty status (manual or automated). Requires automated entry at each change of duty status, at 60-min intervals while in motion, at engine-on and engine-off, and at the start and end of personal use and yard moves.
Graph Grid Display Not required – “time and sequence of duty status changes.” “An ELD must be able to present a graph grid of driver’s daily duty status changes either on a display or printout.”
Hours of Service (HOS) Driver Advisory Messages  N/A HOS limits notification is not required. “Unassigned driving time/miles” warning must be provided upon login.
Device “Default” Duty Status N/A On-duty not driving status, when CMV has not been in-motion for 5 consecutive minutes and driver has not responded to an ELD prompt within 1-min. (No other non-driver-initiated status change is allowed.)
Clock Time Drift N/A ELD time must be synchronized to Universal Coordinated Time (UTC); absolute deviation must not exceed 10-min at any time.
Communications Methods Integral synchronization required, but not defined in regulations. Integral synchronization with the CMV engine electronic control module (ECM) to automatically capture power status, vehicle motion status, miles driven, engine hours. (Exempt: CMVs older than model year 2000.)
Resistance to Tampering Required for each change of duty status (manual or automated). Requires automated entry at each change of duty status, at 60-minute intervals while CMV is in motion, at engine-on and engine-off instances, and at beginning and end of personal use and yard moves.

ELD Required Documentation

The FMCSA also has an ELD-specific requirement that drivers carry a number of records, manuals, and other documents for inspections. Below is a list straight-from the FMCSA themselves.

A driver using an ELD must have an ELD information packet onboard the commercial motor vehicle (CMV) containing the following items:

  • ELD Operations Manual
  • Instruction sheet with step-by-step instructions, describing data transfer mechanisms and how to transfer HOS records to a safety official.
  • Instruction sheet for the driver describing ELD malfunction reporting requirements and recordkeeping procedures during the ELD malfunctions.
  • Supply of blank driver’s records of duty status (RODS) graph-grides sufficient to record the driver’s duty status and other related information for a minimum of 8 days.

Exceptions and Exemptions

ELD Mandate’s Expiring Grandfathered AOBRD Exception

The FMCSA’s mandate policy included an exception allowing those with AOBRDs an extended transition period. Typically, exceptions and exemptions were based on the age of the vehicle or on specific industries’ needs. For instance, until now, if a vehicle was manufactured before 2000 it didn’t require the use of an ELD, although drivers still had to adhere to the FMCSA’s RODS requirements.

Other exempt drivers include those performing drive-away-tow-away operations (depending on commodities transported) and drivers that aren’t required to keep RODS more than 8 days within any 30-day period.

Industry-Specific Exceptions

Ongoing ELD exemptions primarily affect those that aren’t required to keep records of duty status anyway, like short-haul- or timecard-exempt drivers. However, specific industries may require an exemption or special exception for certain drivers, like those within the agricultural industry (which generally doesn’t require an ELD) or the oil-and-gas industry (which has a “waiting time” provision).

An expanded list of exceptions can be found here.

More Exemptions Include:

  • Emergency/Adverse Driving Conditions
  • Driver-Salesperson
  • Oilfield Operations
  • 100 Air-Mile Radius Driver
  • Retail Store Deliveries
  • Travel Time
  • Agricultural Operations
  • Ground Water-Well Drilling Operations
  • Construction Materials and Equipment
  • Utility Service Vehicles
Future Changes to ELD Exceptions and Exemptions

An important note is that the FMCSA is continuing to sculpt these regulations. As companies and drivers continue to communicate challenges they experience, certain rules may be added, edited, or removed. Some proposed changes, not yet approved or enforced, include adverse driving conditions, as well as short-haul, sleeper berth, and break-related exceptions.

The Pedigree Technologies team keeps close tabs on all new rulings and, when necessary, we jump into action to update our OneView solutions to keep our customers compliant.

ELDs & Operating Outside of the U.S.


A final ruling for Canada’s ELD mandate was in June of 2019, with a deadline for full implementation of ELDs in June 2021. In addition, there are also a number of rules that differ from the U.S.’s FMCSA mandate. For more details, you can read about it on the official Canadian DOT website.


Mexico is supportive of the FMCSA’s mandate in the U.S. but, at the moment, they don’t have official plans for their own set of ELD regulations. This may change in the future, however.

Request an ELD Demo

Need to get your AOBRDs transitioned to ELDs? Want to ditch the unhelpful support and call centers? How about having one (ONE!) login for all of your fleet operations?

Schedule a custom demo today to learn about how we can flexibly shape our OneView solutions to simplify all of your daily operations!

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