Q7. Can a user edit or change driving time that has been recorded by an electronic logging device (ELD) to non-driving time?Ī7. However, the right to access is limited to a six-month period, consistent with the period during which a motor carrier must retain drivers’ records of duty status (RODS). If the driver cannot independently access the records from the ELD, the motor carrier must provide access on request. The original ELD records are retained even when allowed edits and annotations are made. Q6. Are the original electronic logging device (ELD) records retained after edits are made, and accessible to drivers?Ī6. However, if the driver is unavailable or unwilling to recertify the record, the carrier’s proposed edit and annotation would remain part of the record. The driver certification is intended, in part, to protect drivers from unilateral changes. Although the ELD reflects the driver’s RODS, the driver and carrier share responsibility for the integrity of the records. Q5. Who is responsible for the integrity of records of duty status in regards to the editing and certification rights of drivers and motor carriers?Ī5. The edit is not accepted until the driver confirms it and resubmits the RODS. The edit and annotation are sent to the driver to verify. Example: a carrier edits a record to switch a period of time from “off-duty” to “on-duty not driving”, with a note that explains “Driver logged training time incorrectly as off-duty”. The ELD must keep the original, unedited record, along with the edits. If the driver chooses not to re-certify RODs, this is also reflected in the ELD record. In addition, the driver must confirm (certify) that any carrier edit is accurate, and resubmit the records. All edits must include a note (annotation) to explain the reason for the edit. Both the driver and authorized carrier staff can make limited edits to an ELD record to correct mistakes or add missing information. Q4. Who can edit an electronic logging device (ELD) record?Ī4. A driver can use annotations to indicate the beginning and end of a period of authorized personal commercial vehicle use, or yard moves, as well as other special driving categories, such as adverse driving conditions (49 CFR 395.1(b)) or oilfield operations (49 CFR 395.1(d)). Q3. Can a driver annotate the electronic logging device (ELD) record?Ī3. For example, an edit showing time being switched from “off duty” to “on-duty not driving” could be annotated by the carrier to note, “Driver logged training time incorrectly as off duty.” This edit and annotation would then be sent to the driver for approval. Section 49 CFR 395.30(c)(2) requires that all edits, whether made by a driver or the motor carrier, be annotated to document the reason for the change. An edit is a change to an electronic logging device (ELD) record that does not overwrite the original record, while an annotation is a note related to a record, update, or edit that a driver or authorized support personnel may input to the ELD. Q2. What is the difference between an “edit” and an “annotation”?Ī2. Printouts of RODS from ELDs are the reports that ELDs must be able to generate upon request from an authorized safety official, per section 4.8.1 of the ELD rule. “Paper RODS” means RODS that are not kept on an ELD or automatic onboard recording device (AOBRD), but that are either recorded manually (in accordance with 49 CFR 395.8(f)) or on a computer not synchronized with the vehicle or that is otherwise not qualified to be an ELD or AOBRD. Q1. What is the difference between “paper records of duty status (RODS)” and printouts of RODS from electronic logging devices (ELDs)?Ī1.
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