ELD Requirement for Blank Paper Logs
| Entry Date | March 22, 2024 |
|---|---|
| Issue Number | 24-021-DRV |
| Name | Cody H Lewis |
| Agency | Werner Enterprises Inc. |
| Address | 14507 Frontier RdOmaha, Nebraska, 68138United StatesMap It (opens in a new tab) |
| Phone | 5312518736 |
| [email protected] | |
| Committee | Driver-Traffic Enforcement Committee |
| Status | Closed |
| Summary of Issue | Carriers are seeing many HOS violations issued citing 395.22H4 for failure to maintain a blank paper logbook. |
| Justification or Need | 395.22H4 is a regulation that doesn't consider our technological advances in the industry regarding modern DOT compliant ELD systems. One example is with Platform Science ELD software. Even if connection to the ECM is lost or data diagnostic events occur, the tablet is still able to record an accurate record of duty status and maintain compliance with DOT regulations. Issuing a violation for failure to maintain a “blank paper logbook” becomes redundant and is essentially requiring a “backup to the backup”. Unless a tablet is physically destroyed or lost it will continue to function as a blank paper logbook in the event of a connection outage or malfunction, just as a physical paper logbook would unless lost or destroyed. |
| Request for Action | The request is for the DOT to stop issuing 395.22H4 in respect to the advances in technology that allow ELDs to have the capability of accurately recording record of duty status while connected to the ECM, while not connected to the ECM, and in the event of a data diagnostic event/malfunction just a as a blank paper logbook would be used in previous years. |