Manage HOS During an ELD Malfunction

At Samsara, we are sensitive to the importance of compliance and its impact on your organization. In the event of an ELD device failure or service disruption, use the guidelines below to understand how you will be notified, legal obligations for both Carriers and Drivers (per 49 CFR §395.4 ELD malfunctions and diagnostic events), and how to best reach us for additional assistance.

We greatly appreciate your partnership and we are here to support you and provide guidance in the event of a malfunction.

Carrier Responsibilities

• Notifications: If an ELD malfunctions, Samsara communicates the service disruption to all users across the dashboard. The disruption will explicitly direct drivers to switch to paper logs if the nature of the disruption necessitates it. For additional guidance on how best to manage the event or for more information relating to the service disruption, Carriers can contact Samsara Support at 415-329-6900 or samsara.com/help.

• Actions for fleets in the United States: Refer to the following guidelines pursuant to §395.34(d) for an ELD malfunction:

  • The motor carrier must correct the malfunctions within eight days of discovery of the condition (whether it was reported by the driver or identified on their own).

  • Samsara will send a new device in the event of a malfunction where the device is the issue and cannot be corrected immediately.

  • According to §395.34(2), if a motor carrier needs to extend the eight-day period of time permitted for repair, replacement, or service of the ELD, the carrier must notify the FMCSA Division Administrator of the state of motor carrier's principal place of business within five days after a driver notifies the motor carrier of the malfunction.

• Actions for fleets in Canada: Refer to the following guidelines per the Commercial Vehicle Drivers Hours of Service Regulations SOR/2019-165 of the Motor Vehicle Transportation Act:

  • The motor carrier shall ensure that any ELD that is installed or used in a commercial vehicle that it operates is in good working order and is calibrated and maintained in accordance with the manufacturer’s or seller’s specifications.

  • The motor carrier shall repair or replace the ELD within 14 days from the day of notification of the ELD malfunction or data diagnostic code by the driver (or otherwise became aware of it) or, at the latest, upon return of the driver to the home terminal from a planned trip if that return exceeds the 14-day period.

  • According to subsection (6), the motor carrier shall maintain a register of ELD malfunction or data diagnostic codes for ELDs installed or used in the commercial vehicles that it operates for which a malfunction was noticed, and that register shall contain the following information:

    • The name of the driver who noticed the malfunction or data diagnostic code

    • The name of each driver that used the commercial vehicle following the discovery of the malfunction or data diagnostic code until the ELD was repaired or replaced

    • The make, model, and serial number of the ELD

    • The license plate of the commercial vehicle in which the ELD is installed or used, or the Vehicle Identification Number

    • The date when the malfunction or data diagnostic code was noticed and the location of the commercial vehicle on that date, as well as the date when the motor carrier was notified or otherwise became aware of the code

    • The date the ELD was replaced or repaired

    • A concise description of the actions taken by the motor carrier to repair or replace the ELD

  • The motor carrier shall retain the information set out in subsection (6) for each ELD for which a malfunction was noticed for a period of six months from the day on which the ELD is replaced or repaired.

Driver Responsibilities

• Notifications: Drivers are notified of an ELD malfunction or a data diagnostic event from the Hours of Service view on their mobile device. An error displays as a red D (diagnostic) or M (malfunction). Drivers can click the icon for more information on the error source.

  After a diagnostic or malfunction has been successfully resolved, it will no longer appear in the Driver App, except in the following scenarios:

  • Unidentified Driving in the United States: Displays the day the event was triggered and the following 7 days, regardless of resolution.

  • Unidentified Driving in Canada: Displays the day the event was triggered and the following 14 days, regardless of resolution.

  • Unidentified Driving in Cross-border scenarios: Displays dependent on the current operating zone. For example, if the data diagnostic event was recorded 9 days ago in either region, the notification will not display in the US and will display in Canada.

• Actions for drivers in the United States: Refer to the following guidelines pursuant to §395.34(a) for an ELD malfunction:

  • Note the malfunction of the ELD and provide written notice of the malfunction to the motor carrier within 24 hours.

  • Reconstruct the Record of Duty Status (RODS) for the current 24-hour period and record the records of duty status on graph-grid paper logs that comply with 49 CFR §395.8.

    Note

    Storing copies of paper logs in the Samsara dashboard is not supported.

  • Use the Samsara ELD to retrieve previous seven days of records. If that is not available, drivers must reconstruct the RODS on paper logs for those previous seven consecutive days.

• Actions for drivers in Canada: Refer to the following guidelines pursuant to the Commercial Vehicle Drivers Hours of Service Regulations SOR/2019-165 of the Motor Vehicle Transportation Act for an ELD malfunction:

  • If the driver of a commercial vehicle becomes aware of the fact that the ELD is displaying a malfunction or data diagnostic code as described in Table 4 of Schedule 2 in the CCMTA Technical Standard, the driver shall notify the motor carrier that is operating the commercial vehicle as soon as the vehicle is parked.

  • On the day of which he or she noticed the malfunction or data diagnostic code, the driver shall document the following information in the Record of Duty Status (RODS):

    Note

    Storing copies of paper logs in the Samsara dashboard is not supported.

    • The malfunction or data diagnostic code as described in Table 4 of Schedule 2 of the Technical Standard.

    • The date and time when the malfunction or data diagnostic code was noticed.

    • The time when notification of the malfunction or data diagnostic code was transmitted to the motor carrier. The driver shall record the code referred to in paragraph.

  • In each RODS following the day on which the code was noticed, the driver shall record the code referred to in paragraph (3)(a) until the ELD is repaired or replaced.