Dear Members:
We received important information from our friends at United Motorcoach Association (UMA). Some operators are experiencing electronic logging device (ELD) malfunctions that may be difficult to diagnose and repair within the prescribed eight days of discovering the condition, or a driver's notification to the motor carrier, whichever occurs first.
As a reminder, your drivers must continue to carry paper logs and the operator must require drivers to maintain paper records of duty status (RODS) until a malfunctioning ELD is back in service.
If you anticipate that it may take longer than eight days to diagnose and repair a malfunctioning ELD, you may submit a request for an extension to your Federal Motor Carrier Safety Administration (FMCSA) state division administrator by emailing the request to
ELD-Extension@dot.gov.
The request must contain:
1. The name, address, and telephone number of the representative filing the request;
2. The make, model, and serial number of each ELD;
3. The date and location of each ELD malfunction as reported by the driver to the carrier; and
4. A concise statement describing actions taken by the motor carrier to make a good faith effort to repair, replace, or service the ELD units, including why the carrier needs additional time beyond the 8 days provided by 49 CFR part 395.34.
UMA has prepared a simple form to complete; however, it will be your responsibility to include all the required and pertinent information with your submission, including any attachments that may be required.
If the extension is granted, you will be able to continue to utilize the commercial motor vehicle (CMV) during the period granted using paper record-of-duty status (RODS).
In an effort to avoid a situation where a CMV is not being utilized, it is recommended that you avoid waiting until the seventh or eighth day to request an extension. The earlier the request is submitted, the more likely you may have uninterrupted use of the CMV(s) using paper RODS.
Thank you for your time,
Pattie
Patricia A. Cowley, Executive Director
908-835-0935 x 105
