Paper Logs During ELD Malfunction

Who This Applies To

• Drivers who need to switch to paper RODS immediately after an ELD malfunction and want to know the correct format and requirements.
• Fleet managers who need to confirm what paper log requirements apply when drivers are operating without a working ELD.
• Carriers building malfunction response kits for vehicles and need to know how many paper log days to include.
• Drivers who are on the road when an ELD malfunctions and need to complete their shift without a working device.

What To Verify

• That the standard paper RODS format is the 24-hour duty-status grid divided into four duty-status categories: off duty, sleeper berth, driving, and on-duty not driving. The grid format and required annotations are specified in 49 CFR Part 395.
• What information must appear on each paper log: the driver's name, the co-driver's name if applicable, the date, the shipping document number or commodity, the carrier's name and address, the home terminal address, vehicle unit numbers, and the beginning and ending odometer readings.
• How many paper logs to carry. FMCSA requires that drivers have sufficient blank logs to cover at least 8 days of duty status while the ELD is out of service.
• That paper logs during an ELD malfunction must be annotated with the reason for using paper (ELD malfunction) and the date and time the malfunction was noted. This annotation should appear on each paper log used during the malfunction period.

Step-by-Step Overview

1. When an ELD malfunction is detected, note the malfunction indicator, the date and time, and the malfunction code if available. Record this on the first paper log used after the malfunction.
2. Continue the current shift on paper RODS using the standard duty-status grid format. Complete all required fields on each paper log.
3. Notify the motor carrier of the malfunction within 24 hours as required by 49 CFR 395.34. Document the notification in the paper logs or separately.
4. Carry the paper logs for the malfunction period during the rest of the trip and present them to inspectors in place of ELD data if stopped.
5. After the ELD is repaired or replaced, retain the paper logs for the malfunction period for the required retention period — do not discard them once the ELD is back online.

Common Mistakes

• Not having blank paper logs in the vehicle before a malfunction occurs. A driver who discovers an ELD malfunction and has no paper logs in the vehicle has no compliant way to continue the shift until logs are obtained.
• Using the wrong log format. Paper RODS must use the standard 24-hour grid format — informal notes, typing on a phone, or sketched timelines do not satisfy the RODS requirement.
• Not annotating paper logs with the reason for using paper. Logs produced during an ELD malfunction must indicate why paper is being used — unmarked paper logs look like an unauthorized departure from ELD use.
• Discarding malfunction-period paper logs after the ELD is repaired. Records from an ELD malfunction period must be retained for the same period as regular HOS records.