ELD Compliance for Small Fleets: Unassigned Driving, Edits and Supporting Documents

Many small carriers treat the electronic logging device as something the driver deals with. But the ELD rule puts real obligations on the motor carrier too — and an audit of a fleet with ELDs installed in every truck can still turn up false logs, unassigned driving and missing supporting documents.

Make sure the device is still registered

ELDs are self-certified by their manufacturers and listed on FMCSA’s registered devices list. FMCSA removes devices from that list when they don’t meet the requirements, and carriers using a revoked device are given a deadline to switch before the device stops counting as compliant. Check FMCSA’s revoked devices list periodically — a device that was fine when you bought it may not be now.

Unassigned driving time

When a truck moves and no driver is logged in, the ELD records the time as “unassigned.” The carrier must review unassigned records and either assign them to the driver who was actually driving (who then accepts or rejects it) or annotate why the time can’t be assigned — for example, a mechanic road-testing the truck.

Unreviewed unassigned time is one of the first things an investigator looks at, because it’s where drivers hide hours.

Edits

Either the driver or the carrier can propose edits to correct mistakes, but:

• Every edit must be annotated with the reason.
• Carrier-proposed edits must be accepted by the driver before they take effect.
• The original record is preserved — edits never erase what was recorded. An investigator can see both.
• Edits can’t change automatically recorded driving time to non-driving time.

Pressuring a driver to accept edits that reduce their hours is harassment under the ELD rule and can lead to separate penalties.

Supporting documents

Under §395.11, carriers must keep supporting documents that verify the logs — investigators compare them against records of duty status to find falsification. The categories are:

1. Bills of lading, itineraries, schedules or equivalent
2. Dispatch records, trip records or equivalent
3. Expense receipts (fuel, meals, lodging, tolls…)
4. Electronic mobile communication records (fleet management system messages)
5. Payroll records, settlement sheets or equivalent

You need to keep up to 8 supporting documents for each driver’s 24-hour period, and each must include the driver’s name (or identifier), date, location and time where available.

Malfunctions

When an ELD malfunctions, the driver must note it and notify the carrier within 24 hours, and switch to paper logs (reconstructing the current day and the previous 7 days if those records aren’t available). The carrier must get the device repaired or replaced within 8 days of discovering the problem, unless FMCSA grants an extension.

Each truck should carry the ELD user’s manual, data transfer instructions, malfunction instructions, and at least 8 days of blank paper logs.

A monthly carrier checklist

• Review and resolve all unassigned driving time.
• Review HOS violations and follow up with drivers.
• Spot-check logs against fuel receipts and dispatch records.
• Confirm no open malfunctions older than 8 days.
• Check your device is still on FMCSA’s registered list.

Bring ELD data into your compliance picture

TruckComply works alongside whatever ELD you already use. Unresolved hours-of-service violations count toward your compliance score next to driver files, testing and vehicle records — so they’re reviewed as part of your overall compliance, not discovered during an audit.