ELD Edits Must Keep the Original Record

What the driver may edit and what the carrier may propose

49 CFR 395.30(a) says the driver and the motor carrier must ensure the ELD records are accurate. Accuracy is the only project. A cleaner graph that is less true is not the project.

The driver reviews the records, edits and corrects inaccurate records, enters missing information, and certifies them. Subject to the ELD's own edit limits, the driver may edit, enter missing information, and annotate. When a change is necessary, the driver uses the ELD and answers its prompts. The prompts exist so the change is attributed.

The carrier's role is a proposal, and only after the driver has submitted the records. 395.30(d)(2) says the carrier may not request edits before that submission. The driver confirms or rejects the proposal, makes the appropriate edit, and recertifies. Until that happens, the proposal is not the log. A back-office user who overwrites the day without that confirmation has violated the section, even if the new story would have been convenient.

Support personnel can help with an annotation. They cannot become the author of the driver's duty status. The certification statement belongs to the driver: the entries and the record for that 24-hour period are true and correct.

Annotation is mandatory

395.30(c)(2) says the driver or support personnel must annotate each change or addition to a record. The note says who changed it and why. A one-word note that says fixed is not a reason. A usable note says the off-duty segment was really a live unload from this time to that time, or the login city was wrong because the driver selected the last stop.

The annotation is part of the record the officer can read. Write it as if it will be read next to the bill of lading. If the note and the freight paperwork disagree, the note will not win. If you cannot write a true reason, you cannot make the change.

Do not annotate in a code your shop understands and an inspector does not. Plain language, a clock time, and a place are enough. The goal is a record a stranger can match to the movement.

The original record is not deleted

395.30(f) forbids the carrier to alter or erase, or to permit or require alteration or erasure of, the original information collected on the driver's hours of service, the source data streams, or the information in any ELD that uses them. An edit is a later layer. The first layer stays available.

That is why an edit is not a delete key. The driving event the ELD recorded from the vehicle remains in the history even if a later annotation explains a real mistake. Anyone who tells you the vendor can wipe yesterday is telling you to violate subsection (f). Decline.

Keep the device's data for the retention period that applies to records of duty status. Exporting a pretty PDF and throwing away the ELD history keeps the picture and loses the original. The original is the point of this rule.

Re-certification after an edit

The driver certifies by selecting Agree under the statement that the data entries and the record of duty status for the 24-hour period are true and correct. That certification is not a one-time splash screen. 395.30(b)(4) says if any edits are necessary after the driver submits the records, the driver must recertify after the edits are made.

Recertifying a record you have not read is a false certification if the edit is wrong. Open the day, read the changed segment, read the annotation, and agree only if both are true. Reject the proposal if they are not. You do not owe dispatch a signature.

A stack of uncertified days is its own problem. Certify the true record the day it happens. Do not let a queue of proposed edits become the moment someone bulk-accepts a week. Bulk acceptance is how a single bad proposal becomes seven false days.

Edits that are just false logs

Changing driving time to off duty so a late delivery becomes legal is a false record of duty status, not an edit. 395.8(e)(1) says no driver or motor carrier may make a false report in connection with a duty status. The prohibition is the whole instruction. This page does not describe the taps, the menu, or the sequence that would make driving disappear.

The same prohibition covers shrinking the 14-hour window, moving a start time later so the window covers the delivery, and labeling highway driving as yard moves. If the correction's purpose is to make a violation look like compliance, it is not a correction.

395.30(e) adds a coercion rule inside the edit section. A carrier may not coerce a driver to certify a false record. A proposed edit that asks the driver to do that is the coercion, and the driver's job is to reject it. Pressure does not convert the false certification into a lawful one.

There is one narrow team-driver reassignment in 395.30(c)(3). It applies when a mistake assigned driving to the wrong co-driver and both drivers were already listed as co-drivers on each other's records for that period. It lets those two people put the hours on the person who was actually driving. It does not let a carrier move hours to a driver who was not in the truck, and it does not let either driver reduce the total driving the truck recorded.

What the transfer file shows an officer

Assume the officer will see the current graph, the annotations, and the original events. Edits that only look good on the driver's phone screen and ugly in the transfer are still edits. The three ways a file moves to the officer are covered in the ELD data transfer guide. This page is not a second transfer manual. Use that one when the question is web services, email, or Bluetooth. Use this one when the question is whether yesterday can be rewritten.

Before you confirm an edit, ask what the transfer will show a stranger. If the answer is a shorter driving line with a vague note, and the GPS still shows the highway, do not confirm. If the answer is a true dock time that had been left off, with the driving untouched, confirm and recertify.

Carriers should review proposed edits the way they review supporting documents. The bill of lading, the gate time, and the fuel receipt either match the new record or they do not. If they do not, reject the proposal in the office before the driver is asked to certify it. Do not make the driver the only person willing to say no.

Keep rejected proposals as well as accepted ones, in whatever history the ELD retains. A pattern of proposals that drivers reject is a dispatch problem. It belongs in coaching, not in a louder request for the same false certification.

A missing remark, a wrong city, or a duty status that was tapped off duty while the driver was actually waiting on a live dock is the kind of mistake 395.30 expects you to correct. Do that promptly, in the driver's name, with a sentence a stranger can check. Leave the automatically recorded highway driving where the vehicle put it.

When the edit is finished, look at the 11-hour total, the 14-hour window, and the 60-or-70 recap again. A true correction can make those totals worse. That is not a reason to undo the correction. It is a reason to stop the next dispatch. An edit that makes the totals prettier by hiding work has failed the accuracy sentence in 395.30(a), no matter how complete the annotation sounds.

Frequently Asked Questions