Lawrence Hamilton II is a Partner in Holland &
Knight's
Jacksonville office
Jameson Rice is an Associate in Holland &
Knight's
Washington, D.C. office
The Federal Motor Carrier Safety Administration (FMCSA)
published its final electronic logging device (ELD) rule on Dec.
16, 2015, which the FMCSA claims, "is intended to help create
a safer work environment for drivers, and make it easier, faster to
accurately track, manage, and share records of duty status (RODS)
data."
An ELD synchronizes with a vehicle engine to automatically
record driving time for purposes of reporting hours of service
(HOS). Subject to some exceptions, the rule applies to most
carriers and drivers that are required to maintain RODS. Congress
mandated as part of the Moving Ahead for Progress in the 21st
Century Act (MAP-21) that an ELD rule be enacted for drivers of
commercial motor vehicles (CMVs) involved in interstate commerce
that are required to keep records of duty status.1