According to a recent development, the CVSA has delayed out-of-service (OOS) enforcement per the ELD mandate until April 1, 2018.

But what’s the real meaning of OOS?

We broke this news last week when the CVSA informed us about this development publicly, but there still seems to be some confusion regarding what OOS enforcement really means for fleets.

In this blog post, we take a more in-depth look and identify what it really means for fleets and truckers that are going to need electronic logging devices.

Let’s start from the top, i.e., the ELD mandate implementation deadline.

ELD mandate timeline

The final ELD rule was published by the FMCSA in 2015. According to the ELD mandate, most commercial motor vehicles (CMVs) must be equipped with compliant and certified electronic logging devices by December 18, 2017 — which is the ELD mandate deadline.

If an eligible vehicle is found to be not equipped with an electronic logging device, it could be cited, fined, and even put out of service by roadside inspectors.

However, as per the recent announcement by the CVSA, vehicles without ELDs will not be put out of service by safety inspectors after December 18, 2017, until April 1, 2018.

Does this mean they will also not be fined or cited?


If a vehicle isn’t equipped with a compliant ELD system after December 18, 2017, it would be cited and fined — as per the discretion of safety inspectors. In fact, a federal investigation could also follow if a trucking company continually violates the rule.

Does this mean that the ELD mandate implementation deadline is changed from December 18, 2017, to April 1, 2018?


The ELD mandate implementation deadline is not changed. It is still December 18, 2017. The CVSA was very clear about this point when they announced it.

In the letter that the CVSA sent to the FMCSA, informing them about this new phased-in approach, the CVSA’s Executive Director, Collin B. Mooney, wrote:

“I also want to assure you that, despite what opponents of the mandate may argue, the enforcement community is ready to begin enforcement of the requirement on Dec. 18, 2017. On that date, inspectors and roadside enforcement personnel will begin documenting violations on roadside inspection reports and, at the jurisdiction’s discretion, will issue citations to commercial motor vehicle drivers operating vehicles without a compliant ELD.”

As you can see, the only thing that’s been changed is that vehicles won’t face OOS enforcement until April 1, 2018. It also means that the ELD mandate implementation deadline has not changed at all. It’s still set to take effect from December 18, 2017.

The need for delaying OOS enforcement

This delay in OOS enforcement is meant to provide fleets with a bit more time to successfully install ELDs before the CVSA starts placing violators out of service.

The CVSA believes that this new phased-in approach “will provide the motor carrier industry, shippers, and the roadside enforcement community with time to adjust to the new requirement before vehicles are placed out of service for ELD violations.”

There is another reason for delaying the OOS enforcement, according to Collin Mooney, CVSA’s Director.

He said, “We don’t have a handle on how many motor carriers are not in compliance with the [ELD mandate] yet; some say it’s 10% while other say it’s as high as 40%. Even though we inspect only a small fraction of the trucks out there, it still gives us a good sample size as to how many are in compliance with the new rule.”

Recapping the OOS criteria

Now would also be a good time to briefly recap the out-of-service criteria — the violations for which a commercial vehicle can be placed out of service.

David Heller, who is the vice president of government affairs of TCA (Truckload Carriers Association), recently detailed the OOS criteria in a webinar earlier this year.

Following are the five major reasons why commercial trucks can be placed out of service:

  1. If they are not equipped with electronic logging devices.
  2. If they are using a non-compliant or non-authorized ELD solution that does not fulfill the requirements set by the FMCSA.
  3. If the driver of the vehicle could not produce or transfer the required ELD data to law enforcement officials.
  4. If an ELD malfunctioned, but it wasn’t replaced or repaired within eight days.
  5. If the driver did not log into the electronic logging device as required and instructed by the FMCSA.

The CVSA roadcheck 2018

As you know, the CVSA organizes a Roadcheck blitz program every year in June, which is a three-day annual event that lasts for 72 hours.

Furthermore, every year, the CVSA highlights one particular area as a “special focus”. The CVSA Roadcheck 2017 focused on “cargo securement”.

The CVSA’s Director, Collin Mooney, said that although they have not yet finalized the focus of next year’s Radcheck inspection blitz, ELDs are “high on the list”.

In his own words, “Hours-of-service enforcement has always been a key component of Roadcheck, and as we will be 6 months in with this new rule, it will be something to look at.”

And it makes a lot of sense.

The ELD mandate would be six months old by June 2018, and the CVSA can make “ELDs” the focus of 2018 Roadcheck. Moreover, since the Roadcheck would be happening after April 1, 2018, trucks found without ELDs will face OOS enforcement during the 72-hour inspection blitz.

Summarizing the meaning of OOS for fleets and drivers

OOS means out of service. OOS is a penalty incurred when violating certain aspects of the ELD mandate.

Here’s a brief summary of ELD and OOS enforcement in case you still have any confusion:

  • The ELD mandate implementation deadline is still the same as before, i.e., December 18, 2017.
  • After December 18, 2017, vehicles without ELDs will be fined and cited, based on the discretion of safety inspectors.
  • Vehicles will not face OOS enforcement for ELD violations in the period between December 18, 2017, and April 1, 2018.
  • Companies with continuous violations of the ELD rule could be subject to a federal investigation.

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