When Paper Logs Are Required
Paper logs during an ELD malfunction are required in two situations: first, if the ELD cannot record at all and no replacement is immediately available, paper logs should begin immediately for that period; second, if the carrier has not repaired or replaced the device within 8 days of the driver's notification, paper logs are required for the remainder of the malfunction period.
Paper logs are not a general fallback that a driver can choose at will — they are specifically required during defined malfunction conditions. Outside of a confirmed malfunction, a driver subject to the ELD mandate must use a compliant ELD.
Completing Paper Logs During A Malfunction
Paper logs completed during an ELD malfunction must meet the same content requirements as any paper HOS record: date, total miles, truck and trailer number, carrier name, home terminal address, signature, and the 24-hour grid showing duty status changes with times.
The driver should also note on the record that the entries are being kept on paper due to an ELD malfunction. This annotation makes the paper period self-explanatory if the records are reviewed later.
Supporting Documents
Supporting documents — fuel receipts, toll records, dispatch logs, border crossing records, inspection receipts — serve as corroborating evidence for paper log entries during a malfunction period. They help demonstrate the accuracy of the reconstructed records if an auditor or inspector reviews the period.
Retain all available supporting documents from the malfunction period. They do not need to be attached to the paper log, but they should be retained and available for the carrier's records.
Transitioning Back To Electronic Logging
When the ELD is repaired or replaced, the driver transitions back to electronic recording. The paper records from the malfunction period should be provided to the carrier and retained according to the standard 6-month record retention requirement. The replacement device should be verified as functioning correctly before the driver begins a new duty period.
Related Pages
Related Fault Code Pages
Sources
- ELD Malfunctions and Data Diagnostic Events Federal Motor Carrier Safety Administration · government · accessed 2026-05-05 · confidence high
Source: Federal Motor Carrier Safety Administration, ELD Malfunctions and Data Diagnostic Events. This page paraphrases factual fields only and is not a substitute for the original document.
Open source - 49 CFR 395.34 - ELD malfunctions and data diagnostic events Electronic Code of Federal Regulations · government · accessed 2026-05-05 · confidence high
Source: Electronic Code of Federal Regulations, 49 CFR 395.34 - ELD malfunctions and data diagnostic events. This page paraphrases factual fields only and is not a substitute for the original document.
Open source - 49 CFR Part 395 Appendix A to Subpart B - Functional Specifications for ELDs Electronic Code of Federal Regulations · government · accessed 2026-05-05 · confidence high
Source: Electronic Code of Federal Regulations, 49 CFR Part 395 Appendix A to Subpart B - Functional Specifications for ELDs. This page paraphrases factual fields only and is not a substitute for the original document.
Open source
FAQ
Can a driver use a paper log app on their phone during a malfunction?
The ELD mandate requires electronic logging using a registered, compliant ELD. During a malfunction period when paper logs are required, actual paper forms are the specified alternative — not a phone app that mimics the grid format. Consult FMCSA guidance for any regulatory updates on digital alternatives to paper logs during malfunction periods.
How far back does the driver need to reconstruct records during a malfunction?
Under 49 CFR 395.34, drivers must reconstruct the previous 7 days of duty status records on paper when the ELD cannot be corrected within 8 days. Records from more than 7 days before the malfunction are subject to standard retention requirements but do not need to be reconstructed on paper.
What happens if supporting documents are not available for the full malfunction period?
Reconstruction should use all available supporting documents. If some periods cannot be fully corroborated by documents, reconstruct from memory as accurately as possible and note where documentation was not available. A good-faith reconstruction using available evidence is better than no record for the period.