What is unidentified driving time on an ELD?
Unidentified driving time is one of the most common ELD issues that drivers and fleet managers encounter.
It occurs when an ELD records driving activity but cannot associate that activity with a specific driver profile. This can happen when a truck is driven before a driver logs into the ELD or when the wrong driver profile is active.
For fleet managers, unidentified driving time should not simply be ignored. FMCSA requires carriers and drivers to review unassigned driving records and take appropriate action.
In this guide, we'll explain what unidentified driving time is, why it happens, how drivers should handle it, and what carriers need to know about FMCSA requirements.
What is unidentified driving time?
Unidentified driving time is driving activity recorded by an ELD under its Unidentified Driver (UD) profile rather than under a specific driver's account.
For example, imagine a truck leaves the yard at 7:00 AM, but the driver has not yet logged into the ELD. The vehicle begins moving, and the ELD records the driving activity.
Because no driver is logged in, the ELD cannot associate that driving with a specific driver. The time is therefore recorded under the Unidentified Driver profile.
FMCSA requires ELDs to record this activity when a driver has not logged in and does not respond to the ELD's visual and audible prompts.
Why does unidentified driving happen?
There are several situations that can result in unidentified driving time.
1. The driver starts driving before logging in
This is one of the simplest causes.
A driver gets into the truck, starts the engine, and begins driving without first logging into the ELD.
The device records the vehicle movement, but there is no active driver profile associated with that movement.
2. The wrong driver is logged in
If one driver is logged into the ELD while another driver operates the vehicle, the driving activity may be associated with the wrong account or become part of the unidentified records that need to be reviewed.
This can happen when drivers switch vehicles or when multiple drivers use the same truck.
3. A driver forgets to claim unidentified driving
A driver may see unidentified driving records when logging into the ELD but fail to review or claim them.
FMCSA requires a driver to review unassigned driving time when prompted after logging into the ELD. If the records belong to the driver, the driver must add that driving time to their own record. If they do not belong to the driver, the driver must indicate that.
4. Vehicle movement occurs during a driver change
When trucks are shared between drivers, a short period of driving during a driver change can create unidentified records if the new driver has not yet logged in.
This is one reason fleets should establish a consistent procedure for driver changes.
How does an ELD record unidentified driving?
When a driver has not logged into the ELD and does not respond to the device's prompts, the ELD records accumulated driving and On-Duty Not-Driving time according to its required default behavior.
The ELD also associates certain events with the Unidentified Driver profile, including vehicle engine power-up and power-down events and power compliance monitoring.
The purpose is to preserve the electronic record instead of simply losing vehicle activity because no driver profile was active.
When does the unidentified driving diagnostic event occur?
An important distinction is the difference between unidentified driving records and an unidentified driving records data diagnostic event.
FMCSA states that the diagnostic event occurs when more than 30 minutes of driving time for an unidentified driver is recorded within a 24-hour period.
When this threshold is reached, the ELD data diagnostic indicator is activated across drivers logged into that ELD for the current day and the following seven days.
This does not mean that every unidentified driving record automatically becomes a violation. It means the ELD has reached the regulatory threshold for the diagnostic event and the records need to be properly reviewed and handled.
What should a driver do with unidentified driving time?
When a driver logs into an ELD, the driver should review any unassigned driving records presented by the system.
There are two basic possibilities.
If the driving belongs to the driver
The driver should claim the appropriate unidentified driving time and add it to their own record.
FMCSA allows unidentified driving time to be assigned to the driver when the driver accepts the records.
If the driving does not belong to the driver
The driver should indicate that the unidentified driving does not belong to them.
The record should not simply be claimed because it is convenient.
The purpose of the review process is to ensure that driving activity is associated with the correct driver.
Can a carrier assign unidentified driving time?
Yes.
A motor carrier can later assign unidentified driving records to the appropriate driver.
However, the driver must accept the assignment.
Under FMCSA's requirements, the carrier must either assign the unidentified driving time to the appropriate driver or annotate the record and explain why the time remains unassigned.
This means fleet managers should have a process for regularly reviewing unidentified driving rather than allowing a large amount of unassigned activity to accumulate.
What happens if a driver accepts unidentified driving?
The original unidentified records do not simply disappear.
FMCSA explains that the original records remain with an inactive status. When the records are assumed by the driver, new event records are created using information from the unidentified records and the driver's input.
This is important because ELD records are designed to maintain an electronic history of events rather than allowing original records to be silently erased.
What if the driver rejects unidentified driving?
If a driver rejects unidentified driving records, those rejected events remain available for roadside review for 8 days and should be included in the ELD output file.
This is one reason drivers should not treat the unidentified driving section as something that can simply be ignored.
Are unidentified driving records visible during a roadside inspection?
Yes.
FMCSA requirements provide for the inspected driver's profile and the Unidentified Driver profile to be available as separate reports at roadside, either by display or printout.
If there are no unidentified driver records for the current 24-hour period or the previous seven consecutive days, the ELD does not need to display or print the unidentified records for the authorized safety official.
For carriers, this makes regular review of unidentified driving particularly important.
How long must carriers keep unidentified driving records?
Motor carriers must retain unidentified driving records for at least six months from the date they receive them.
These records are part of the carrier's ELD hours-of-service records and must be made available to authorized safety officials when required.
So even after an unidentified record has been reviewed and appropriately assigned or annotated, the underlying electronic record is part of the carrier's retained records.
Can unidentified driving records be deleted?
The original records should not simply be deleted.
For example, when a driver accepts unidentified driving, the original records remain with an inactive status and new records are created for the driver's log.
FMCSA also explains that when an unidentified driving diagnostic event is cleared after the unidentified driving falls below the applicable threshold, only the diagnostic event becomes inactive; the underlying records that generated it are not deleted.
How can fleet managers reduce unidentified driving time?
A large amount of unidentified driving can often be reduced through consistent fleet procedures.
Make logging in part of the pre-trip routine
Drivers should log into the ELD before beginning normal driving activity.
Review unidentified driving regularly
Fleet managers should monitor unidentified records rather than waiting until an inspection or audit.
Establish driver-change procedures
If multiple drivers operate the same vehicle, establish a clear process for logging out and logging in when drivers change.
Train drivers on ELD prompts
Drivers should understand what the unidentified driving prompt means and what they need to do when they see one.
Monitor shared vehicles
Trucks used by multiple drivers require additional attention because driver changes can create unassigned activity.
Use fleet-level ELD monitoring
A fleet management dashboard can make it easier for managers to identify vehicles or drivers associated with recurring unidentified driving.
What is the difference between unidentified driving and an ELD malfunction?
These two issues should not be confused.
Unidentified driving generally means the ELD recorded driving activity but could not associate it with a specific driver.
An ELD malfunction, on the other hand, involves a failure affecting the device's ability to perform required functions.
For example, FMCSA separately defines an unidentified driving records data diagnostic event and various ELD compliance malfunctions.
If an ELD is malfunctioning, drivers and carriers must follow the applicable malfunction procedures. Unidentified driving should instead be reviewed and assigned or annotated according to the applicable requirements.
What should fleet managers check?
Fleet managers can use the following checklist when reviewing unidentified driving:
- Check which vehicles have unidentified driving
- Review the time and duration of each event
- Determine which driver was operating the vehicle
- Assign records to the appropriate driver when applicable
- Ask drivers to accept assigned records
- Annotate records that remain unassigned when required
- Monitor recurring unidentified driving
- Train drivers who repeatedly start driving before logging in
- Retain unidentified records as required
A consistent review process can make unidentified driving much easier to manage.
How Unity ELD can help
Unidentified driving is easier to manage when drivers and fleet managers have clear visibility into ELD records.
Unity ELD can help fleet managers monitor driver activity and review electronic logs from a centralized platform.
Instead of discovering unidentified driving only when an issue comes up, fleet managers can incorporate log review into their regular compliance workflow.
The goal is simple: make it easier to see what happened, determine which driver was responsible, and keep ELD records organized.
Frequently asked questions
Is unidentified driving automatically a violation?
Not necessarily. Unidentified driving is a record that needs to be reviewed and appropriately handled. FMCSA separately defines the threshold for an unidentified driving records data diagnostic event.
How much unidentified driving triggers a diagnostic event?
More than 30 minutes of unidentified driving within a 24-hour period triggers the unidentified driving records data diagnostic event.
Can a driver claim unidentified driving?
Yes. If the unidentified driving belongs to the driver, the driver can claim it when prompted by the ELD.
Can a fleet manager assign unidentified driving?
Yes. A motor carrier can assign unidentified driving records to the appropriate driver, but the driver must accept the assignment.
How long are unidentified driving records kept?
Motor carriers must retain unidentified driving records for at least six months from the date of receipt.
Can unidentified driving records be removed from the ELD?
The original records are not simply deleted when they are assigned. FMCSA states that original unidentified records remain with inactive status while new records are created for the driver.
Are unidentified driving records visible during an inspection?
Yes. When applicable, the Unidentified Driver profile must be available separately for roadside review.
Final thoughts
Unidentified driving time is a normal ELD record that occurs when vehicle movement cannot initially be associated with a specific driver.
The important part is what happens afterward.
Drivers should review unidentified records when prompted, claim the records that belong to them, and reject records that do not. Carriers should regularly review unassigned driving, assign records when appropriate, annotate records that remain unassigned, and retain the required records.
A consistent ELD review process can help fleets maintain cleaner records and identify problems before they become more difficult to resolve.