FMCSR 395.15F: Onboard Recording Device Failure Q&A

No. Across our inspection records, 395.15F citations have resulted in zero out-of-service placements. Our data shows a 0.0% OOS rate for this violation code across all 5 citations in our database. This is significantly below the 31.4% average OOS rate across all FMCSR codes, meaning 395.15F is typically treated as a non-immediate compliance issue rather than a safety-critical roadside action.

First, document everything about the citation—date, location, and the specific onboard recording device issue noted. Second, review your ELD or recording device logs and reconstruct the missing or incomplete information immediately. Third, contact your carrier's compliance team if you're leased. Our inspection data shows that 395.15F frequently co-occurs with 395.8F01 (driver's record of duty status not current) in the same inspection, so ensure your duty status records are complete and accurate. Fourth, photograph your device's display or error messages for your records.

No. While 395.15F itself carries a 0.0% OOS rate, peer violations in the same category vary widely. For example, 395.8A1 (failing to have a record using the prescribed method) has a 92.9% OOS rate, and 395.8(a)(1) (not using the appropriate recording method) reaches 93.2% OOS. By contrast, 395.24 (ELD form and manner violations) also has a 0.0% OOS rate. 395.15F ranks #2406 of 3,036 FMCSR codes by citation volume, placing it well below the most frequently cited violations.

Our database contains 5 all-time citations for 395.15F, with 3 citations in the last 12 months and 1 in the last 90 days. This extremely low enforcement volume reflects that the violation is rare in practice. Citations were distributed across August 2025, September 2025, and February 2026, with no clear seasonal pattern. North Carolina accounts for 1 citation in the last 180 days.

Based on the last 180 days of inspection records, North Carolina is the only state with a recorded 395.15F citation (1 citation, 0.0% OOS rate). The extremely limited geographic data reflects how rarely this violation is enforced nationally. Given the small sample, citation location cannot be reliably predicted, but drivers should ensure their onboard recording device functions and can reconstruct hours of service data in any state.

Yes. DataQs (the FMCSA's Challenge Process) allows you to contest roadside inspection records if you believe the citation was issued in error or the evidence does not support the finding. For 395.15F, contestability typically hinges on whether you can demonstrate that your onboard recording device was functioning and that reconstructed duty status information was available or accurately provided. Document your device logs, error codes, and any contemporaneous records. Consult your carrier's safety manager or a compliance professional to evaluate the strength of your challenge before submitting.

Our all-time data shows five carriers with one citation each: L AND C FARMS LLC (USDOT 1849754), CSK LOGISTICS LLC (USDOT 3348129), CLEMENT TRANSPORT LLC (USDOT 3628), BARNHART DRIVEAWAY LLC (USDOT 3994775), and A1 ROADMAP LOGISTICS LLC (USDOT 4301615). No carrier shows a pattern of repeated 395.15F citations, confirming the violation's rarity across the trucking industry.

While not immediate (0.0% OOS rate), address it promptly. You have a compliance obligation to maintain a functioning onboard recording device and the ability to reconstruct hours of service data. Since only 1 citation occurred in the last 90 days, enforcement is infrequent, but that does not reduce your legal duty. Contact your carrier or a fleet compliance service to verify your device is recording properly and that you can reconstruct all required information. Delay increases the risk of repeat citations or escalation during a roadside inspection.