What 395.22(g) means in plain language
This regulation comes down to one simple idea: if you're running a portable electronic logging device, it cannot be loose, tucked away, or hidden from your line of sight while you're driving. The device must be secured in a fixed position and remain visible to you at all times during operation.
The rule exists because an ELD that's sliding around your dash or stuffed in a cupholder isn't really doing its job. Inspectors need to be able to see it during a roadside check, and you need to be able to glance at it without hunting for it. A cable zip-tied to a vent or a device velcroed to the windshield post but flopping around doesn't meet the standard.
In short: if your portable ELD isn't locked down in a defined spot where you — and an inspector standing at your window — can clearly see it, you're at risk of this citation every time you pull into a weigh station or get flagged for an inspection.
What our enforcement data actually shows
Across our database of 13 million+ inspections, 395.22(g) has generated 16,675 all-time citations, placing it at #157 out of 3,036 FMCSR codes by citation volume. That's a meaningful enforcement footprint — this isn't an obscure technicality that inspectors ignore.
The out-of-service picture, however, is almost entirely favorable to drivers. Of those 16,675 citations, only 22 resulted in a driver being placed out of service, yielding an OOS rate of just 0.1%. Compare that to the all-FMCSR average OOS rate of 31.4%, and it's clear that while inspectors write this violation regularly, they almost never park a truck over it. You're very unlikely to lose your ability to drive that day because of a mounting issue alone.
What should get your attention in the recent trend data: our inspection records show 0 citations in the last 90 days and 0 citations in the last 12 months. That pattern can mean enforcement focus has shifted, or that the industry has broadly corrected this issue — but it does not mean the regulation went away. If portable ELD adoption patterns shift or if enforcement priorities cycle back, this code can return to active writing.
Who gets cited most
The statistics block for this code does not include a state-by-state breakdown, so we won't speculate on which states drive enforcement volume. What the data does show is which carrier fleets have accumulated the most citations over time.
Our data shows fleets such as EVANS DELIVERY COMPANY INC (USDOT 38111) with 85 citations — the highest count in our records for this code — followed by SPG TRANSPORTATION INC (USDOT 2881143) with 31 citations. The presence of large, well-resourced carriers in these numbers reinforces that this isn't just a small-operator problem. It's a process gap that can exist in any fleet that runs portable devices rather than hardwired OEM ELD systems.
Fleet safety managers should note: when even established carriers accumulate dozens of citations for the same mounting rule, the root cause is almost always a gap in driver training or a pre-trip checklist that doesn't explicitly call out ELD position and visibility.
How severe is this compared to similar codes
Within the Hours of Service category, 395.22(g) sits well below the high-volume leaders in terms of raw citation counts, but it's far from rare.
Consider 395.24 (HOS ELD Form and Manner): our inspection records show 106,486 all-time citations — more than six times the volume of 395.22(g) — with a 0.0% OOS rate. That code covers a broader range of ELD compliance issues, which explains the higher frequency, but neither code carries meaningful OOS risk.
Now look at 395.8A1-HOSP (HOS Property — Failing to have a record of duty status using the method prescribed): 52,266 citations and a 92.9% OOS rate. That's the other end of the spectrum. A driver caught without any valid hours-of-service record faces nearly certain parking. A driver cited for 395.22(g) — a mounting and visibility issue — faces almost no OOS risk, as the 0.1% rate confirms.
Also worth noting: 395.8(e)(1) carries 78,276 citations and a 26.0% OOS rate. Violations in that range involve the integrity of the records themselves, not how the device is physically positioned. The gap between those rates and 395.22(g)'s 0.1% tells you exactly how inspectors weight a mounting issue versus a recordkeeping integrity issue.
Bottom line: 395.22(g) is a correctable equipment-position violation, not a records falsification or missing-log problem. Its severity in practice is low, but it still generates a citation on your record and contributes to your fleet's CSA score.
How to avoid it
This violation is almost entirely preventable with a few consistent habits. Add these to your pre-trip and every time you get back in the cab after a break:
- Lock the mount before you move. If your ELD uses a friction-mount, suction cup, or vent clip, physically test it — push on the device. If it shifts, it's not fixed. Tighten, reposition, or replace the mount before you pull out.
- Confirm visibility from the driver's seat. Sit in your normal driving position and look at the ELD. Can you read it without leaning or moving? Can an inspector see it from outside the driver's window? If not, reposition it.
- Check after any vibration event. Freightliner platforms (1,636 citations in our records for this code) and Volvo platforms (626 citations) appear frequently in our data. High-vibration road conditions can loosen mounts over a run. A quick check when you stop for fuel costs nothing.
- Use a dedicated mounting bracket, not a temporary solution. Velcro alone, rubber-banded devices, or a phone propped against the dash are easy targets for an inspector. A purpose-built cradle or RAM-style arm mount gives you both fixity and visibility.
- Document your mount setup in your truck's equipment notes. Fleet managers: if drivers are swapping trucks or running rental units, ensure every cab has an approved mount installed before the driver takes the wheel. Portable doesn't mean unmounted — it means the device isn't built into the dash, not that it can float around the cab.
A 395.22(g) citation is one of the easiest violations to prevent because it requires no mechanical work — just a secure, visible home for your ELD every single trip.