What 395.24(d) means in plain language
This regulation requires that your Electronic Logging Device be capable of transmitting your hours-of-service records to an authorized safety official through an approved electronic transfer method. When an inspector requests your ELD data during a roadside check, the device is supposed to send those records wirelessly or via another approved electronic means — not just display them on a screen.
A citation under 395.24(d) means the officer determined your ELD failed to complete that electronic transfer. The device itself may have malfunctioned, lost connectivity, had a software or firmware issue, or the transfer process was not initiated correctly. In any of these scenarios, the inspector's ability to remotely review your logs was compromised.
It's worth being clear about what this violation does not mean: it is not an accusation that your logs are falsified or that your hours are out of compliance. It is specifically about the transfer mechanism failing — a technical failure that has real compliance consequences regardless of whether your actual driving record is perfect.
What our enforcement data actually shows
Across our database of 13 million+ inspections, 395.24(d) has accumulated 17,629 all-time citations, placing it at #153 out of 3,036 FMCSR codes by citation volume. That ranking puts it solidly in the upper tier of enforcement activity — this is not an obscure or rarely-enforced rule.
Despite that volume, the out-of-service impact is almost negligible. Of those 17,629 citations, only 42 resulted in a driver being placed out of service, producing an OOS rate of just 0.2%. To put that in perspective, the all-FMCSR average OOS rate across every code in our database is 31.4%. The 395.24(d) rate of 0.2% is dramatically below that average, which tells you something important: inspectors cite this violation routinely, but they almost never take the step of pulling a driver out of service for it alone.
Looking at recent enforcement activity, our inspection records show zero citations in the last 90 days and zero in the last 12 months. That sharp drop from the all-time volume of 17,629 suggests enforcement of this specific sub-section has effectively paused — possibly due to updated inspection procedures, software improvements across the ELD market, or shifts in inspector focus toward other ELD sub-sections. Whatever the reason, the all-time record still matters because those citations remain on carrier safety profiles and can factor into SMS scores.
Who gets cited most
The STATISTICS block for this code does not include a state-by-state breakdown, so no specific state rankings can be reported here. What our data does show clearly is the carrier distribution. Among the fleets with the highest all-time citation counts for 395.24(d), our records indicate carriers such as SWIFT TRANSPORTATION CO OF ARIZONA LLC (USDOT 54283) with 96 citations and CENTRAL TRANSPORT LLC (USDOT 661173) with 75 citations appear at the top of the list. J B HUNT TRANSPORT INC (USDOT 80806) follows with 50 citations.
These are all very large carriers operating enormous fleets across many states and inspections. A higher raw citation count at a major carrier reflects exposure volume — more trucks on the road means more inspections. Our data does not indicate anything about those carriers' safety culture beyond the raw counts.
On the equipment side, FRHT (Freightliner) units account for 2,269 of the all-time citations — by far the most of any make. UTIL trailers follow at 1,053 citations, and VOLV (Volvo) tractors appear at 762 citations. If you drive a Freightliner, this data point is a reason to pay closer attention to your ELD's transfer functionality during pre-trip.
How severe is this compared to similar codes
Placing 395.24(d) alongside its peer codes in the Hours of Service / ELD category gives important context.
395.24 (ELD Form and Manner violations broadly) has accumulated 106,486 citations with a 0.0% OOS rate — six times the volume of 395.24(d) and similarly non-OOS in practice. That comparison tells you the broader ELD form-and-manner category is heavily enforced but rarely triggers roadside removal.
Move one category over and the severity picture changes significantly. 395.8(a)(1) — cited when a driver is not using the appropriate method to record hours of service — carries a 93.2% OOS rate across 39,561 citations. Similarly, 395.8A1-HOSP (failing to have a record of duty status using the required method for property carriers) sits at a 92.9% OOS rate across 52,266 citations. Those two codes represent the scenario where a driver has no compliant record at all — a fundamentally different and far more serious problem than a transfer failure.
The takeaway: a 395.24(d) citation is a technical paperwork-tier violation. It affects your CSA score and your carrier's SMS profile, but the 0.2% OOS rate means it almost never stops your truck. The codes that will stop your truck — and stop it nearly every time — are the ones involving missing or falsified records entirely.
How to avoid it
Because 395.24(d) is a technical transfer failure, prevention is almost entirely about device readiness before you pull out of the yard. Here are concrete steps you can take:
- Test your ELD's transfer function during pre-trip. Many ELD platforms include a self-test or diagnostic mode. Use it. Confirm the device can initiate a transfer before an officer has to ask for one.
- Verify cellular or Bluetooth connectivity before departure. If your ELD relies on a cellular data connection to transmit records, make sure the device shows an active connection — not just that your cab has phone signal. A device in airplane mode or with a dead data plan will fail the transfer.
- Keep firmware and app software current. Our data shows Freightliner-platform vehicles (2,269 citations) and Volvo units (762 citations) appear frequently in 395.24(d) records. If your truck's ELD is integrated with the vehicle system, check that the OEM software has no pending updates before long hauls.
- Know your ELD's manual backup procedure. Even if a transfer fails, being able to immediately display your logs on-screen and walk the inspector through them demonstrates good faith and is often the difference between a citation-only outcome and a more serious interaction.
- Carry your ELD provider's support number in the cab. If an inspector triggers a transfer attempt and it fails, being able to call technical support in real time — and having that call documented — shows you are not attempting to conceal records.
- During pre-trip on FRHT or VOLV equipment specifically, check that the ELD mounting and cable connections are secure. Vibration over long routes can loosen connections on integrated systems, causing intermittent transfer failures that work fine in the yard and fail at the scale.