The ELD Mandate specifies that the carrier must audit the ELD logs (not the driver) to make sure the driver logs are as accurate as possible. Personal Conveyance must be done correctly, annotations must be properly used, corrective action and driver training is required, yard moves, and maintenance must be logged properly, and in the event of team drivers, the ELD must display the data for both co-drivers who are logged into the system.
Due to manual entry requirements, no log is immune to the risk of falsification. Due to the requirement of manual inputs into the ELD device itself, there is increased risk or error or falsification. There could also be instances where ELDs are switched off intentionally.
ELD’s record engine activity, but often fall short on recording human activity, such as duty status, roadside inspections, fuel stops, etc., all of which must be supplemented to engine data to complete the ELD log. Simply put, HOS driver log auditing remains an important procedure even after the ELD mandate.
Review and Monitor ELD Violations
The most common violations are usually related to the 30-minute rest break, followed by the 11-hour driving limit and 14 hours driving limit. Drivers who continue to accumulate repeated violations should be reprimanded. They should be able to plan their schedule ahead of time, and if they have problems planning their schedule, they should be re-trained again.
Review Unassigned Miles Report
Review unassigned miles report on a weekly basis and don’t allow it to accumulate. Reassigned the miles to the driver where necessary and ensure that it gets accepted. During an audit FMCSA auditor will ask for the fleet’s unassigned driver report for the month and identify if there was any event of driver log falsification. The auditor will review other related documents and ascertain if the logs were meant to be assigned to a specific driver and if the logs were not assigned, that driver logs would be considered inaccurate or even worse deemed false.
Review Odometer Jumps Report
It is important to download and review this report to ensure all driven miles are appropriately recorded. There is always a risk that driver may unplug the ELD device on purpose and the only effective way to identify this is to review this report on a weekly basis and make sure all driven miles are appropriately recorded on his or her logs. If the ELD device are unplug on purpose, drivers should be held accountable and strict disciplinary action must be taken to ensure such incidents do not recur.
Establish Personal Conveyance (PC) Policy
Personal Conveyance is allowed but based only on certain requirements and it should not be misused. More often than drivers do not annotate why PC was used and during inspection, the officer may deem that the driver misclassified driving time as PC. Its therefore important to review the use of PC on a weekly basis and ensure it is applied in accordance with the company’s Personal Conveyance Policy and not misused to do more loads.
How your assigned Freight Analytics Associate can help you manage this process better:
- Download and report the list of violations on weekly basis for management to review. This can include report on use of Personal Conveyance (PC) and whether each use of PC was appropriate
- Assist Safety Manager in reviewing list of open unassigned miles and assess where these miles should be assigned too, by reviewing the unit’s movement on that given day and ascertaining if it should be re-assigned to a driver.
- Download other ELD report such as odometer jump report and violation reports for a given week to ensure all driving hours have been appropriately recorded.
- Perform Hours of Service (HOS) audits, by comparing the ELD record for the selected driver against the loads hauled, and assess if driver had correctly recorded his drive time and break time by making comparison to supporting documents such as fuel and toll receipts.
