Learn how to develop or adjust your policies and procedures to align with ELD requirements.

Mark Schedler - Sr. DOT Editor - J. J. Keller & Associates, Inc.

August 30 , 2019

Your fleet should already have written policies and procedures covering expectations for drivers and other company personnel operating with electronic logs, but updates may be needed to align with the requirements of using ELDs. When getting ready for the ELD Mandate, you’ll be much better prepared for the transition if your team has a clear understanding of your operation’s policies and procedures. Ensure the expectations for operating with electronic logging devices (ELDs) are clear by developing or adjusting your policies and procedures to cover the following best practices.

ELD Compliance Best Practices

  1. Training. Establish initial and ongoing hours-of-service training for drivers and supervisors, including proper use of exceptions (and annotations when using those exceptions or going over hours-of-service limits), and operation of the electronic logging device (ELD).
  2. Assigning Responsibilities. Document who will have authority to do which actions within the ELD back-office system, including account maintenance, log auditing, and reviewing unassigned driving events.
  3. Auditing. Provide specific guidance on auditing logs to detect the new methods of falsification.
  4. Setting Supporting Document Limitations. Limit supporting documents to eight per driver, per duty day, within the five categories of required documents – per the ELD final rule and §395.11.
  5. Determining Availability. Require supervisors to consider the driver’s available hours and level of fatigue when assigning a movement – include actions to take when a driver’s hours are insufficient for a movement.
  6. Prohibiting Harassment and Coercion. Prevent harassment and coercion of drivers by anyone in the organization, and define each and the differences between the two.
  7. Counseling and Correcting. Outline how and when drivers are to be counseled, retrained, and disciplined when violations, improper edits, tampering, or falsification occurs.

Other ELD-related policies and procedures to consider are:

  • Requiring drivers to properly handle ELD malfunctions and transfer/display data for roadside inspections.
  • Defining the requirements of the “Personal Use” (off-duty driving) option (if you allow personal use of your vehicles) to include any changes that you want to allow based on the June 2018 revision of interpretation #26 in 395.8 by FMCSA.
  • Defining the requirements to use the “Yard Move” option, which drivers and company mechanics can choose if they move trucks on private property that is restricted from public access. ELDs must automatically record drive time at 5 mph or greater as “on-duty driving,” so this is an option to reduce unassigned drive time events.
  • Determining whether each company mechanic will have an ELD account to reduce unassigned driving events when operating a truck. It is not required to have ELD accounts for most company mechanics because they stay within a radius (100 to 150 air-miles) considered to be exempt from logging. For truck repair vendors, do not create an account. The back-office personnel will need to annotate the vendor-generated unassigned events.

In the end, policies and procedures are only valuable if followed consistently by your team. Make sure your fleet is well positioned for the December 16, 2019 ELD mandate deadline by applying any necessary changes to your current policies and procedures, and clearly communicating expectations across your operation. 

For additional guidance, request your FREE copy of the ELD Policies & Procedures: The Foundation of ELog Success whitepaper.  


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