Daren Hansen - DOT Sr. Editor - J. J. Keller & Associates, Inc.
September 26 , 2019
The Fleet Manager's Playbook
Build a Best-in-Class Performance Management Program!
Take a proactive approach to identifying and correcting inefficient and unsafe driving behaviors so you can maximize results and mitigate risk.
This playbook helps you determine how to take advantage of the volume of data generated from your vehicle safety systems, electronic logging devices, and cameras.
Hours-of-service rules are ever-changing, full of exceptions, and open to interpretation — making them a critical and essential component for training. Using our 6-point checklist for driver training, you can help your employees learn the basic limits, exceptions they may be eligible for, supporting documents they have to keep, and how to avoid some of the most commonly cited violations.
On a daily or as needed basis, make sure your drivers understand and are able to follow these key hours-of-service rules:
Convey the basic requirements for how long drivers may operate a commercial motor vehicle (CMV) and/or be on duty before they have to stop driving, and how long they’re required to rest, at minimum. The rules are much more complex than the limits indicate, so a formal training program should be implemented to communicate the requirements in their entirety, including:
Drivers must show they’re complying with the hours-of-service limits by keeping a detailed record of their time. Knowing which type of record to use — and how to use it — is critical. The “form and manner” in which logs are created remains the number one most common violation at the roadside, making it vital to provide training on:
Perhaps no hours-of-service topic has created as much confusion over the years as the “personal conveyance” (PC) provision, which allows drivers to operate their commercial vehicles in an “off duty” status for personal reasons. Given the confusing nature of the PC provision, driver and dispatcher training on the following is critical to avoid violations:
The rules for supporting documents changed when ELDs were introduced, with new requirements for what has to be kept and what’s expected of drivers. “Supporting” documents are those that investigators may use to audit your logs, so drivers and support personnel must be trained regarding how to:
Drivers must be familiar with the rules that apply to — and must be able to converse with enforcement personnel about — the electronic logging device they’re using. Misunderstandings about logging technologies have led to many unnecessary violations, penalties, arguments and headaches, which is it is vital to provide training on:
In addition to establishing clear policies regarding the use of exceptions, in-depth training can help dispel any myths about how the exception applies. The most common exceptions used by drivers include:
This exception is for drivers of vehicles that require a CDL, stay within a 100-air-mile radius, and return home each day. It is NOT an exemption from all safety regulations or hours-of-service regulations, and only exempts drivers from logs, supporting documents, and (for truck drivers) 30-minute breaks. Drivers must still follow daily and weekly driving and on-duty limits, and all safety regulations. Key training points should include:
This exception is restricted to drivers of property-carrying vehicles who are not required to have a CDL for the vehicle they drive (whether the driver happens to hold a CDL or not). This generally includes non-placarded trucks under 26,001 pounds. Key training points should include:
The phrase, “To every rule there is an exception” is especially true with hours of service. Hours-of-service exceptions can be useful, but also quite risky, as a driver can mistakenly believe they’re eligible or misuse the exception. Because either situation can result in violations, penalties, and added liability, key training points should include:
For additional guidance preparing for the final ELD mandate deadline, see Part 1 and Part 2 of our Countdown to Full ELD Compliance series.
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