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COUNTDOWN TO FULL ELD COMPLIANCE - PART 3: 6-POINT DRIVER TRAINING CHECKLIST

Make sure your drivers are trained to understand and follow key hours-of-service rules.
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Daren Hansen - DOT Sr. Editor - J. J. Keller & Associates, Inc.

September 26 , 2019

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:

Limits and Breaks

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:

  • Related company policies
  • Definitions of on-duty and off-duty time
  • Calculating and tracking limits
  • Taking rest breaks and avoiding fatigue

Form and Manner

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:

Personal Conveyance

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:

Supporting Documents

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:

  • Identify a supporting document
  • Present supporting documents to roadside enforcement personnel
  • Submit supporting documents

ELDs

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:

  • Installing and using the electronic logging devices required by your company
  • Applicable regulations and documentation requirements
  • Information about the “back office” system
  • Interacting with enforcement personnel

Exceptions

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:

CDL Driver Short-Haul Exception

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:

  • Driving, on-duty, and distance limits that must be observed
  • Who can use the 100-air-mile exception and how to calculate it
  • Recordkeeping requirements
  • Discussing the exception with roadside enforcement personnel

Non-CDL Driver Short-Haul Exception

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:

  • Driving, on-duty, and distance limits that must be observed
  • Who can use the 150-air-mile exception and how to calculate it
  • Recordkeeping requirements
  • Discussing the exception with roadside enforcement personnel

Other Popular Exceptions

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:

  • Exceptions allowed by your company
  • When and to whom each exception applies
  • Applicable paperwork and logging requirements
  • Action that will be taken if a driver fails to comply with the terms of the exception

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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