Tom Bray - Industry Consultant - J. J. Keller & Associates, Inc.
August 20 , 2019
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Regulations governing electronic logging devices (ELDs) require drivers and other motor carrier personnel to enter certain annotations into the ELD record. Annotations — comments added to a driver’s ELD record — are used to explain any special exemptions that apply, any edits that were made, or any other special circumstances that exist.
The trouble is, the hours-of-service regulations offer no guidance on what the annotations should say, and annotations are restricted to just 60 characters. This can make it difficult to decide how to write one.
Some annotations are mandatory, like when submitting records during a roadside inspection or editing a record. Others simply offer an explanation. An annotation is “regulation speak” for “entering a comment.”
A well written annotation will explain what was going on during a specific occurrence or a driver’s day. Perhaps a driver hit heavy traffic and used the “adverse conditions” exception or forgot to switch to “personal use” when driving to a local restaurant for lunch. Without an annotation, it may appear to anyone reviewing the record that there is a violation or falsification. This makes a properly written annotation vital to compliance.
The following are suggested annotations that drivers and ELD administrators can use to explain exceptions or exemptions. Keep in mind that annotations should be clear, concise, and refer to a regulation whenever possible.
Some ELDs may automatically account for the use of some of these exemptions and may make manual annotations unnecessary. Drivers should check with their safety office for details. When applicable, and as space allows, drivers should also enter a document number for any documentation (e.g., shipment number, BOL number, work order number, etc.) that can support their claim of an exemption.
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