Tom Bray - Industry Consultant - J. J. Keller & Associates, Inc.
August 20 , 2019
FLEET MANAGER'S PLAYBOOK
Use all the data generated from vehicle safety systems, electronic logging devices, and cameras to develop programs to reduce risk, create policies and procedures and coach your drivers.
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 forgot to log out or incorrectly recorded on-duty time as off-duty. 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 log edits or suggested edits. Keep in mind that annotations should be clear and concise.
Before the driver certifies their electronic log, the driver must review the ELD records, edit, and correct inaccurate records, and enter any missing information. The rules require that the driver annotate each change or addition made to a record. Drivers should check with their safety office or refer to their user’s manual for details on how and when to edit their record.
ELD Transition Guidance From Fleets That Know
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FMCSA Proposed Changes to Create Flexibility in HOS Rules
Learn the implications of FMCSA's recently proposed changes to the hours-of-service rules.
ELD Annotations: Exemptions
Read this compliance brief for suggested annotations that explain log exemption edits.