Sr. Industry Business Advisor — J. J. Keller & Associates, Inc.
Read this compliance brief for suggested annotations that explain log edits.
Written by:
Tom Bray
Sr. Industry Business Advisor — J. J. Keller & Associates, Inc.
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.
Reason for Log Edit | Suggested Annotation |
---|---|
Log out error | Forgot to log out at proper time |
Log in error | Forgot to log in at proper time |
Missed duty status change | Forgot to lof off duty for break Forgot to switch to SB (sleeper birth) Forgot to switch to on duty |
Duty status changes took place while the driver was away from the logging device | Duty status changed when away from ELD |
Driving time cannot be assigned to a specific ELD driver account | Drive time unassignable: _______(explain) At shop for repair, driven by third party (other details should be added as avaialble, such as shop name, work order number, etc. Driven by exempt driver: _____ (explain why driver is not assigned an ELD account and identify driver if possible |
Yard move logged as driving | Forgot to switch to yard move |
Driving logged as yard move | Forgot to switch to normal driving |
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.
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