Supporting Documents and the ELD Rule

The supporting documents rule sets the bar for recordkeeping in the electronic age.

Published On: 01/07/2019
Supporting Documents and the ELD Rule Compliance Brief
J. J. Keller Editor Rick Malchow

Written by:

Rick Malchow

Industry Business Advisor — J. J. Keller & Associates, Inc.

Asupporting document is defined in the FMCSA’s ELD final rule as “a document, in any medium, generated or received by a motor carrier in the normal course of business as described in §395.11 that can be used, as produced or with additional identifying information, by the motor carrier and enforcement officials to verify the accuracy of a driver’s record of duty status.”

The FMCSA makes it clear that supporting documents are not meant to validate drive time, because ELDs will do that. Rather, supporting documents “are still needed to verify on-duty not driving time (ODND).”

5 Types of Supporting Documents

  1. Bills of lading, itineraries, schedules, or equivalent documents that indicate the origin and destination of each trip
  2. Dispatch records, trip records, or equivalent documents
  3. Expense receipts
  4. Electronic mobile communication records, reflecting communications transmitted through a fleet management system (FMS) (the record is counted as one document)
  5. Payroll records, settlement sheets, or equivalent documents that indicates payment to a driver

Supporting Document Requirement Summary

Motor carriers must retain up to eight supporting documents for every 24-hour period a driver using ELDs is on duty.

Carriers must retain record of duty status (RODS) and supporting documents for six months.

Drivers must submit supporting documents to the motor carrier no later than 13 days after receiving them.

The documents should contain all of the following elements:

  • Driver name or driver number, either on the document or on another document enabling the carrier to link the document to the driver, or the vehicle unit number if that number can be linked to the driver
  • Date
  • Location (including name of nearest city, town or village)
  • Time

If a driver has fewer than eight documents that include the four elements above, a document that contains all of the elements except time is
considered a supporting document; otherwise, it is not.

If a driver submits more than eight documents, the motor carrier must include the first and last documents for that day.

If a driver submits fewer than eight documents, the motor carrier must keep each document.

If a driver records duty status on paper logs, all toll receipts are also supporting documents.

Upon request during a roadside inspection, a driver must make available to an authorized Federal, State, or local official for the official’s review any supporting document in the driver’s possession.

The carrier must retain supporting documents in such a manner that they may be effectively matched to the corresponding driver’s record of duty status.

The driver is not responsible for procuring all supporting documents and in fact may never see some of the documents. At a roadside inspection, the driver is only responsible to share the supporting documents that he or she has in the vehicle.

Exemptions from the Supporting Documents Provisions

The final rule specifically exempts two types of drivers or operations:

  1. Short-haul drivers as defined by the short-haul exemptions of §395.1(e)
  2. Drivers for a private motor carrier of passengers (non-business) or non-business PMCP
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