The electronic logging device era has not changed the standards for compliance reviews but has allowed inspectors to determine more quickly when carriers have been naughty or nice.
ELD systems enable detection of gaps in records of duty status data, so carriers should pay special attention to those issues before an inspector finds them, said Danielle Smith, transportation specialist in the passenger carrier division of the Federal Motor Carrier Safety Administration. She spoke during an online videoconference, “You, ELD Data and a Compliance Audit.” The event was hosted on Dec. 11 by United Motorcoach Association board members Joan Libby of Cavalier Coach in Boston, Mass., and Tim Stout of Stout’s Transportation in New Jersey.
“Make sure you know your system and know how to access the information that we are going to request,” Smith said. “If you can’t provide it, that tells us right up front that you are not using your system to manage the records of duty status. That puts red flags up,” she said.
More red flags
One of the biggest red flags will be over hours logged by a bus or motorcoach but not assigned to a driver. Such a gap may result from an electronic glitch or intentional interference, Smith said.
“The first thing you should do in the morning, besides taking your first cup of coffee, is look for unidentified driving,” she said.
Hours not properly attributed to a driver can lead to a serious violation for falsification of records of duty status, she said, adding that daily monitoring can enable corrections to be made sooner and more accurately.
Keep good records
Electronic glitches can cause other gaps, such as “odometer jumps” not accompanied by data logged from the vehicle’s electronic control module. Supporting documents such as fuel and meal receipts can help verify corrections, she said.
It is important to watch for evidence that glitches are being induced by drivers to mask hours of service violations, Smith said. “Make sure it is not an intentional disconnection but a loose wire or an installation problem.”
Excessive edits of driving logs can raise a red flag, too, she added. Watch to see if edits were made before the driver confirmed the record of duty status for that day or after that confirmation when the driver was close to the 70-hour rule (for operation over successive days).
Smith also warned operators to watch for the sharing of ELD log-ins, which might permit hours to be assigned to an off-duty driver when the actual driver on the road is running out of hours.
“That is one of the worst types of falsification,” she said. “It is considered aiding and abetting. Dispatchers and other motor carrier personnel are not immune to enforcement. We pursue cases against dispatchers when we find they have coerced or encouraged a driver to do this type of falsification.”
