• Drivers must follow a specific process involving ELDs, manually entry of data and comments, and enter the comments requested by the officer when transferring records to an officer during a roadside inspection.
• During a roadside inspection, a driver must be able to display or print logs, along with using “telemetric” or local” methods to transmit data when requested.

Drivers have to manually input information when prompted by the electronic logging device (ELD) and required by the motor carrier, including any notes, a location description if necessary, and comments needed when transferring data to an enforcement officer. They also must input or verify the power unit number, trailer number(s), and shipping document number(s), as applicable.

Required use and submission

Drivers must log in and out at the appropriate time, make the required entries at the appropriate time, review their ELD records, edit and correct inaccuracies, and enter any missing information. The information a driver will need to enter includes vehicle numbers. The truck number may already be programmed into the device, but the driver will need to enter trailer numbers. Shipment information also must be entered.

Another required entry is if for some reason the ELD cannot locate its position automatically when necessary (such as during a manual duty change). When this happens, the device will ask the driver to manually enter the location (city and state, or a description of where the driver is and the nearest city and state).

The driver must certify the log after the last duty change of the day, and then submit the completed log within 13 days. Logging out at the end of the day is different than certifying and submitting, so drivers will need to become familiar with the process of certifying and submitting logs using the system their company provides.

Driver annotations (comments)

Drivers must add comments (called “annotations” in some systems) to the record for the day. There are several reasons for wanting to place comments into the record for the day. Common reasons for a driver comment include:

• Explaining why the driver went over hours (required);
• Explaining which exception was being used that allowed hours to be exceeded (required);
• Indicating the beginning of the use of a special driving category (required);
• Noting any vehicle inspections (optional or a company requirement at some carriers);
• Noting fueling (optional or a company requirement at some carriers - some carriers also require the driver to note the fuel vendor and number of gallons, and/or to upload the receipt);
• Providing a brief explanation of what the driver was doing during any on-duty time (optional or a company requirement at some carriers); and
• Asking “official” questions related to hours-of-service issues (recommended).

Another situation that would require a comment is if an error was made that led to driving time being incorrectly assigned to the driver. Automatically captured driving time cannot be changed, shortened, shifted, altered, or deleted. If a driver ended up with driving time that was logged incorrectly, the driver must add a comment explaining that the driving time is incorrect and providing the correct driving times.

Supporting documents

Under 49 CFR Parts 395.8(k)(1) and 395.11, motor carriers must retain all supporting documents at their principal places of business for six months from the date of receipt. Such documents include:

• Shipment paperwork,
• Dispatch records,
• Expense receipts,
• Fleet management and communication systems, and
• Payroll records the driver or carrier creates or comes to possess.

If the driver is/was using paper logs, toll receipts are also to be retained and presented as a supporting document.

These documents are used to verify the accuracy of drivers’ logs during an agency audit or a roadside inspection. They are used to verify:

• The location of the driver at specific times, and
• The driver logged on-duty time when required.

When asked for supporting documents for a specific driver during an audit, the carrier must present them. However, the carrier must only present eight supporting documents for a 24-hour period even if there are more than eight. The eight must include the first and last supporting documents created during the 24-hour period. Toll receipts retained because the driver was using paper logs cannot be counted among the eight, and they must always be presented.

During a roadside inspection, drivers must present any supporting documents they have in their possession.

Roadside inspections

Drivers must be able to display or print their logs during an inspection. Upon request, drivers must also transfer their ELD records electronically to the enforcement official for on-the-spot auditing, including logs for that day and the prior seven days. If the driver provides the display to the officer, the officer will then either ask the driver to display the current day and previous seven days, or ask for the device and the required user’s manual, instruction card, and malfunction code card.

If the officer requests the records, the driver must send them directly to the officer using either one of two “telemetric” methods (web service or email) or one of two “local” methods (Bluetooth or USB 2.0). The driver should tell the officer which method a device uses (telemetric or local). Then the officer will tell the driver which communication method to use to send records to the officer. Here is an example of how the discussion could go:

• Officer: “I want you to send me the logs,” or “I want your logs.”
• Driver: “OK. We use telemetrics to send them.”
• Officer: “All right, send them to me via email with this comment attached,” or “All right, send them to me via the web service with this comment attached.”

Edit process

If any edits are needed after an ELD record has been submitted, except automatically recorded drive time under the driver’s account, the driver has to make the edits through the ELD and then recertify the record. Changes or additions to a record must be explained.

After reviewing a driver’s submitted logs (but not before they have been submitted), the motor carrier can request edits to ensure accuracy. The driver must confirm or reject any proposed changes, make the appropriate edits, and recertify the record. No one may alter or erase the original information collected concerning a driver’s hours of service.

Editing of automatically captured driving time is not allowed under any circumstances. The programming in most ELDs and their support systems will not allow such edits. The only exceptions to this are:

• Driving time involving team drivers may be moved between the two drivers if a logout/login error was made, and
• Unassigned driving time may be assigned to the correct driver.