What preparations should a carrier undertake?

Here is a short list of what you can do to prepare your vehicles:

• Make sure all vehicles are current on maintenance inspections and maintenance (if not, get them in for maintenance ASAP);
• Make sure all vehicles have a current periodic/annual inspection (if any are expired, get them in for the inspection ASAP); and
• Insist that drivers do daily vehicle inspections, including a full pretrip, enroute inspections that including checking the lights, tires, and cargo securement, and a complete post-trip inspection.

Prepare the drivers

To make sure your drivers are ready, remind them:

• What a roadside inspection involves, what will be expected of them during an inspection, and how to conduct themselves during an inspection;
• That they must have their credentials with them and verify that they are valid (license and medical card if a non-CDL driver); and
• That their hours-of-service records must be up-to-date and truthful.

Hours-of-service is the other focus this year

As hours-of-service is one of the focus areas this year, you should put a special effort into reminding your drivers of the applicable limits and recordkeeping requirements. When it comes to presenting hours-of-service records to the officer, the situation will vary depending on the driver’s specific situation. Drivers using electronic logging devices will need to know:

• What must be presented to the officer (display only, or display and the ability to transfer data if requested);
• How to present the required information (and transfer it); and
• What supporting materials are required (user’s guide, transfer instructions, malfunction instructions, blank logs, etc.).

A driver that is using paper logs must be able to explain to the officer why he or she is using a paper log, rather than an electronic one. Common reasons include:

• The driver is operating a vehicle older than model year 2000 (based on the VIN or engine serial number),
• The driver’s ELD is currently malfunctioning,
• The driver is involved in certain driveaway or towaway operations, or
• The driver is operating a rental vehicle that was rented for eight days or less.

If the driver does not need to have logs, the driver will need to be able to explain to the officer why he or she does not have logs. Common reasons include that the driver is:

• Using one of the short-haul exemptions that allow time records to be used in place of logs; or
• Operating under one of the exemptions that exempts the drivers from the hours-of-service regulations, such as operating under the terms of an emergency declaration, the agricultural exemption, or the utility service vehicle exemption.