ELD Log Auditing Checklist: A Comprehensive Guide

An ELD system often auto-audits logs for form, manner, and over-hours violations. However, the depth and accuracy differ based on the ELD provider. Log auditors must validate driver data against system-generated reports, ensuring compliance. This ELD log auditing checklist provides steps for thorough log auditing:

1. Form and Manner (§395.2)

  • Review the system audit report for any missing data;

  • Identify if the missing data was mandatory;

  • Document the violation if any required data or entries are absent.

2. Falsification (§395.8(e))

  • Look out for unexplained data “jumps” (miles, engine hours, locations);

  • Monitor any unassigned driving time during the 24-hour window for the vehicles operated by the driver;

  • Review log edits and special driving categories;

  • Scan for any ghost drivers;

  • Ensure proper on-duty time is logged;

  • If any discrepancies are found indicating falsification, record the violation.

3. Hours-of-service limits (§395.3)

  • Assess system-reported hours-of-service limit breaches.
    • Confirm if an exception allowed the driver to exceed the limit;
    • If there’s no acceptable comment from the driver after surpassing a limit, or the provided exception doesn’t apply, mark this as a violation.

  • If there’s an absence of a paper log, ELD record, or time record for the day, consider this a breach of the log submission requirement. Exceptions:
    • The day is within the previous 13 days;
    • The driver is a short-haul operator not submitting time records for off-days;
    • The driver is on leave, furlough, or extended time off;
    • The driver, deemed an intermittent operator, has provided the necessary summary of hours;
    • The driver is exempt from hours of service.

EXEMPT Log Auditing Checklist

The recent 150 Air-Mile exception (§395.1(e), §395.8(a), §395.8(e)) sees an increase in fleets allowing their short-haul drivers to maintain basic time records, sidelining paper logs or ELDs. This means stricter enforcement and more checks on driver hours.

  • Verify there’s a time record detailing the day’s start, end, and total duty hours.
    • For regular short-haul drivers, no time record is needed on off-duty days unless mandated by the carrier. In its absence, cross-check with dispatch, trip, and payroll records.

  • Confirm the driver’s eligibility for the exemption;

  • Check for false time records.
    • Corroborate with support documents like dispatch records, trip details, payroll data, e-tracking, and communication records. Any discrepancy means the record is false (§395.8(e)).
    • A false record that should’ve been logged should be documented as no log when needed (§395.8(a)).

  • If the driver is ineligible for the exemption or the time record is incorrect, mark it as a violation;

  • Lack of a paper log, ELD, or time record for the day is considered a violation, with exceptions similar to those mentioned in the hours-of-service limits section.

This comprehensive ELD log auditing checklist ensures all angles are covered, helping in maintaining high compliance standards.

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