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.
- 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.