There’s a substantial amount of information to read and learn when it comes to understanding how FMCSA and State compliance auditors review Hours of Service (HOS) compliance using ELD records, and other supporting documents required to be maintained by fleets under the ELD rule. Thus, STC staff recently took some time to research and understand these reviews to best assist clients with this work.
The ELD auditing information provided by FMCSA to its field staff who conduct either on- or off-site ELD-HOS compliance audits includes guidance on how many drivers should be selected, which drivers should be selected, and how ELD data should be analyzed and audited to ensure it’s accurate. For example, auditors are trained to check a company’s ELD support system settings to ensure the carrier cannot customize settings that would be in violation of ELD technical standards.
Examples include settings that could:
- Allow a company to increase the 5 mph vehicle motion status
- Override the auto drive duty status to allow the driver to remain in an on-duty not driving status
- Override the required muted volume feature during sleeper berth time
FMCSA’s guidance to its auditors also includes eight different techniques aimed at detecting ELD record falsification. Two of these techniques are:
- Evaluating all non-driving periods to determine whether they started and ended in the same location;
- Checking ELD record edits to determine if on-duty not driving time was moved to either off-duty or sleeper berth time in order to bank time for the 14 hour and 70-hour rules.
Much of FMCSA’s ELD and HOS auditing guidance can be used by motor carriers to develop and utilize their own internal auditing system.