Omnitracs' Road Ahead blog

Document management is a critical part of HOS compliance

Michael Ahart
Michael Ahart
Vice President of Regulatory Affairs

Often, the magic ingredient involved with managing compliance is organization.

According to the Federal Motor Carrier Safety Administration (FMCSA), many commonly cited Electronic Logging Device (ELD) compliance violations involve non-compliance with regulations regarding documents and materials. Drivers and motor carriers must produce specific documents and materials when requested by enforcement personnel, whether at roadside or during a safety investigation.

To help you enhance compliance and simplify your day-to-day, I’m highlighting key documents you should keep with you during your next trip, along with those that will need to be turned into the motor carrier. Let’s explore!

#1: ELD user documentation

You must always have specific ELD information in your commercial vehicle. The ELD information “packet” includes an:

  • ELD user manual
  • Driver-focused instruction sheet which describes how to report ELD malfunctions and which recordkeeping processes to follow during malfunction events
  • Eight-day or more supply of blank driver Record of Duty Status (RODS) graph-grids
  • Instruction sheet that describes:

    • ELD-supported data transfer mechanisms
  • Step-by-step instructions on producing and transferring Hours-of-Service (HOS) logs to an authorized safety official (which is also known as an eRODS transfer)

The ELD information materials listed above can be in electronic form.  Any combination of electronic and physical documentation is also acceptable.  A software application that logs RODS also meets FMCSA requirements during malfunction events.

#2: RODS supporting documentation

RODS supporting documentation is another critical element in HOS regulatory compliance. To verify a driver’s RODS, safety officials request documents fitting these five categories:

  • Bills of lading, itineraries, schedules, or equivalent documents highlighting each trip’s origin and destination
  • Dispatch or trip records or equivalent documents
  • On-duty, not-driving-related expense receipts
  • Electronic mobile communication records that highlight communications transmitted through a fleet management system
  • Payroll records, settlement sheets, or equivalent documents indicating how the driver was paid

If you’re a driver meeting one of the four exemptions from the ELD requirement allowing the use of paper RODS, you must also hold on to your toll receipts.

#3: Additional information about supporting documents

Supporting documents must contain specific documentation, including:

  • Driver’s name, vehicle unit number (if it’s linked to your name), or a carrier-assigned ID number, which should be reflected on the supporting document or another driver-linked document
  • Date
  • Location
  • Time

Motor carriers must retain up to eight supporting documents for every 24 hours you’re on duty. Upon receipt, you have up to 13 days to submit your RODS and supporting documents to your motor carrier.

Mobile communications and payroll records can be submitted electronically and thus would not need to be physically retained. In applying the eight-document limit, all information in an electronic mobile communication record will be counted as one document per duty day.

I hope these three reminders help you avoid the most common citations in the future! Learn more about required documentation and other ELD-related questions by visiting the FMCSA’s FAQs page.