2019 STS: Hours of Service
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This document discusses hours of service regulations and supporting documentation requirements. It provides answers to frequently asked questions about requirements for motor carriers and drivers regarding retaining records of duty status and supporting documents. Key points covered include carriers retaining up to 8 supporting documents per 24-hour period, drivers submitting documents within 13 days, categories of supporting documents, and information that must be included in the documents.
2019 STS: Hours of Service
- 1. Safety Track: Hours of Service Chris Nelson, NBIS (NationsBuilders Insurance Services, Inc.)
- 3. Chris Nelson, NBIS Specialized Transportation Program Manager As program manager, Chris partners with agents and insureds to sell comprehensive coverage and cross sell existing accounts, rehabilitate conditionally rated transportation companies, and work with active insureds on compliance and regulatory relevant updates and changes. He works with agents and insureds on risk assessments, CSA performance analysis and presentations. Chris is a member of TIDA, CVSA & the SC&RA. He currently serves as the Vice Chairman of the Safety, Education and Training committee for the SC&RA. I have been published in American Crane & Transport (AC&T) and American Concrete Pumping Association (ACPA) magazines. In addition, I serve on the Specialized Carriers & Rigging Association (SC&RA) - Safety & Training Committee.
- 4. Scenario: Knock.Knock.Knock A DOT investigator is at your door. Your company has been identified for intervention by the FMCSA because your Hours-of-Service BASIC is in ALERT status. The investigator will be conducting a focused Hours-of-Service audit. He has selected 10 drivers (based on their CSA performance) and has asked you for each drivers past 6-months of logs (paper & electronic). While your staff is collecting the information the DOT investigator asked for, he asks you…. Walk me through your log auditing procedures. Tell me about the hours-of-service information you have and retain, and what specific auditing do you perform here at your company?
- 5. Why is this important to know? • Unassigned Drive Time • Miles Without Hours What will you need to do… 1. Assign to a driver 2. Be able to show the DOT investigator that it was assigned to the correct driver
- 6. Supporting Documents FAQ 1. When are motor carriers and drivers required to comply with the supporting document requirements? All motor carriers and drivers must comply with the supporting documents requirements starting December 18, 2017. 2. How many supporting documents must be retained by motor carriers, and when must drivers submit them to the motor carrier? Motor carriers must retain up to eight supporting documents for every 24-hour period that a driver is on duty. Drivers must submit their records of duty status (RODS) and supporting documents to the motor carrier no later than 13 days after receiving them. If a motor carrier retains more than 8 supporting documents, the motor carrier must maintain the first and last document generated during the regular course of business.
- 7. Supporting Documents FAQ 3. How long must motor carriers retain records of duty status (RODS) and supporting documents? Motor carriers must retain RODS and supporting documents for six months. 4. What are the categories of supporting documents? Supporting documents required in the normal course of business are important to verify a driver’s records of duty status (RODS). They consist of five categories, described in 49 CFR 395.11(c): • Bills of lading, itineraries, schedules, or equivalent documents that indicate the origin and destination of each trip; • Dispatch records, trip records, or equivalent documents; • Expense receipts related to any on-duty not-driving time; • Electronic mobile communication records, reflecting communications transmitted through a fleet management system; and • Payroll records, settlement sheets, or equivalent documents that indicate what and how a driver was paid. If a driver keeps paper RODS under 49 CFR 395.8(a)(1)(iii), the carrier must also retain toll receipts. For drivers using paper RODS, toll receipts do not count toward the eight-document cap.
- 8. Supporting Documents FAQ 5. Are there specific categories of supporting documents that drivers can provide electronically? Two categories—electronic mobile communications and payroll records—are not documents a driver would have to physically retain. They may be part of a larger record that the carrier retains electronically or physically at the dispatch location or principal place of business. In applying the eight-document limit, all information in an electronic mobile communication record will be counted as one document per duty day. 6. Can supporting documents be limited to only those acquired at the beginning and end of the workday? No. Documents acquired throughout the day are important in enforcing the 60/70-hour rule—a crucial part of ensuring hours of service compliance. Compliance with the 60/70-hour rule is based on the cumulative hours an individual works over a period of days. Supporting documents are critical to verify the proper duty statuses in assessing compliance with the 60/70 hour rules.
- 9. Supporting Documents FAQ 7. What information should be in the supporting documents? Supporting documents must contain the following elements: • Driver name or carrier-assigned identification number, either on the document or on another • document enabling the carrier to link the document to the driver. The vehicle unit number can also be • used if it can be linked to the driver; • Date; • Location (including name of nearest city, town, or village); and • Time. 8. Can a document with fewer than four required elements be used as a supporting document? If a driver has fewer than eight documents that include all four elements, a document that contains all of the elements except “time” is considered a supporting document.
- 10. Supporting Documents FAQ 9. What supporting documents should a motor carrier retain if a driver submits more than eight documents for a 24-hour period? If a driver submits more than eight documents, the motor carrier must retain the first and last documents for that day and six other supporting documents. If a driver submits fewer than eight documents, the motor carrier must keep each document. 10. Are drivers required to show supporting documents during roadside inspections? Upon request, a driver must provide any supporting document in the driver’s possession for an authorized safety official’s review.