The Hours-of-Service (HOS) Compliance BASIC is one of seven areas that the Federal Motor Carrier Safety Administration (FMCSA) use to determine how safe a motor carrier is compared to other, similar carriers. After the ELD mandate went into effect, FMCSA updated its list of HOS violations used in the Compliance, Safety, Accountability (CSA) enforcement model.
The CSA’s HOS Compliance BASIC addresses four key categories:
- Form and manner violations
- HOS rule violations
- Unidentified trips
- Issues with AOBRDs and ELDs
With the advent of ELDs, this BASIC naturally became top of mind for many carriers. While intimidating at first, with proper policies and established procedures in place, the switch to ELD can be beneficial to improving your safety culture and your CSA score. Here’s how ELDs can affect your HOS Compliance BASIC:
Form and manner violations
These are the most common violation, since they are the simplest for an inspector to notice. They cost a single point per violation, but they add up over time. ELDs have been responsible for an industry-wide drop in form and manner violations, though they can still occur. Keep in mind, not all ELDs are created equal. If the device is easy for drivers to use, you’ll have a better chance at success here.
HOS rule violations
These rules have not changed since the roll out of the ELD mandate, but ELDs increase visibility of violations. Violations of the 14-hour rule are most common, and they cost you 7 points per violation (1 point for a nominal violation). Similarly, violating the 11-hour rule or rules about taking mandatory breaks will cost 7 points. ELDs are great for identifying patterns of behavior. It could be dispatch issues, location- or shipper-specific issues (ELDs can help with last one via geofencing). If you notice a driver violating his 30-minute break often, it’s great to use the data for coaching.
Unidentified Trip violations
These are created if a vehicle is on the move and no driver is logged into the ELD. Most ELDs show a prompt if it detects vehicle movement with no one logged in. Drivers are responsible for responding to these prompts, as well as reviewing their trips. It costs 5 points if a prompt goes ignored completely.
During inspection, time may be added to a driver’s logs to account for the time of an unidentified trip. If enough is added to a driver’s logs, this could trip an HOS violation. Some ELDs are programmed to make these prompts very visible. Be sure to rely on a device that makes it easy as possible for drivers to always account for a vehicle’s time on the road.
Achieving compliance with ELD
At EROAD we have staff dedicated to understanding the regulations, rules and policies our industry operates under, and make sure our solution meets the highest standards to achieve compliance. It doesn’t stop with our solution. We also focus on evolving best practices for our customers when it comes to using ELDs and improving CSA scores. Stay tuned for our compliance webinar series which launches next week.
Susan is responsible for the development and execution of EROAD's robust training program in the U.S. With over 10 years’ experience in the regulatory environment, Susan brings knowledge from both carrier and driver perspectives. Susan’s main objective is bridging the gap between customers, product developers, enforcement and regulators to ensure compliance and safety is achieved quickly, easily and with lasting results.