GOVERNMENT REGULATIONS ARNOLD SAFETY CONSULTING O
ne of the fastest ways to accumulate CSA points, and thereby get audited by
DOT, is get stopped by the police with an incorrect driver’s log. There are two ways to keep your drivers’ logs: electronically or on paper.
A few years ago, before the pandemic, DOT mandated all over-the-road drivers utilize elec- tronic logging devices (ELDs) in their vehicles. OABA was able to obtain an interpretation from DOT stating that most, if not all, OABA members were not subject to the ELD logging mandate, if they chose not to be. The rules state if you drive the vehicle eight (8) times or less every 30 days, you may still use paper logs, or a time sheet to track your drivers’ hours. Since OABA members’ vehicles
generally do more sitting than driving, this is basically how we are exempt from the ELD mandate.
Nevertheless, some members have chosen to use the ELDs
anyway. If you are using an ELD, you still need to exercise oversight of the logs. The ELDs do not operate themselves; far from it. The drivers must still push the correct buttons to establish their proper statuses of duty throughout the week. If they are not doing this, the logging information in the ELD will be mostly gibberish. You must review the ELD information daily to make sure the duty status information entered is cor- rect. Otherwise, you’ll get a ticket if stopped by the police. Naturally, the same goes for paper logs. Management must make sure each driver has a time record for each day of the season. All days must be accounted for. For days on which a jump took place, there should be a paper log. Days on which no driving took place, but the driver worked for the OABA member on the show, should have either a time sheet, or a paper log showing ‘on-duty, not driving’.
Drivers who are retired, or only drive when a move takes place should be submitting a time sheet, or logs showing what they did during the week prior to pulling for the OABA member. Does that driver drive for another motor carrier? If
22 OABA ShowTime Magazine | JULY 2022
so, all of his driving and on-duty time during the week for the other employer must be accounted for by the OABA member. If a driver works 50 hours during the week delivering snacks for Frito-Lay, he may be over hours by the time he works for you on the weekend. You must establish whether or not your part- time help have other jobs.
Make sure your drivers understand the basics of com- pleting the logs. Ensure they are logging at least a 10 hour off-duty break in between work shifts. Ensure they have a 30 minute on-duty or off-duty break for every 8 hours of driving. Double-check they are not driving more than 11 consecutive hours, or working more than 14 hours in any one shift. Doing these basic steps on a consistent basis will greatly increase your chances of passing a DOT roadside stop if and when it happens.
Eric Arnold, President of Arnold Safety Consulting, Inc. is a former U.S. Department of Transportation agent, with 32 years regulatory and transportation compliance experience. His column will appear periodically in ShowTime magazine. As part of your OABA dues, Mr. Arnold is available for free consultations regarding the DOT rules and regulations.
The Importance of Accurate Log Keeping by Eric Arnold, Arnold Safety Consulting
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