Your ELD can do a lot for your company or fleet, including streamlining recording keeping and RODS, to name a couple. And, with everything transmitted and stored digitally — from hours of service all the way to load matching — it can feel like the need for supporting documents are useless. They aren’t — at least not yet. In fact, drivers and carriers are still required to verify HOS compliance with supporting documents (whether in paper or digital formats).
Thought your ELD was taking you to a paperwork-free nirvana? It’s close, but not quite. Here’s what you need to know to make sure you remain in compliance with your ELD supporting documents, starting December 18, 2017.
ELD Supporting Document Categories
ELD supporting documents can be separated into five categories:
- Bills of lading, itineraries, schedules, or equivalent documents that show the starting and ending location for each trip.
- Dispatch records, trip records, or equivalent documents.
- Expense receipts (meals, lodging, fuel, etc.).
- Fleet management system communication records.
- Payroll records, settlement sheets, or equivalent documents showing payment to a driver.
*Drivers using paper RODS must also keep toll receipts, however, these don’t count toward the eight-document cap (see below in ELD Supporting Documents for Motor Carriers).
ELD Supporting Document Basics — For Drivers
- Drivers must submit all supporting documents to the motor carrier.
- RODS and supporting documents must be submitted to the motor carrier no later than 13 days after receiving them.
- Drivers must certify each RODS.
- While limited editing is allowed to correct mistakes on RODS, any driver edits must be certified and annotated to explain the reason for the change (this will be prompted by the ELD). Changes must be confirmed, recertified, and resubmitted. Please note: driving time and other automatically captured information can’t be edited.
- If the carrier requests edits for accuracy, or makes changes themselves, the driver must confirm and certify these changes, if they are accurate.
- Drivers may request records from carriers, for a period of up to six months.
- During roadside inspections, and upon request, a driver must provide any supporting documents in their possession for an authorized safety official’s review.
ELD Supporting Document Basics — For Motor Carriers
- Motor carriers must retain “not more than eight supporting documents for each 24-hour period that a driver is on duty.” Toll receipts do not count towards this 8-document cap. If more than eight are submitted, the carrier must keep the first and last documents for that day, plus six others. If a driver submits fewer than eight documents, the carrier must keep them all.
- Carriers must retain original ELD information and supporting documents (either on the device or on a different backup system) for at least six months. If scanned and saved, paper copies of documents do not need to be retained.
- To protect driver privacy, all ELD information must be securely and appropriately stored.
- Carriers must allow drivers access to records, upon request, for a period of six months.
- Carriers can suggest or request edits to RODS to make them more accurate. However, all edits must be annotated to explain the reason for the change, as well as recertified and resubmitted by the driver.
Supporting Document Information Requirements
Supplying the ELD documents isn’t enough. You also need to make sure the following information is on each supporting document:
- The driver’s name (or a carrier-assigned identification number) must be on the document or on another document that allows the carrier to link the first document to the driver. The vehicle unit number can be used, if that number can be linked to the driver.
- The date.
- The location (including the name of the nearest city, town, or village)
*Drivers with fewer than eight documents, all of which contain all four information requirements, can use a document that does not include “time” as a supporting document.
Using ELD supporting documents goes into effect December 18, 2017 — right along with the ELD compliance timeline. It is on this date, however, that enforcement officials can also request access to your RODS via a data transfer. This means that your ELD must be able to transmit data using the web or email, or it must be able to transfer data via thumb or flash drive (USB 2.0) and Bluetooth. Make sure your ELD can handle the task. For more information on supporting documents, please visit the FMCSA’s FAQs ELD Rule page.
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