HOS Compliance: Common Mistakes Carriers Make
Recurring hours-of-service issues that tend to surface during reviews and audits.
Electronic logging devices have been part of everyday trucking operations for years now, but ELD compliance is still one of the more misunderstood areas of the regulations — partly because responsibility for it is split between carriers and drivers, and the two sides don't always know exactly where their part starts and ends.
An ELD automatically records a driver's duty status, driving time, vehicle movement, engine hours, and location data, and syncs that information to the vehicle's engine to verify it's accurate. The goal is a more reliable record of hours-of-service compliance than a paper log, which relies entirely on manual, after-the-fact entry.
An ELD generating accurate data doesn't help much if nobody reviews it. Regular log review — checking for unresolved data diagnostic events, unidentified driving time, and unusual patterns — is where most ELD compliance problems actually get caught, well before they'd surface at roadside or in an audit.
Under 49 CFR 395.34, an ELD must monitor its own compliance and flag malfunctions and data diagnostic events related to things like power, data recording, positioning, and data transfer. When a malfunction occurs, the driver is required to report it to the carrier, and the carrier is generally required to correct, repair, replace, or service the ELD within a defined window — this is a case where the exact timeframe is worth confirming directly against the current regulation rather than a secondary source, since compliance deadlines like this are exactly the kind of detail that needs to be accurate.
Critically, a malfunction doesn't excuse a driver from HOS compliance. If an ELD malfunctions, the driver generally needs to reconstruct their record of duty status manually for the current 24-hour period and the prior 7 days, using whatever supporting information is available, until the device is back in service.
Even with a fully functioning ELD, carriers are still required to retain certain supporting documents that help verify the accuracy of driver logs — things like bills of lading, dispatch records, and fuel receipts. ELDs replaced paper logs; they didn't eliminate the need for supporting documentation.
ELDs must be able to transfer HOS data to an authorized safety official during a roadside inspection, either electronically or by display/printout, depending on the device. Drivers should know how to perform this transfer on whatever device their company uses — fumbling through an unfamiliar data transfer process at roadside is a common, avoidable source of friction during an inspection.
An ELD is only as reliable as the process around it — device accuracy is half the equation, review and response is the other half.
ELD data is one of the more detailed records FMCSA can request during a compliance review, and it connects directly to the broader HOS picture covered in our article on common HOS compliance mistakes. If building a consistent ELD review process across your fleet feels like more than your team can keep up with manually, our compliance services are built for exactly that, and you can get audit ready whenever you're ready.
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