HOS Compliance: Common Mistakes Carriers Make

Hours-of-service rules are some of the most consistently enforced regulations in trucking, and they generate more roadside violations than almost any other category. Most HOS problems aren't the result of carriers ignoring the rules — they're the result of small, recurring habits that compound over time. Here are the ones we see most often.

Regulations and enforcement priorities can change. Always verify current HOS requirements against FMCSA's official HOS resources before relying on this or any secondary source for a compliance decision.

1. Incorrect Duty-Status Records

The most basic HOS mistake is also the most common: a driver's logged duty status doesn't match what they were actually doing. On-duty time logged as off-duty, or driving time misclassified, creates a record that looks clean on the surface but doesn't hold up against supporting documents like fuel receipts, dispatch records, or GPS data.

2. Log Edits Without Proper Annotation

Both drivers and carriers can edit ELD records in limited circumstances, but every edit needs a clear annotation explaining why. Edits that change a driver's available hours without documentation are one of the fastest ways to turn a minor discrepancy into a serious finding during a review.

3. Unidentified Driving Time

When a vehicle moves and no driver is logged in, the ELD records that time as unidentified driving, and it has to be resolved — assigned to the correct driver or otherwise accounted for. Left unresolved, unidentified driving time accumulates and becomes its own audit flag, even when the underlying explanation (a yard move, a mechanic road-testing a repair) is completely legitimate.

4. Form-and-Manner Issues

Not every HOS violation is about hours themselves. Missing information on a log — carrier name, driver license number, total miles, vehicle numbers — is a form-and-manner violation. It's a smaller issue individually, but a pattern of them signals to a reviewer that logs aren't being checked before they're finalized.

5. Missing or Inconsistent Supporting Documents

Supporting documents — things like bills of lading, fuel receipts, toll records, and dispatch logs — exist to verify that a driver's logged hours match reality. When supporting documents contradict a driver's log (a fuel receipt timestamped during logged off-duty time, for example), it raises questions about the accuracy of the record itself, not just that one entry.

6. Misunderstanding Available Exceptions

Short-haul, adverse driving conditions, and other HOS exceptions exist for legitimate operational situations — but they're often applied incorrectly, either by drivers who don't fully understand the qualifying conditions or by carriers who don't have a clear internal policy on when they apply. An exception used outside its actual qualifying conditions doesn't provide protection; it just adds a violation.

7. Poor Communication Between Drivers and Management

A surprising number of HOS problems trace back to something simple: drivers not clearly understanding what's expected of them, or management not reviewing logs closely enough to catch issues while they're still small. A driver who doesn't know how to properly annotate a personal conveyance entry, for instance, will make the same mistake repeatedly until someone catches it and explains the correct process.

Most HOS violations aren't discovered at roadside first — they're sitting in your own ELD data, waiting to be reviewed.

Practical Ways to Reduce HOS Issues

• Review logs regularly, not just after an incident. Weekly spot-checks catch problems while they're still one-off mistakes.
• Train drivers on annotation, not just the rules. Knowing the HOS limits and knowing how to properly document an edit or exception are two different skills.
• Reconcile unidentified driving time promptly instead of letting it accumulate unassigned.
• Cross-check supporting documents periodically against logged hours for a sample of trips, not every trip.
• Put your exception policies in writing so drivers and dispatch apply them consistently.

HOS data feeds directly into your SMS record — see our companion article on understanding your SMS data for how that connects. If your team could use help building a more consistent HOS review process, that's a core part of what our compliance services cover, and you're welcome to get audit ready with us.