Transflo ELD and HOS Guide: Part 1

Use this KB article to learn basic driver tips for using your electronic logging device (ELD) to manage your hours of service (HOS).

 

This article describes how hours of service (HOS) logs are managed and how driving requirements are regulated in the United States. Australia, Brazil, Canada, and other countries around the world have their own HOS regulations. The Federal Motor Carrier Service Administration (FMCSA) Hours of Service regulations affect every commercial vehicle driver on the road. Staying up-to-date with HOS regulations is a critical task for both drivers and carriers. As a driver, be aware of the following key points:

  • You play a major role in FMCSA and DOT compliance.

  • Learn as much as you can about the regulations and rule sets.

  • Periodically discuss with your supervisor and review the Hours of Service (HOS) requirements for commercial vehicle drivers.

  • At minimum, you should understand HOS rule sets, driving limits, and important terms such as ELD, HOS, DVIR, IFTA, and other words defined in the built-in glossary in this Transflo knowledge base (KB). You can easily use the search field to find the definition for any term.

 

Each year in the USA and Canada more than 400,000 police-reported large commercial vehicle crashes occur. Hours of Service (HOS) regulations improve road safety by governing the number of hours truck drivers can drive and work. In general, HOS rules regulate the maximum number of hours that can be driven, specify mandatory break times and time off, and help you and your supervisor manage driver duty cycles.

Example: HOS logs and compliance graph showing duty status for 24-hour period in Geotab Drive, Transflo HOS, and Mobile+ app:

HOS regulations apply to all drivers who operate a commercial motor vehicle (CMV) in the United States, even if they are from an international motor carrier from Canada, Mexico, or another country. A CMV is any vehicle with or without a trailer that meets any of the following conditions:

  • Weighs (including any load) at least 10,001 lbs. (4,536 kg),

  • Has a gross vehicle weight rating or gross combination weight rating of at least 10,001 lbs. (4,536 kg)

  • Transports hazardous materials in a quantity requiring placards

  • Made intentionally or used to transport 9 or more passengers, including the driver, for compensation, or 16 or more passengers, including the driver, without compensation

 

In the USA, there are two different sets of regulatory provisions for Hours of Service: intrastate and interstate:

  • Intrastate commerce: The transfer of goods, services, or passengers that stay within the borders of one state. If you are operating in intrastate commerce only, the federal HOS regulations do not apply to you. However, each state creates their own HOS regulations for intrastate commerce drivers, such as the Texas Transportation Code for Texas intrastate drivers.

  • Interstate commerce: The transfer of goods, services, or passengers across two or more state lines.

Vehicles transporting hazardous material in large quantities, even during times in which they are not carrying any load, must always comply with FMCSA HOS regulations, not intrastate regulations.

A common misconception is that interstate commerce refers to vehicles themselves or the driver crossing state borders, but this is not the case. Interstate commerce refers strictly to the transfer of goods, services, or passengers across state borders. Drivers who are not involved in interstate commerce at all times must continue to comply with FMCSA HOS regulations for at least 7 or 8 days after they stop performing interstate commerce, depending on what exact rule set they operate under.

HOS rules determine how many hours you are allowed to drive in a day. Different HOS rules apply depending on whether you are carrying passengers or property:

  • A passenger carrier transports people, such as a city or tour bus. Both property and passenger carriers have various sets of rules they must adhere to, otherwise known as a ruleset. These rulesets have different exemptions as well.

  • A property carrier is a company that transports goods or services, such as one that delivers packaged food or a moving company.

 

Passenger Drivers: What is the passenger-carrying duty limit?

For passenger-carrying vehicles, a 15-hour duty limit applies, instead of a workday limit. Duty Limit is non-consecutive, meaning that any time spent in OFF-Duty or the sleeper berth does not count toward the limit. The 15-hour duty limit is used for passenger carriers and some intrastate property carriers to help the driver accomplish more non-driving related tasks in the day. It also accommodates long breaks in between picking up and dropping off cargo.

Property Drivers: In this section, we’ll explain each of the HOS rule sets for property-carrying drivers. Under the property-carrying rule sets, truck drivers must follow several important limits:

Within a 14-hour workday, property-carrying drivers are only permitted to drive their truck for a maximum of 11 hours after 10 consecutive hours of OFF-Duty time. This means they cannot drive for more than 11 hours in a day without a long break of OFF-Duty time.

The 14-hour workday limit means that once a driver comes back ON-duty after 10 consecutive hours of OFF-duty time, that driver cannot drive beyond 14 consecutive hours. This workday limit is the total number of hours a driver can work in a day and is designed to prevent driver fatigue. It consists of driving, rest limits, and various OFF-duty breaks such as getting lunch or a mandatory rest limit. This 14 consecutive hour driving window does not change even if the driver takes time OFF to take a break or nap.

14-Hour Rule Example:

  • Ken drives from 6:00 AM to 2:00 PM (8 hours).

  • He takes one (1) hour OFF-duty time for lunch.

  • He drives another two (2) hours for a total of 10 hours.

  • Next, at 5:00 PM he logs three (3) hours of OFF-duty time.

Because a total block of 14 hours have transpired, Ken has reached his 14-hour limit even though he didn't reach a simple 11-hour driving limit.

The DOT 70 hour Rule is the total time spent Driving and ON-Duty, and cannot exceed 70 hours in any 8-day period (or 60 hours in any 7-day period). In other words, drivers have a limited number of hours they can be ON-Duty per cycle (week).

To calculate this total, add up the time spent Driving and ON-Duty today plus the prior 7 days. That total cannot be more than 70 hours. Drivers cannot drive after they have reached 60/70 hours of ON-Duty time in 7/8 consecutive days.

A driver may gain back time at midnight when the oldest day in his 8-day window falls out of the time range. To completely reset the 70-hour clock, it requires a 34-hour restart.

60-Hour Rule Example:

A driver can be ON-Duty a maximum 60 hours in a 7 day cycle. In order to reset the cycle, drivers must take a consecutive 34 hours of OFF-Duty. This can be done at any time as long as the hours do not exceed 60 hours.

70-Hour Rule Example:

A driver can be ON-Duty a maximum 70 hours in a 8-day cycle. In order to reset the cycle, drivers must take 34 consecutive hours of OFF-duty time. This can be done at any time as long as the hours do not exceed 60 hours in 7 days or 70 hours in 8 days.

Exception for Sales Professionals Who Also Drive:

Drivers who are also sales representatives or account professionals do not have to comply with the 60-hour/7-day limit or the 70-hour/8-day limit.

Once a driver has worked a total of 60 hours in the past 7 days (or 70 hours in 8 days), they have hit their limit. They must be OFF-Duty for a consecutive 34 hours in order to work again. This is also referred to as the 34-hour reset or 34-hour restart.

Drivers must have a certain number of non-working/off hours within a 24-hour time period to give them a rest from driving and other miscellaneous tasks. Drivers can do their OFF-duty time in the sleeper berth, in a hotel, at home, or other areas outside of actual work. The driver is considered OFF-Duty as soon as they are no longer in transit with the goods, services or passengers. They can drive while OFF-Duty, but not for any work-related tasks such as fueling the vehicle or taking it to the mechanic.

Previously, an extra restriction for the 34-hour restart had been considered, requiring two OFF-Duty periods during 1 a.m. to 5 a.m. and a once per week provision. However, based on a Department of Transportation (DOT) study of truckers conducted by the FMCSA and Virginia Tech which showed that the changes did not benefit driver safety, the requirements were struck down.

A sleeper berth refers to the cab in the back of the truck which can contain a bed, desk, TV, and refrigerator. Drivers can use the time spent in the sleeper berth to count toward their mandatory rest limits or their OFF-duty time.

If drivers have a 10-hour OFF-duty time, they can spend the full 10 hours in the sleeper berth or they can do 8 hours of OFF-duty time, followed by some driving then 2-hours of OFF-duty time which would count toward their total OFF-Duty time.

Rest time is the required break for a CMV driver after a certain number of hours driven. For example, if a property-carrying driver drives 8 continuous hours, he or she is required to take a 30-minute break.

Rest breaks are not optional for drivers; they are mandatory and must be taken. You can set an alarm to end your rest break. Breaks can be logged as any status that is not driving. For example, set your HOS status to OFF-duty and write an annotation in your logs for 75-minute break to walk, eat lunch, and rest a bit.

Many different exemptions and exceptions can change or extend the HOS limits shown above. Here are some of the most common HOS exemptions:

  • 16-hour rule: Allows drivers to add 2 hours onto their 14 hour workday within certain conditions.

  • Adverse Driving Conditions: Lengthens the driving limit or ON-Duty limit by up to 2 hours due to unforeseen driving conditions. Adverse driving conditions include snow, fog, or unexpected traffic shut-down, but do not cover more common occurrences such as traffic congestion in rush hour or typical delays at peak times.

  • Salesperson: Drivers, who are also salespersons, do not have to comply with the 60-hour/7-day limit or the 70-hour/8-day limit.

  • Short-haul: Drivers of “short-haul” vehicles do not need to take a half-hour rest break after 8 hours of ON-Duty.

  • Oil transport: Allows drivers in the oil transportation industry to restart their cumulative work week after 24 consecutive hours of OFF-Duty Time.

  • Wait-at-well: Drivers in oil-well transportation service at oil drilling sites can use time spent waiting at an oil well location as OFF-Duty time or to satisfy the 30-minute break.

As a driver, to prove that you followed the regulations, you must present or submit documented logs, also known as a record of duty status (RODs) to roadside inspection officers. The official requirements for a driver’s record of duty status are detailed in 49 CFR 395.8 and are embedded in the Transflo HOS app or Transflo Mobile+ app for you. See ELD and HOS Roadside Inspections.

RODs logs must include:

  • 24-hour period grid

  • Date (Day, Month, Year)

  • Total miles driven

  • Truck/Tractor/Trailer number

  • Name of carrier

  • Main office address

  • Driver certification sign-off verifying their logs

  • Name of co-driver

  • Time zone

  • Total hours spent in: OFF-Duty, ON-Duty, Sleeper Berth, Driving

  • Shipping document number/name of shipper/name of commodity

  • Annotations

 

The annotations you add to your logs give a description of what happened, whether it be a duty status change or forgetting to apply an exemption. This allows the driver to inform the roadside officer, inspector, and the fleet manager, upon request, of their whereabouts at a certain time. Annotations can be as simple as lunch or they can be more detailed as decided by the carrier.

For level 3 DOT inspections and other driver-specific inspections, RODs belong to the individual driver, not the vehicle or the motor carrier. If a driver changes vehicles, their RODs logs stay with them unchanged. In cases of co-drivers or team-drivers (where there are multiple drivers in the same vehicle) each driver must have their own RODS logs. Drivers must ensure that their pre-trip checklists and logs are clear and accurate as possible so they can be easily reviewed during an inspection if necessary.

The ELD rule requires drivers to use either an electronic logging device (ELD) or an automatic on board recording device (AOBRD, no longer supported) for records of duty status (RODS). Paper logbooks are no longer allowed for drivers subject to the rule (except in rare emergencies). Ever since the rule went into full effect on December 19, 2019, only self-certified ELDs can be used.

In the event of a roadside inspection, drivers must have their RODs readily available. All RODs must be compliant with their ruleset, or else the driver will be subject to fines for HOS violations.

Although many kinds of HOS violations exist, these are the most common:

  • Operating past 14 hours ON-duty

  • Driving over 60/70 hours in 7/8 days

  • Violating the 11-hour driving limit

  • No Record of Duty Status

  • False logs

  • Wrong class license

 

Violations can be discovered in a number of ways:

  • Your carrier keeps track of your hours and will know if you are in violation.

  • The police can discover a violation during a roadside inspection.

  • The DOT can catch you at a weigh station if your company happens to get audited.

  • If you get into a collision while operating over an HOS limit.

 

Violating HOS rules can lead to a variety of penalties for both the driver and carrier:

  • Drivers may be placed on shutdown (at roadside) until they have accumulated enough off-duty time to be back in compliance (for example, a 34-hour restart).

  • State and local law enforcement officials may assess fines.

  • The Federal Motor Carrier Safety Administration may levy civil penalties of $1,000 or more on a driver or carrier depending on the severity of the violation.

  • A carrier's safety rating can be downgraded for a pattern of violations.

  • Federal criminal penalties can be brought against carriers who knowingly and willfully allow or ignore violations; or against drivers who knowingly and willfully violate the regulations. These can include fines, license suspension, and jail time.

Historically, drivers used paper logs to record their Hours of Service. However, with the introduction of the ELD mandate in the United States, drivers and carriers are required to use electronic logging devices for record-keeping. Smart carriers know that they can get the best ELD solution from Transflo with our integrated offerings that combine Geotab HOS, FMCSA rules, tech-savvy ATI innovations, (ATI is now part of Transflo), and other back-end data-driven solutions.

Transflo Geotab ELD fleet compliance and management solutions help you monitor and record HOS activity, including record of duty status (RODs) and driver vehicle inspection reports (DVIRs). Managing DOT compliance is more than simply meeting regulatory requirements – it’s about promoting safety, preserving profits, and streamlining fleet operations. Transflo Geotab FMCSA-certified software ensures compliance for both drivers and fleet managers. By automating audits and processes, we help your fleet operate smoothly and avoid costly violations. With Transflo, you get:

  • Easier log management

  • Simplified pre-and-post inspections

  • Detailed insights into driver logs and remaining hours with near real-time status updates

  • Cross-border compliance with 100+ HOS rulesets for U.S. and Canada

  • Driver assistance with alerts for HOS violations, missed inspections, and vehicle usage

Drivers log their Hours of Service from the Geotab Drive mobile app which can be used on a smartphone or tablet. In the Geotab Drive HOS screen, drivers can select and change their duty status. They can also see a summary of the time remaining in each duty status, such as Rest in, Driving left, Workday left, and Cycle left.

The following example image shows the Geotab Drive app embedded inside the Transflo HOS app or Transflo Mobile+ app on tablet and phone:

A blue bar near the top of the screen shows the remaining driving time. The bar turns red if the driver goes into violation. Geotab Drive has automatic duty status changes. When the truck is in motion, the duty status automatically changes to D (Drive). If a driver needs to change that, they can override the automatic change in their logs (see Edit Driver HOS Logs in the Mobile App).

 

  • AOBRD: Automatic On Board Recording Device (old legacy term; AOBRDs are no longer supported; as of Dec 16, 2019, all carriers subject to the ELD mandate are required to use electronic logging devices)

  • CMV: Commercial Motor Vehicle

  • DOT: Department of Transportation

  • DVIR: Driver Vehicle Inspection Report

  • ELD: An Electronic Logging Device (ELD) is a technology device and accompanying software solution that automatically records driving time and other aspects of the Hours of Service (HOS) records.

  • FMCSA: The Federal Motor Carrier Safety Administration (FMCSA) is an agency under the United States Federal Department of Transportation that regulates all interstate and international CMVs.

  • HOS: Hours of Service (HOS) is the general system of rule sets, limits, and logs that demonstrate official compliance with safety regulations for the time spent by drivers of commercial vehicles as their status changes from driving to on-duty to OFF duty to resting.

  • RODs: Records of Duty Status

  • 34-hour Restart: A requirement that states that a driver must be OFF-Duty for 34 consecutive hours before starting work again.

  • DOT Officer: Officer that is hired by a Department of Transportation (DOT) to enforce set regulations.

  • Driver logs: Same as HOS logs or RODs.

  • Fine: Violations of hours of service rules can result in fines or other penalties such as being placed out of service or a reduction in the driver or carrier’s safety rating, depending on the severity of the violation. When a driver is in violation of HOS regulations they must pay a fine and stop driving until they are no longer in violation.

  • Hazmat (Hazardous Material): Any materials deemed hazardous by the FMCSA, such as compressed gasses or spontaneously combustible material, require a placard on the truck and special training for transporting (as per the FMCSA regulations).

  • Inspection: Carried out by a DOT officer to ensure that the driver did not violate HOS regulations and other various factors of the trucking industry

  • Logbook: Form which tracks the Hours of Service statuses of a driver for 24-hours

  • Motor carrier: Company or person supplying transportation of property or passengers via CMVs.

  • Team drivers (co-drivers): Two or more drivers that alternate between the passenger and the driver’s seat of a vehicle. Typically used for time sensitive deliveries, like moving trucks.

  • D (Drive): Drive status is the time spent driving or operating a CMV. Contrast with ON duty, OFF duty, yard move (YM), personal conveyance (PC), or another HOS status or exemption.

  • ON (ON-Duty): All the time that drivers spend working and being compensated. When a driver is doing tasks that would otherwise be known as work, that is not driving

  • OFF (OFF-Duty): Leisure time or rest time for a driver. Time that the driver is relieved of all duty and responsibility for performing work. To be considered OFF-Duty time, drivers must be free to pursue activities of their choice and leave the place where their vehicle is parked.

  • SB (Sleeper Berth): Similar to OFF-Duty.

Your ETA and PTA times are important to communicate with your shipper, receiver, and carrier fleet dispatcher.

  • ETA: Estimated time of arrival

  • PTA: Projected time of availability

 

Determine your best guess for these times based on your current location, projected location, and HOS time.

Example 1: Your estimated time of arrival (ETA) at a location is 1:00 PM. After you unload and submit your documents, your PTA might be 2:30 PM.

Example 2: You arrive at a customer location at 7:00 PM and cannot unload until the morning. In this scenario, your PTA might be 9:00 AM the following morning—some 14 hours after your ETA.