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FMCSA includes ELD violations in revised CSA methodology

22 new HOS violations added to accommodate full enforcement of ELD mandate

Posted April 16, 2018

The Federal Motor Carrier Safety Administration (FMCSA) has updated its list of hours-of-service (HOS) violations used in the Compliance, Safety, Accountability (CSA) enforcement model.

The agency added 22 roadside inspection violations to its HOS Compliance BASIC (Behavior Analysis and Safety Improvement Category). The bulk of the changes address the use of electronic logging devices (ELDs).

Prior to April 1, 2018, roadside inspectors noted ELD violations on roadside inspection reports, but drivers were not placed out of service and the violations were not calculated into the HOS Compliance BASIC. However, ELD violations occurring during roadside inspections effective April 1, 2018, will result in out-of-service orders and impact the CSA HOS Compliance BASIC score.

As a result of full enforcement, FMCSA needed to revise its CSA methodology to include ELD violations. Following is a list of the new HOS violations and assessed severity values:

Citation Description Severity value
395.8A-ELD ELD - No record of duty status (ELD Required) 5
395.8A-NON-ELD No record of duty status when one is required (ELD Not Required) 5
395.8A1 Not using the appropriate method to record hours of service 5
395.11G Failing to provide supporting documents in the driver’s possession upon request 7
395.20B The ELD’s display screen cannot be viewed outside of the commercial motor vehicle 5
395.22A Operating with a device that is not registered with FMCSA 5
395.22G Portable ELD not mounted in a fixed position and visible to driver 1
395.22H1 Driver failing to maintain ELD user's manual 1
395.22H2 Driver failing to maintain ELD instruction sheet 1
395.22H3 Driver failed to maintain instruction sheet for ELD malfunction reporting requirements 1
395.22H4 Driver failed to maintain supply of blank driver's records of duty status graph-grids 1
395.24C1I Driver failed to make annotations when applicable 1
395.24C1II Driver failed to manually add location description 1
395.24C1III Driver failed to add file comment per safety officer's request 1
395.24C2I Driver failed to manually add CMV power unit number 1
395.24C2II Driver failed to manually add the trailer number 1
395.24C2III Driver failed to manually add shipping document number 1
395.28 Driver failed to select/deselect or annotate a special driving category or exempt status 1
395.30B1 Driver failed to certify the accuracy of the information gathered by the ELD 1
395.30C Failing to follow the prompts from the ELD when editing/adding missing information 1
395.32B Driver failed to assume or decline unassigned driving time 5
395.34A1 Failing to note malfunction that requires use of paper log 5

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