Regulations governing electronic logging devices (ELDs) require drivers and other motor carrier personnel to enter certain annotations into the ELD record. Annotations - comments added to a driver's ELD record - are used to explain any special exemptions that apply, any edits that were made, or any other special circumstances that exist.
The trouble is, the hours-of-service regulations offer no guidance on what the annotations should say, and annotations are restricted to just 60 characters. This can make it difficult to decide how to write one.
What was going on?
Written properly, annotations help roadside enforcement personnel and auditors understand what was going on during a driver's day. Perhaps a driver hit heavy traffic and used the "adverse conditions" exception, or forgot to switch to "personal use" when driving to a local restaurant for lunch.
Annotations can be used to explain each of these. Absent an annotation, an inspector may assume there was a violation of the hours-of-service rules. This can make a properly written annotation vital to compliance.
The following are suggested annotations that may be used to explain various exemptions that may apply, as well as edits that ELD administrators may need to make. Keep in mind that annotations should be clear, concise, and refer to a regulation whenever possible.
Note to drivers: Your ELD may automatically account for the use of some of these exemptions and may make manual annotations unnecessary. Check with your safety office for details. When applicable, and as space allows, enter a document number for any documentation (e.g., shipment number, BOL number, work order number, etc.) that can support your claim of an exemption.
EXEMPT FROM MOST SAFETY REGULATIONS INCLUDING HOS
|School bus operation (home to school, school to home)||School bus operation 390.3(f)(1)|
|Non--commercial transportation of personal properly||Non-commercial, personal property 390.3(f)(3)|
|Transporting deceased/sick/injured persons||Transporting corpse/sick person/injured person 390.3(f)(4)|
|Fire truck or rescue vehicle engaged in emergency operations||Engaged in emergency rescue/fire operations 390.3(f)(5)|
|9- to 15-passenger CMV, not used for direct compensation||<16 passenger vehicle, no direct compensation 390.3(f)(6)|
|Propane winter-heating fuel delivery in response to an emergency condition||Emergency propane heating-fuel delivery 390.3(f)(7)|
|Pipline emergency response||Pipeline emergency response 390.3(f)(7)|
EXEMPT FROM ALL HOURS OF SERVICE
|Emergency conditions||Emergency 395.1(b)(2):________ [enter explanation of the emergency]|
|Agricultural exemption||Ag commodities/Farm supplies, 150-air-mile, 395.1(k)|
|Utility service vehicle exemption||Utility service vehicle; HOS exempt 395.1(n)|
|Covered farm vehicle exemption||Covered farm vehicle; HOS exempt 395.1(s)|
EXEMPT FROM CERTAIN HOS PROVISIONS
|Adverse driving conditions||
Adverse conditions 395.1(b):________ [enter reason for unexpected delay, and location, such as:
|Oilfield equipment 24- hour restart||Oilfield equipment, 24-hr restart 395.1(d)(1)|
|Oilfield waiting time for specialized equipment||Oilfield waiting time 395.1(d)(2)|
|100-air-mile exception||100 air mile time record 395.1(e)(1)|
|150-air-mile exception for non-CDL drivers||150 air mile time record 395.1(e)(2)|
|Local retail store delivers during Christmas season (Dec. 10-25)||Retail store deliveries, 100 air mile radius 395.1(f)|
|Split sleeper-berth option||Split sleeper berth 395.1(g)|
|Split rest break using sleeping accommodation at a natural gas or oil well site||Split break, slept at oil/gas well location 395.1(g)(3)|
|Split break for passenger-carrying vehicle with sleeper berth||Split rest in bus sleeper berth, 395.1(g)(3)|
|Alaska - property-carrying vehicle||Alaska HOS 395.1(h)(1)|
|Alaska - passenger-carrying vehicle||Alaska HOS 396.1(h)(2)|
|Groundwater well drilling 24-hour restart||Groundwater well drilling rig 24-hr restart 395.1(l)|
|Transportation of construction materials and equipment in a 75-air-mile radius, 24-hour restart||Construction materials/equipment 24-hr restart 395.1(m)|
|Short-haul 16-hour exception allowed once per week||Short-haul 16-hour limit 395.1(o)|
|TV/movie production exception||TV/movie HOS 395.1(p)|
|30-minute break exception for Div. 1.1, 1.2, 1.3 explosives||1.1/1.2/1.3 explosives; break may be on duty 395.1(q)|
|30-minute break exemption for bee transportation||Transporting bees; exempt from 30-min break 395.1(u)|
|30-minute break exemption for livestock transportation||Transporting livestock; exempt from 30-min break 395.1(v)|
|Hi-rail exception for transportation to/from duty assignment||Hi-rail CMV; to/from duty assignment 395.1(w)|
|Personal Conveyance (if "personal use" driving category is not selected in the ELD||Personal use: _________ [enter a brief explanation of the personal use, to justify its use]|
EXEMPT FROM ELD USE
|ELD exempt: driver not required to log more than 8 days in 30 consecutive days||ELD exempt: <8 days in 30 - 395.8(a)(1)(iii)|
|ELD exempt: driven vehicle is being delivered via driveaway/towaway operation||ELD exempt: driven unit being delivered 395.8(a)(1)(iii)|
|ELD exempt: motor home or RV trailer being delivered via driveaway/towaway operation||ELD exempt: motor home/RV being delivered 295.8(a)(1)(iii)|
Note: An administrator may use the following suggested annotations to explain why an ELD record was edited.
|Log out error||Forgot to log out at proper time|
|Log in error||Forgot to log in at proper time|
|Missed duty status change||
Forgot to log off duty for break
Forgot to switch to SB [sleeper berth]
Forgot to switch to on duty
|Duty status changes took place while the driver was away from the logging device||Duty status changed when away from ELD|
|Driving time cannot be assigned to a specific ELD driver account||
Drive time unassignable; _______ [explain]
"At shop for repair, driven by 3rd party" [other details should be added as avaialble, such as shop name, work order number, etc.]
"Driven by exempt driver; _______ [explain why driver is not assigned an ELD account; identify the driver if possible]
|Yard move logged as driving||Forgot to switch to yard move|
|Driving logged as yard move||Forgot to switch to normal driving|