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L & L Transportation Services, LLC
2817 E. Wisconsin Ave
Appleton, WI 54911
800-852-1179
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L & L
Transport Service’s tips and instructions on safety
and compliance issues.
MOST
COMMON LOG VIOLATIONS
(FMCSR 395.8)
We
audit thousands of driver logs and we issue thousands
of violations for "Shipping Document Missing/In
Error" and "Duty Change Not Labeled/In
Error." Here's how to avoid these particular
violations:
Shipping Document
Missing/In Error
- When cargo
is on the truck, the driver must record on the
log either a shipping document number or the
name of the shipper and the commodity being
hauled. The number must be something that specifically
identifies the shipment, such as a bill of lading
number or a pro-number. If using "shipper
and commodity" be certain to list both
the company name of the shipper and the specific
commodity you are hauling.
- The number
or shipper and commodity must be recorded in
the "Remarks" section of the log.
The best location for this is on the far left
side of remarks.
- If the truck
is empty for the entire day, the driver should
indicate this. Empty (MT), Deadhead (DH), or
Bobtail (BT) work well. Not recording anything
just looks like the driver made an error. Except
for off duty days, this space should not be
left blank. An auditor or investigator can not
assume the truck was empty.
Duty Change Not
Labeled/In Error
- Each time a
driver changes duty status, the location of
the change must be labeled in the "Remarks"
section of the log with the full city name (no
abbreviations) and the state name abbreviation
(2 letters only). If more than 1 activity occurs
in the same location, such as going from on
duty not driving to off duty or into sleeper,
we suggest a bracket between time markers to
clearly show this all happened in the same location.
BETTER
LIVING THROUGH BETTER LOGGING
(FMCSR 395.8)
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Examples
of: "On Duty, Not Driving"
- Time spent loading or unloading.
- Time attending to the vehicle such
as maintenance and break downs.
- Time spent at the scene of an accident.
- Time spent at a scale inspection or
other law enforcement action, such
as getting a speeding ticket.
- Time spent riding in the vehicle, other
than sleeper berth time.
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Examples
of: "Log Falsification"
- Not logging all loads hauled.
- Showing scale inspections at a different time
or location than when they actually occurred.
- When your logs do not agree with other documents
such as trip reports, traffic tickets,
certified toll receipts, scale inspections,
delivery receipts.
- Logging less miles than you actually
drove.
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Duty
Changes Of Less Than 15 Minutes
Changes
of duty status for short periods of time
(less than 15 minutes) may be identified
by drawing a line from the appropriate
on-duty, not driving or driving line to
the “Remarks” section. The location
of the duty change must be identified
with the full city name and state name
abbreviation. The driver must also
record the amount of time spent, such
as “6 minutes.”
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Owner-Operator
Supporting Documents
As defined
by the FMCSR, owner-operators are employees
of the motor carrier. This means
motor carriers must retain or cause to
be retained supporting documents associated
with the owner-operator’s logs.
Supporting documents include but are not
limited to toll receipts, fuel receipts,
roadside vehicle inspections and other
enforcement documents. Supporting
documents must be available to the motor
carrier within 48 hours. The retention
period for these documents is 6 months.
These documents are the motor carrier’s
responsibility to produce upon request
of the FMCSA whether or not they reimburse
the owner-operator for them.
We suggest
that motor carriers retain copies of the
supporting documents so that they are
available to be used for falsification
checks and safety reviews.
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VEHICLE INSPECTION
(FMCSR 392.7,
396.11, 396.13)
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Pre-Trip Or
Post-Trip & Time Spent
There has traditionally
been a great deal of confusion concerning pre-trip
and post-trip inspections and what to put on the
logs and inspection form, if anything.
To clarify, a long
standing D.O.T. interpretation has held that no
specific time is required for a vehicle inspection.
Actual time spent must be logged. Therefore, if
a driver performs an inspection, the driver is
to log the actual time spent. If it takes less
than 15 minutes for the driver to satisfy himself/herself
that the vehicle is safe to operate, no specific
on duty time is required to be shown on the driver’s
log. Always label a change of duty status with
full city name and state name abbreviation.
It is a common
misconception that the driver’s daily vehicle
inspection report is to be completed as part of
the pre-trip inspection (392.7) & (396.13).
This report, however, is required to be completed
as part of the driver’s post-trip vehicle inspection
(396.11). |
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