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 |
Originally shared via the Idealease Safety Bulletin