Hours of Service Compliance Audit

Flag any DOT medical card expiring within 60 days. Drivers with a lapsed medical certificate are out-of-service under Part 391.41 — common gotcha is the 12-month card (vs. standard 24-month) for hypertension or diabetes that gets logged as 24-month in the DQ system.

Verify a full Clearinghouse query has been run for each driver within the last 365 days per 49 CFR 382.701. Capture the query date and consent in the DQ file. Capture whether any DQ files have lapsed credentials of any type — this drives the renewal step at the end of the audit.

Export driver-by-driver RODS from the ELD platform (Motive, Samsara, Geotab, Omnitracs, etc.) covering the last 30 days. Save the export to the audit folder so the records exist outside the ELD vendor in case of a Compliance Review.

Confirm the ELD make, model, and version are still listed at the FMCSA registered ELD list. Devices get revoked — a revoked ELD is treated as no ELD at all and triggers an 8-day replacement clock under 395.22.

Pull the unidentified driver report. Each unidentified event must be assigned to a driver or annotated with a yard-move / shop-tech reason. Carriers commonly fail audits by leaving 30+ minutes of unidentified driving sitting unassigned for weeks.

For drivers using the 150 air-mile short-haul exemption (395.1(e)(1)), confirm timesheets exist and the driver returned to the work-reporting location within 14 hours. Drivers who break exemption on any day must run an ELD log for that day.

Run the violation / exception report from the ELD platform for the audit period. Tag whether any violations were detected — this drives the driver counseling step at the end of the audit.

Compare driving time and on-duty window per Part 395.3. Repeat 11-hour overruns within a 30-day window are an Unsafe Driving / HOS Compliance BASIC hit on CSA — not just a paperwork issue.

Confirm each driver took a 30-minute non-driving break before 8 cumulative hours of driving. Sleeper berth, off-duty, and on-duty-not-driving all qualify since the 2020 rule change — drivers commonly mis-log this as off-duty when they were actually on-duty fueling.

Check rolling 7/8-day totals and any 34-hour restarts. Note any drivers who flipped between 60-hour and 70-hour cycles mid-period — that is a common ELD configuration error rather than a real driver violation.

Pull the edit log. Every edit by a back-office user requires driver re-certification under 395.30. Edits that move driving time to on-duty-not-driving without an annotation are a falsification flag in a Compliance Review.

Personal conveyance is only valid when the driver is fully relieved from duty and the move is for the driver's benefit, not the carrier's. Loaded drives to the next shipper, repositioning to find parking under dispatch direction, and bobtails to the yard are not PC. Flag any PC segment over 1 hour or 50 miles for review.

For team and solo split-sleeper drivers, confirm the 7/3 or 8/2 split math. Neither period counts toward the 14-hour window when paired correctly. Most ELDs apply the split automatically only after the second qualifying period — manual splits are a common error source.

Pull the malfunction and diagnostic event report from the ELD platform. Capture whether any units have an open malfunction — under 395.34, drivers must paper-log and the carrier must repair or replace the device within 8 days.

Per 395.22(h), each cab must carry the ELD user manual, an instruction sheet for data transfer to a roadside officer, an instruction sheet for malfunction reporting, and a supply of blank paper logs for at least 8 days. Spot-check 10% of the fleet.

Schedule the swap or service ticket with the ELD vendor before the 8-day deadline from initial malfunction. Drivers continue on paper logs in the meantime — confirm dispatch is aware so they don't push the driver past 11 hours without ELD enforcement.

Hold a documented coaching session for each driver with a confirmed violation. Capture the conversation date, the specific log entries reviewed, and the driver's signed acknowledgment. Repeat violations within 90 days escalate to written warning per company progressive discipline policy.

Schedule MVR re-pulls, DOT physicals, or Clearinghouse queries for any flagged drivers. Place the driver out-of-service from dispatch until the credential is back in the DQ file — Part 391.11 prohibits dispatch of an unqualified driver, and insurance carriers will disclaim coverage on a loss involving one.

The Safety Director reviews the audit summary, captures the overall result, and signs. The signed audit packet lives in the safety records folder for at least 6 months under 395.8(k) and longer per company retention policy — this is the artifact the FMCSA auditor asks for first in a Compliance Review.