Maintaining accurate Hours-of-Service (HOS) records is a foundational part of FMCSA compliance. Whether your fleet uses Electronic Logging Devices (ELDs) or is permitted to use paper logs under exemptions, consistency and accuracy in timekeeping are important for passing a compliance review or roadside inspection.

Below is a structured approach to help your operation meet regulatory requirements and avoid common audit findings.

1. Understand the Differences Between Paper Logs and ELD Requirements

**Reference:** 49 CFR § 395.8 for general HOS logging and § 395.22 for ELD specifics.

2. Best Practices for Correcting Errors Without Violations

Incorrect log entries—such as missing a duty status change or incorrect location data—can trigger violations if not corrected properly. Here’s the process to correct errors:

For ELD Users:

Annotate Changes: If a duty status needs to be changed, add a brief annotation explaining why.
Driver Re-Certification: Edits by a motor carrier should be approved and re-certified by the driver before submission.
Audit Trail: Ensure your system maintains an edit log for review.

For Paper Log Users:

One Strike: Cross out errors with a single line and initial the change.
No White-Out or Obscuring Ink: Logs must remain legible and unaltered in intent.

3. Common Audit Flags in HOS Records

DOT auditors look for consistency, completeness, and legitimacy in log entries. Red flags include:

Form & Manner Violations: Missing signatures, dates, or vehicle/trailer numbers.
Unassigned Drive Time (ELDs): Drive time not associated with a driver ID.
Editing: Inconsistencies between timestamps and GPS location data.
Misuse of Personal Conveyance or Yard Move statuses.

Regular internal reviews can catch and correct errors before they escalate into violations.

4. Sample Daily Log with Annotations (ELD Format)

Here is a simplified example of a properly annotated log:

Date: 02/15/2026

Driver: John Smith

Vehicle #: 5432

Carrier: Clay Trucking Inc.

06:00 - 07:00: On Duty (Pre-Trip Inspection and fuel)

07:00 - 12:00: Driving

12:00 - 13:00: Off Duty (Lunch)

13:00 - 17:00: Driving

17:00 - 17:30: On Duty (Post-Trip)

17:30 - 22:00: Off Duty

Driver Signature & Certification Line
Recorded GPS location matches timeline

Audit-Readiness Action Item

Review your fleet’s HOS records from the past 14 days. Use a checklist to review:

Unassigned drive time
Corrected errors are properly annotated
Logs are signed and certified
Logs include required form and manner elements

How to Maintain Accurate Hours‑of‑Service Records