What are DOT Log Book Form & Manner Violations?

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Learning the nuances of logging (running under a DOT log book — also known as the Record of Duty Status or RODS) is something that sometimes falls through the cracks in the course of many driver’s development. Instructions and the example found on the back of the logbook may have been the only training many drivers have ever had. On occasions, a DOT officer will sit down with the driver and explain the facts of life about logging.

“My school, nor my company ever got into this specific rule . . .”  Driver

Electronic logging is not a solution, if the driver does not know what he is doing. (See: 395.15(c) Onboard recording device improper form and manner.)

Form and manner violations are log inaccuracies (usually unintentional), sometimes caused by carelessness or even bad habits in filling out the log sheet, and are considered minor violations. (Major violations would be: missing logs, false logs, 70 Hour Rule violations carrying over for more than one day, 11 or 14 Hour Rule violations not created by grid errors, dropped trips.) But small things can start to snowball, and even a form and manner violation will result in one CSA severity point (multiplied by a Time Weight (TiW) of 3 points = 3 points).

One definition of form is the manner or conduct as tested by a prescribed or accepted standard. Manner is defined as a way in which a thing is done or happens.

So a form and manner log violation has to do with the way a log book is done, according to the standard. The standard would be the requirements of 49 CFR Sec. 395.8.

Section d. lists the following:

(1) Date;
(2) Total miles driving today;
(3) Truck or tractor and trailer number;
(4) Name of carrier;
(5) Driver’s signature/certification;
(6) 24-hour period starting time (e.g. midnight, 9:00 a.m., noon, 3:00 p.m.);
(7) Main office address;
(8) Remarks;
(9) Name of co-driver;
(10) Total hours (far right edge of grid);
(11) Shipping document number(s), or name of shipper and commodity;

required information on a DOT log book

Missing information in any of the above requirements would result in a citation for improper form and manner. Trouble comes in the form of abbreviations in the remarks area (as putting down SLC instead of writing out Salt Lake City, UT). But that’s not all.

Sloppiness Counts As Well

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Drivers should show clean corners on a paper log book. Use the edge of a ruler to guide the line.

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Here the extension line should be extended to the remarks section for precision.

center lines

 

 

 

 

 

In this example the status line is not centered between the grid lines.

thin_line

This line has been drawn too light by a fine pen and may not copy well in a fax or copy machine. This is an example of a scripting error. Use a medium point pen for logging.

writing on the grid

Writing on the grid is another error.

Form and manner violations include:

Log Sheet Missing: Drivers shall submit a log for each day, except that two or more consecutive off duty days may be on one sheet Note: regulations require that driver separates off duty days that fall between months by submitting a minimum of two logs;

Date Missing/Duplicate Logs: Each log must be dated and there must be only one log submitted for each day;

Miles Driven Missing: Total actual miles driven in the 24- hour period must be entered;

Vehicle/Trailer Number(s) Missing: Unit numbers of all company vehicles operated in the 24-hour period must be entered;

Driver‘s Signature Missing in Error: The driver must sign his or her full legal name on each daily log sheet;

Co-Driver Name Missing: The driver must enter first name, initial and complete last name of his/her co-driver if operating as a team;

Missing Shipment Identification Error: The driver must show a Trip Number(s) for each trip in the 24-hour period;

Pre-Trip Inspection/Post-Trip Inspection Improperly Noted: Drivers shall identify locations, by full city name and state abbreviation, when performing vehicles inspections;

Change In Duty Status/improper Remarks: Driver’s shall identify locations when changing duty status, by full city name and state abbreviation.

Different Log For Same Day: Each log graph can carry only one set of information;

Hours Missing Error: Drivers must record total hours used at the end of each line of the graph. The hours added together must equal 24;

Graph Incomplete Error: A driver must account for all time on the graph. Drivers must show a complete continuous line for each 24-hour period.

Each year tens of thousands of form and manner violations are cited by the DOT. Work to educate your drivers on the importance of precision logging.

This information was condensed from our Log Audit Guide.

As always, thank you for reading this.

 

The 8 Biggest Mistakes Made In Dealing With Regulations . . .

1. Ignoring Deadlines

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If you get an official notice or a notice from an official, then deal with it. Immediately. Wait until the last day and you are asking for trouble. Once the deadline passes, if you were facing a fine or other sanctions, you may lose your rights to an appeal. Don’t wait until the end of the day: remember the government’s “business day” legally ends at 5 PM not midnight.

Some current problem areas include the Biennial Update or renewal of DOT Number registration or the return of the completed roadside inspection form to the issuing agency (§396.9 Inspection of motor vehicles in operation).

2. Not Filling out Forms — Completely

Mr. Doc

 

 

 

 

 

 

An incomplete form or unsigned form may be taken for a missing form. If the correct response is “NONE” then write “NONE” not “n/a.” And don’t accept “bad paperwork” from employees.

Common errors are found in applications for employment, log books, driver’s vehicle inspection reports (DVIRs), shipping paperwork and supporting documents for logbooks.

3. Not reading, checking or verifying incoming paperwork

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When checking documents, ask yourself “Why?” Why does the results of a drug test have a certain box checked off? Why don’t the supporting documents match the logbook? Why didn’t the driver (or mechanic) sign the DVIR?

You are responsible for every piece of paper crossing your desk. So make every day
your why day.

4. Not Reading the Regulations

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“Every employer shall be knowledgeable of and comply with all regulations contained in this subchapter which are applicable to that motor carrier’s operations.” (49 C.F.R. Part 390.3(e) Knowledge of and compliance with the regulations)

Sure it’s dry stuff. But here’s a tip: Start the Federal Motors Carrier Safety Regulations (FMCSRs) at 49 C.F.R. Part 390 — that would be Chapter One of any other book . . .

5. Not Reading Into the Regulations Far Enough

read me

 

 

 

 

 

The same section goes on to say in (2) “Every driver and employee shall be instructed regarding, and comply with, all applicable regulations contained in this subchapter.” If you are the employer and driver, then all the regulations apply.

Don’t stop reading at the point when it seems the regulations meet our predisposed expectations. Keep going . . .

6. Not Setting up a Tickler File

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A tickler file is a term used by office professionals to remind themselves and keep track of upcoming events. For example: vehicle maintenance and inspections, annual inspections, driver annual reviews, driver’s license renewals, medical examiner’s renewals, the biennial update, all of these documents and forms have due dates or renew dates. Loss of ability to operate and fines may occur to employer and/or driver, if any actions take place after the due dates.

There are many apps that can help in this area.

7. Not Doing Your Homework . . .

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In business it’s called “due diligence.” There is no requirement for any government agency to inform you of your legal and regulatory responsibilities. Transportation laws may vary from state to state and even city to city. Bridge laws and seasonal load restrictions may restrict when and how much you may carry.

Know what you are allowed to do or not do. Get any special permits, if necessary. If you are not sure what you need for a trip, then ask a specialist.

8. Falling Short of the Regulations

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Just as we can’t leap a gap in two jumps, it’s bad policy to ignore regulations or go around them for the sake of expediency. Missing permits, missing paperwork, incomplete files, can lead to trouble, months or years later.

STAR — Stop. Think. Act. Review.

STAR is a safety acronym. In approaching a new work challenge, before rushing in it’s always better to first stop, think it over, before taking action, and then reflect on whether we made the best possible decision.

Many of us make these mistakes due to biases in our thought process.

Availability bias — making a decision based on limited information. “Well, I found it on the Internet, so it must be true . . .”

Anchor bias — making a decision based on an “anchor” fact you have been given. “I won’t vote because the polls show my candidate is down.”

Overconfidence bias — making a decision based on one’s own subject judgement. “I can have it there by tomorrow. No, really . . .”

Confirmation bias — making a decision based on one’s preconceptions, ignoring evidence to the contrary. “The economy will keep growing forever.”

Rush-to-solve bias  — making a decision without considering all of the data. “My intuition tells me it’s a go.”

Summary

Nobody wants to make mistakes. Mistakes cost time and money. Regulatory mistakes often carry a high price tag: audit risk, the potential for unbelievable fines, and even the loss of ability to engage in certain aspects of your business. There is always a lot going on in any successful business or organization, but skipping or going around regulations to save the bother is not one of the options.