Luxury Coach & Transportation

March 2019

Magazine for the professional limousine, charter and tour industry.

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26 LUXURY COACH & TRANSPORTATION MARCH 2019 WWW.LCTMAG.COM Experts Advice Knowledgable Success Safety & Financial Audits I Cost Savings Growth Strategies I Negotiations Product Knowledge I DOT Compliance Improving Your Bottom Line Tom Holden Business Guru Keith Johnson CDS, CSI, CDI Regulatory Consultant 980-999-8484 • Results are Just a Phone Call Away! the device, so we have no idea who is operating the vehicle. Edits: You can edit it because the man- date in 395.22 does say you can assign it to a driver. "I believe based off the charter report and trip records that this driver was in the vehicle." You as- sign it to a driver and he then certifies he received the assignment. Another option is to explain the movement. Violation reports: ese will be the second set of reports FMCSA asks for when it visits. ey will show any 10-hour, 15-hour, or 70-hour violations. Now, some violations can be abated where a driver forgets to log off-duty. You can fix such mistakes. Some will be circumstantial, while others may require you to invoke 395.1B in adverse conditions if the driver ran into some- thing unexpected before dispatch. Here is where you need someone monitoring the daily logs. Once they get away from you, it's very hard to go back and figure out who was in the vehicle or why the record changed. If • Edits • Violation reports • Operational data • Self-auditing Unassigned drive time: is one is simple: e vehicle moved from point A to point B, and nobody was logged into a sticky situation and get written up for something that was just a case of mistaken identity. Supporting Documentation: e ELD mandate added a section to the rules for hours of service. Now, this does not apply for short-haul drivers, but it applies to drivers carrying property and passengers. Regulation 395.11 states: "You must maintain support- ing documentation so that if DOT/ FMCSA investigates, they can compare your paperwork to what the driver was actually doing." FMCSA is confident the ELD will do a good job document- ing drive time. What they're unsure of is off-duty time and on-duty not driving time, but that's what support- ing documents do. Your drivers need to understand the rules are in place to ensure they submit them as supporting documents to FMCSA. For example, such documents would include receipts for fuel, tolls, hotels, meals, etc. The Big Data • Unassigned driving time MOTORCOACH: REGUL ATIONS Richard Malchow from J.J. Keller & Associates helped explain the many compliance requirements involved with ELDs.

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