HOS Documentation — What Carriers Get Wrong

Last reviewed · By Chad Griffith

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Chad Griffith, Founder & CEO

FileFlo — AI compliance document intelligence for DOT, OSHA, and EPA regulated businesses. LinkedIn · About

This comprehensive guide covers everything you need to know about hos documentation: what carriers get wrong. Whether you're a safety manager, compliance officer, or operations director, understanding dot compliance requirements is critical to avoiding costly fines and failed audits.

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Frequently Asked Questions

What HOS supporting documents must I keep?

Per 49 CFR 395.11: bills of lading or trip manifests, dispatch records, fuel receipts, toll receipts, payroll records, inspection reports, and any document that can verify on-duty status (delivery confirmations, weigh-station records, GPS data if used). 6-month retention. Required for both driver-level (proving HOS compliance) and carrier-level (audit defense).

What's the difference between an ELD log and HOS supporting documents?

ELD log: the driver's status (driving, on-duty not driving, off-duty, sleeper berth) recorded automatically by the Electronic Logging Device. Supporting documents: external evidence that verifies the ELD log is accurate. If the ELD shows 'driving' but no fuel receipt, no delivery confirmation, no toll record exists for that period, FMCSA can question the log's accuracy.

How long do HOS records have to be kept?

Per 49 CFR 395.8(k) and 395.11(d): 6 months. ELD logs (electronic) plus all supporting documents. Falsified or altered logs can carry penalties up to $13,500 per false log under 49 CFR 386. Drivers AND carriers can be cited separately for log violations.

What's the most-cited HOS violation?

Per FMCSA enforcement data: (1) Driving beyond 11-hour limit, (2) Driving beyond 14-hour on-duty window, (3) Failing to take required 30-minute break after 8 cumulative driving hours, (4) Inaccurate or falsified logs, (5) Operating without a registered ELD when not exempt. HOS Compliance is consistently in the top 3 BASIC categories for inspection citations.

Does FileFlo handle HOS supporting documents?

Yes. FileFlo's FMCSA rule-pack stores all HOS supporting documents alongside the ELD logs they verify (49 CFR 395.11 categories), per-driver per-trip. 6-month retention with auto-archive. Audit binder cross-references ELD logs to supporting docs in FMCSA review format. Cited HOS violations linked to the supporting docs that would have prevented them.

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