Magellan
ELD log review: resolve unidentified driving and proposed edits
Investigate unidentified driving, route carrier-proposed edits through the driver, and retain the evidence behind each ELD review decision.
An ELD can record activity without resolving the company's questions about it. A dashboard alert may need explanation, an unidentified movement may need investigation and an edit may need the driver's review under the applicable process. Assign a responsible reviewer and a clear question rather than assume the system's existence proves hours-of-service control.
Use a review queue that distinguishes urgency and type. An issue affecting the next assignment should not wait for a routine weekly meeting. A periodic sample may help identify process weaknesses, but the frequency is a company choice unless a particular requirement sets it. Avoid presenting “weekly log audit” as a universal federal rule.
The record-of-duty-status rule, 49 CFR 395.8 (https://www.ecfr.gov/current/title-49/section-395.8) concerns the records and operations within its scope, including applicable exceptions. Establish that scope before applying a checklist. Record which driver, vehicle, date and source are being reviewed. An alert count is a starting point for investigation, not a finding of misconduct or a complete explanation of what happened.
Use the available operational evidence to understand an apparent discrepancy. The supporting-documents rule, 49 CFR 395.11 (https://www.ecfr.gov/current/title-49/section-395.11) identifies categories and conditions within its scope. Relevant records may be held in dispatch, billing or another approved system; the review should establish the link to the driver and date without collecting unrelated material.
A hypothetical fueling receipt and a log entry may appear inconsistent because they use different time zones, identify different vehicles or reflect a later payment event. Check the actual record basis before reaching a conclusion. Preserve the source and explain any conversion or inference. Do not edit a source document to make the timeline look cleaner.
A practical evidence index records the source system, person responsible, matching identifiers and retrieval method. It should also identify what is unavailable. The purpose is to answer the particular question using genuine evidence. A large export with no clear link to the event can be less useful than a focused set of correctly identified records. Keep access appropriate and protect the driver's privacy.
Example: a receipt that appears one hour out
The examples in this guide are fictional. Fueling receipt F-204 records September 14, 2026, 07:15 MDT (UTC−06:00); the related ELD export records 08:15 CDT (UTC−05:00). The reviewer verifies both stated time bases, matches Unit 204 and Driver 104, and confirms that the receipt time identifies fueling rather than a later card settlement. Both times convert to 13:15 UTC on September 14.
The resolution note records the source references and conversion: “F-204 and the ELD event show the same instant after verified time-zone conversion; no timing discrepancy remains.” The originals stay unchanged. This finding resolves the apparent one-hour difference; the reviewer still evaluates any separate duty-status question on its own evidence.
49 CFR 395.32 (https://www.ecfr.gov/current/title-49/section-395.32) requires the carrier to review unidentified driving and annotate why it remains unassigned or assign it to the appropriate driver. 49 CFR 395.30 (https://www.ecfr.gov/current/title-49/section-395.30) addresses driver review/certification and edits, annotations and required change history. Do not automatically assign every unidentified movement to whichever driver normally uses the truck, or change a log merely to eliminate an alert.
Record the unit, time, source information, person consulted, explanation and actual resolution. A yard movement, maintenance activity and a driver's movement are different factual possibilities. Verify the relevant facts instead of choosing the most convenient label. Preserve original information and the required change history.
For example, Unit 204 records seven minutes of unidentified driving from 08:42 to 08:49 CDT on September 15. Load assignment L-104 names Driver 104, the facility gate record G-204 identifies that driver leaving with the unit at 08:44, and the driver confirms operating it during the recorded interval. The reviewer checks that these records describe the same unit and movement rather than assigning the event merely because Driver 104 usually uses the truck.
Driver 104 reviews the unassigned time when prompted by the ELD and assumes the records belonging to them, as required by 395.32(b) (https://www.ecfr.gov/current/title-49/section-395.32). The review trail records the assignment to Driver 104 and the driver's action. Its annotation reads: “September 15, Unit 204, 08:42–08:49 CDT: Driver 104 confirmed operation; matched assignment L-104 and gate record G-204. Driving record assigned to Driver 104; original event and change history preserved.” The seven-minute movement remains driving time; the correction identifies its driver rather than relabeling it to remove an alert. If the evidence did not establish the driver, the reviewer would keep the identification question open and annotate the actual reason it remained unassigned.
An annotation should state the actual reason and supporting facts. Personal-conveyance, yard-move and malfunction questions also need their own applicable rules; an internal label cannot create an hours-of-service exception.
Carry a proposed edit through the driver’s review
In the proposed-edit example, a driver has submitted a record with an incorrect shipping-document reference. The reviewer compares it with the genuine bill of lading and identifies a proposed correction. The driving events are not moved to resolve this reference error.
Under 49 CFR 395.30(d) (https://www.ecfr.gov/current/title-49/section-395.30), a carrier may propose an accuracy correction after the driver has submitted the record. The driver must electronically confirm or reject a change made by another person or system. For the carrier’s change to take effect, the driver confirms the proposal, implements the appropriate edit, recertifies and resubmits the record. The annotation explains why the reference changed.
If the driver rejects the proposal, do not apply it as an accepted correction. Preserve the response and investigate the remaining disagreement. A rejected proposal alone is not a corrected record. The carrier must not pressure the driver to falsely certify it; 395.30(e) (https://www.ecfr.gov/current/title-49/section-395.30) prohibits that coercion.
Topics
- HOS / ELD / Logs / Supporting Documents