Begin with the task being performed
The federal definition in 49 CFR 395.2 includes activities such as vehicle inspection, servicing, loading and other carrier work in on-duty time. It also addresses compensated work outside the motor-carrier business. The absence of vehicle movement does not by itself establish off-duty time.
An ELD can automatically record driving, but the driver still needs to represent non-driving activity accurately. Use the actual task, relief from responsibilities and applicable provisions to determine the record.
Walk through these ordinary work situations
| Activity | Question for the review |
|---|---|
| Pre-trip inspection | When did the driver start inspecting or preparing the vehicle? |
| Loading assistance | Was the driver loading, supervising, attending or receiving shipment paperwork? |
| Vehicle servicing | What work did the driver perform or remain responsible for? |
| Office closeout | Was dispatch, paperwork or other carrier work still being performed after arrival? |
| Another paid job | Does compensated work need to be included in the carrier’s hours review? |
Consider a driver who parks at the terminal, then spends time unloading returns and completing dispatch paperwork. Parking the truck was not necessarily the end of the working day. Record the actual activities rather than carrying the last driving event straight into an assumed rest period.
Keep status and remaining-hours questions separate
First establish the correct activity record. Then assess what that record means for the applicable driving, duty-window and cycle limits. Do not choose a status because it makes a remaining-hours display more convenient.
When the record is inaccurate, use the carrier’s supported correction and annotation process. Preserve original events and have the driver review and certify the resulting record. Ask Factor ELD to show how those tasks work in the proposed app version rather than assuming a universal button sequence. A Driver's Daily ELD Workflow. HOS with ELD: A Daily Planning Guide.
Non-driving work questions
Is every minute in a parked truck on duty?
No. The definition contains conditions and exceptions, including certain resting situations. Review what the driver actually does and which responsibilities remain.
Should work performed after a delivery appear in the review?
Yes. The last delivery does not necessarily end the driver’s duties. Include remaining work when determining the accurate record.