Using Suggested ELD Annotations for Exemptions and Log Edits

Purpose

This article provides guidance on creating clear, concise Annotations in Electronic Logging Device (ELD) records to explain exemptions, edits, or special circumstances, ensuring compliance and aiding inspectors or auditors in understanding Driver activity. It includes suggested 60-character annotations for common exemptions and ELD record edits.

When to Use This Article

Use this article when a driver or administrator needs guidance on what annotations to enter when claiming an exemption, explaining a special circumstance, or editing an ELD log record. Proper annotations help roadside enforcement and auditors understand what was happening during a driver's day.

Steps to Follow

When writing an annotation, follow these guidelines:

1. Keep annotations clear and concise (60 characters or less when possible).
2. Reference the applicable regulation whenever possible.
3. Include supporting documentation details (e.g., shipment number, BOL number, work order number) when applicable and as space allows.
4. Select the appropriate annotation from the reference tables below based on the situation.

Note to drivers: Your ELD may automatically account for the use of some exemptions and may make manual annotations unnecessary. Check with your safety office for details.

Exemptions (PDF Copy)

EXEMPT FROM MOST SAFETY REGULATIONS INCLUDING HOS
Exemption	Suggested Annotation
School bus operation (home to school, school to home)	School bus operation 390.3(f)(1)
Non-commercial transportation of personal property	Non-commercial, personal property 390.3(f)(3)
Transporting deceased/sick/injured persons	Transporting corpse/sick person/injured person 390.3(f)(4)
Fire truck or rescue vehicle engaged in emergency operations	Engaged in emergency rescue/fire operations 390.3(f)(5)
9- to 15-passenger CMV, not used for direct compensation	<16 passenger vehicle, no direct compensation 390.3(f)(6)
Propane winter-heating fuel delivery in response to an emergency condition	Emergency propane heating-fuel delivery 390.3(f)(7)
Pipeline emergency response	Pipeline emergency response 390.3(f)(7)
EXEMPT FROM ALL HOURS OF SERVICE
Emergency conditions	Emergency 395.1(b)(2):________ [enter explanation of the emergency]
Agricultural exemption	Ag commodities/Farm supplies, 150-air-mile, 395.1(k)
Utility service vehicle exemption	Utility service vehicle; HOS exempt 395.1(n)
Covered farm vehicle exemption	Covered farm vehicle; HOS exempt 395.1(s)
EXEMPT FROM CERTAIN HOS PROVISIONS
Adverse driving conditions	Adverse conditions 395.1(b):________ [enter reason for unexpected delay]
Driver-salesperson	Driver-salesperson 395.1(c)
Oilfield equipment 24-hour restart	Oilfield equipment, 24-hr restart 395.1(d)(1)
Oilfield waiting time for specialized equipment	Oilfield waiting time 395.1(d)(2)
150-air-mile exception	150 air mile time record 395.1(e)(1)
150-air-mile exception for non-CDL drivers	150 air mile time record 395.1(e)(2)
Local retail store delivers during Christmas season (Dec. 10-25)	Retail store deliveries, 100 air mile radius 395.1(f)
Split sleeper-berth option	Split sleeper berth 395.1(g)
Split rest break using sleeping accommodation at a natural gas or oil well site	Split break, slept at oil/gas well location 395.1(g)(3)
Split break for passenger-carrying vehicle with sleeper berth	Split rest in bus sleeper berth, 395.1(g)(3)
Alaska - property-carrying vehicle	Alaska HOS 395.1(h)(1)
Alaska - passenger-carrying vehicle	Alaska HOS 395.1(h)(2)
Groundwater well drilling 24-hour restart	Groundwater well drilling rig 24-hr restart 395.1(l)
Transportation of construction materials and equipment in a 75-air-mile radius, 24-hour restart	Construction materials/equipment 24-hr restart 395.1(m)
Short-haul 16-hour exception allowed once per week	Short-haul 16-hour limit 395.1(o)
TV/movie production exception	TV/movie HOS 395.1(p)
30-minute break exemption for bee transportation	Transporting bees; exempt from 30-min break 395.1(u)
30-minute break exemption for livestock transportation	Transporting livestock; exempt from 30-min break 395.1(v)
Hi-rail exception for transportation to/from duty assignment	Hi-rail CMV; to/from duty assignment 395.1(w)
Personal Conveyance (if "personal use" driving category is not selected in the ELD)	Personal use: _________ [enter a brief explanation of the personal use]
EXEMPT FROM ELD USE
ELD exempt: driver not required to log more than 8 days in 30 consecutive days	ELD exempt: <8 days in 30 - 395.8(a)(1)(iii)
ELD exempt: driven vehicle is being delivered via driveaway/towaway operation	ELD exempt: driven unit being delivered 395.8(a)(1)(iii)
ELD exempt: motor home or RV trailer being delivered via driveaway/towaway operation	ELD exempt: motor home/RV being delivered 295.8(a)(1)(iii)

Edits (PDF Copy)

Note: An administrator may use the following suggested annotations to explain why an ELD record was edited.

Edit Reason	Suggested Annotation
Log out error	Forgot to log out at proper time
Log in error	Forgot to log in at proper time
Missed duty status change	Forgot to log off duty for break / Forgot to switch to SB / Forgot to switch to on duty
Duty status changes took place while the driver was away from the logging device	Duty status changed when away from ELD
Driving time cannot be assigned to a specific ELD driver account	Drive time unassignable; _______ [explain — e.g., "At shop for repair, driven by 3rd party" or "Driven by exempt driver"]
Yard move logged as driving	Forgot to switch to yard move
Driving logged as yard move	Forgot to switch to normal driving

What Not to Do / Common Pitfalls

• Do not leave annotations blank — an inspector may assume a violation occurred without an explanation.
• Do not use vague or unclear language — annotations should be specific enough to explain the situation.
• Do not forget to reference the applicable regulation when claiming an exemption.
• Do not exceed the character limit — keep annotations concise (60 characters or less when possible).

Escalation Path

For questions about which exemption or annotation applies to a specific situation, contact your company's safety office or Encompass administrator. For technical issues with entering annotations, contact 24/7 ELD Support at 1-800-327-1342 or [e-mail].