| Entry Date | May 22, 2025 |
|---|---|
| Issue Number | 25-048-DRV |
| Name | Nick |
| Agency | Wright |
| Address | 1220 S. Enterprise Olathe, KS 66061 United States Map It |
| Phone | 913-782-8100 |
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| Issue Name | OOSC, Part I, Item 9. Driver's Record of Duty Status - U.S., Footnote 6 |
| Summary of Issue | The CVSA OOSC, Part I, "Footnotes for driver's RODS - U.S.," footnote #6, refers to Automatic On-Board Recording Devices (AOBRDs) and a "requirement" reference to 395.15 in the footnote. 49 CFR 395.15 has been removed/reserved from the regulation as of November 18, 2024. Therefore, this footnote could be misleading to enforcement personnel. |
| Justification or Need | Any requirement for an AOBRD has been removed now that 395.15 has been reserved. Any driver using a AOBRD will be treated as using a paper RODS or electronic logging software. |
| Request for Action | Remove the last sentence of footnote #6 that reads: "If a driver is unable to produce hours-of-service data from an AOBRD to an authorized safety official as required by 395.15(b), the driver is considered to have no RODS." An alternative may be to amend the wording to something along the lines of: "If a driver is unable to produce hours-of-service data from an electronic logging device or a device formerly known as an AOBRD to an authorized safety official, the driver is considered to have no RODS." |
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