| Entry Date | April 7, 2026 |
|---|---|
| Issue Number | 26-056-DRV |
| Name | Sean Sheridan |
| Agency | Oregon Department of Transportation |
| Address | 63085 N Highway 97 Building K Bend, OR 97703 United States Map It |
| Phone | 5412318220 |
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| Issue Name | Operational Policy 14 - Documenting ELD Tampering |
| Summary of Issue | I’ve had several questions recently regarding how to properly document violations under 395.8(e)(2) for re-engineered/altered logs. After selecting the violation, a prompt will appear asking which days the violations occurred. |
| Justification or Need | This issue should be addressed in CVSA Operational Policy 14. This would help ensure that all inspectors are documenting this violation with the same guidance. |
| Request for Action | This violation falls under the category of a False Record of Duty Status. Therefore, I recommend the following guidance be included in CVSA Operational Policy 14; A violation for 395.8(e)(2) should be recorded for each 24-hour period for which you have a supporting document that does not match the log. Example 1: Log reflects off-duty/sleeper berth on 4/5/26 in Denver, CO. However, you have a scale crossing for that same day in Ashland, OR. Result: Record one (1) re-engineered log violation, as there is only one supporting document (scale crossing) that conflicts with the log. Example 2: Same scenario, but you have: Fuel receipt from 4/4/26, 4/3/26; and, In this case, write three (3) re-engineered log violations, one for each day supported by documentation. Inspectors have also asked how to properly describe the violation. These should be documented similarly to a false log violation: Clearly state what the log shows vs. what the supporting evidence shows. Include location, time, and mileage discrepancy and if space allows, include the term “re-engineered” Example narrative: |
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