Entry DateApril 7, 2026
Issue Number26-056-DRV
NameSean Sheridan
AgencyOregon Department of Transportation
Address63085 N Highway 97
Building K
Bend, OR 97703
United States
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Phone5412318220
EmailEmail hidden; Javascript is required.
Issue NameOperational 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.
(Note: If you believe a day’s log is false, but do not have a supporting document to verify the discrepancy, do not use the re-engineered log violation for that day.)

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,
Scale crossing from 4/2/26.

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:
4/2/26 Ashland scale confirms crossing at 1530 hrs PT. Log shows off-duty in Denver, CO. 1,334 miles away. Log re-engineered.

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