A record of duty status (RODS) is a commercial motor vehicle driver's log of how each 24-hour period was spent, divided into off-duty, sleeper berth, driving and on-duty not driving time. Under 49 CFR 395.8, most drivers subject to the hours-of-service rules must keep a RODS, and in most cases it must be recorded on an electronic logging device (ELD).
The RODS matters because it is the main evidence that a driver followed the hours-of-service limits designed to prevent fatigue. Missing, inaccurate or false logs are common roadside violations, count in the HOS Compliance BASIC of FMCSA's Safety Measurement System, and can place a driver out of service. Carriers are responsible for the accuracy of their drivers' logs as well as their own retention of them.
What Is a Record of Duty Status?
The RODS shows each change of duty status during the day, with its time and location, so an inspector or auditor can check compliance with driving, on-duty window and weekly limits. The four duty statuses are:
- Off duty: time the driver is relieved of all duty and responsibility for the vehicle and cargo.
- Sleeper berth: time resting in a sleeper berth that meets FMCSA requirements.
- Driving: time at the driving controls of a CMV in operation.
- On duty not driving: all other work time, including inspections, fueling, loading and unloading, waiting to be dispatched, and paperwork.
ELD vs. Paper Logs
Since the ELD rule took full effect, most drivers required to keep a RODS must use a registered ELD that automatically records driving time from the engine. Paper logs or logging software are still permitted in limited situations, including:
- Drivers who are required to keep a RODS for no more than 8 days in any 30-day period.
- Drivers in driveaway-towaway operations where the vehicle being driven is part of the shipment.
- Drivers of vehicles with engines manufactured before model year 2000.
- Drivers using paper logs temporarily during an ELD malfunction.
Drivers who qualify for the short-haul exception in 49 CFR 395.1(e) do not need a RODS at all on days they meet its conditions, but the carrier must keep time records showing when they start and end work and their total on-duty hours.
ELD drivers must have an instruction sheet describing how to transfer data to an inspector, an instruction sheet for reporting and handling malfunctions, and enough blank paper RODS to record 8 days of duty status. The instruction sheets may be kept in electronic form. Since June 2026, an in-vehicle copy of the ELD user's manual is no longer required. See electronic logging devices for more detail.
Required Entries
A RODS must include, in addition to the duty status grid or ELD record:
- Date and the start time of the 24-hour period used by the driver's home terminal.
- Total miles driven that day.
- Truck or tractor and trailer numbers.
- Name of the carrier and its main office address.
- Driver's signature or certification.
- Name of any co-driver.
- Total hours in each duty status.
- Shipping document numbers, or the name of the shipper and the commodity.
- City and state, or location, for each change of duty status.
On an ELD, much of this information is captured automatically, and the driver must certify each day's record. Edits must be annotated, and the original record is preserved.
Retention and Supporting Documents
- Driver copies: drivers must be able to show the current day's record and the previous 7 consecutive days.
- Submission to the carrier: under 395.8(i), drivers must submit RODS and supporting documents to the carrier within 13 days of completing each record. With an ELD, this happens electronically.
- Carrier retention: under 395.8(k), carriers must keep RODS and supporting documents for each driver for 6 months from the date of receipt, with a backup copy kept on a separate device for ELD records.
- Supporting documents: under 49 CFR 395.11, carriers must keep up to 8 supporting documents per driver per 24-hour period, such as bills of lading, fuel and toll receipts, dispatch records and payroll records, which can be used to verify the logs.
How to Manage RODS Compliance Step by Step
- Determine who needs a RODS. Identify drivers covered by ELD requirements, paper log exceptions and the short-haul exception.
- Equip and train drivers. Install registered ELDs and train drivers on duty status changes, personal conveyance, yard moves and malfunctions.
- Keep the in-cab documents. Make sure each driver has the data transfer and malfunction instructions and blank paper logs.
- Audit logs regularly. Compare RODS with supporting documents to find falsification, form and manner errors and HOS violations.
- Resolve unassigned driving time. Review unidentified driving events and assign them to the right driver or annotate why they are not driving time.
- Correct and coach. Address violations with documented coaching and follow-up.
- Retain records. Keep RODS and supporting documents for 6 months in a way that can be produced in an audit.
Common Mistakes to Avoid
- Logging pre-trip inspections, fueling or waiting time as off duty.
- Misusing personal conveyance or yard move status to hide driving time.
- Leaving unassigned driving events unresolved.
- Not keeping supporting documents, or discarding them before 6 months.
- Running on paper logs longer than allowed during an ELD malfunction without notifying the carrier.
How SMS360 Helps
SMS360's DOT Compliance module keeps hours-of-service related records, reminders and audit findings in one place. Training Management tracks driver training on ELD use and HOS rules, and Fleet Reports helps review violations by driver and terminal.
Frequently Asked Questions
How long must carriers keep RODS?
Carriers must keep each driver's RODS and supporting documents for 6 months from the date of receipt under 49 CFR 395.8.
What should a driver do if the ELD malfunctions?
The driver must note the malfunction, notify the carrier within 24 hours, and reconstruct the RODS for the current day and the previous 7 days on paper or logging software unless the records can be retrieved. The carrier must correct or replace the ELD within 8 days or request an extension from FMCSA.
Is a RODS the same as an ELD?
No. The RODS is the record itself. An ELD is the device most drivers must use to create it.
