Detention time records: making an arrival timestamp that holds

The federal auditor's finding is the whole problem

In January 2018 the US Department of Transportation's Office of Inspector General published Estimates Show Commercial Driver Detention Increases Crash Risks and Costs, but Current Data Limit Further Analysis (report ST2018019). The title is the finding. The report states that “accurate industrywide data on driver detention do not currently exist,” and that “available electronic data cannot readily discern detention time from legitimate loading and unloading tasks.”

Read that second sentence as an operator rather than an auditor. An electronic logging device can show that a truck was stationary at a facility for four hours. It cannot show whether three of those hours were loading and one was waiting, or the reverse. The distinction between dwell and detention is not in the telematics. It is in what somebody wrote down at the time.

The same report estimated that a 15-minute increase in average dwell time is associated with a 6.2 percent increase in the expected crash rate, and put the cost to for-hire truckload drivers at $1.1–$1.3 billion a year in reduced earnings, with a further $250.6–$302.9 million off carrier net income. Those are national estimates and they will not settle your invoice. They are the reason the subject gets attention at all.

Dwell is not detention

Two words get used interchangeably and mean different things.

US research convention commonly treats dwell beyond two hours as the point where detention is occurring, and FMCSA's 2024 information collection on the impact of driver detention time on safety and operations — approved in the Federal Register on 16 February 2024 — is built on drawing detention out of electronic logging device, transportation management system and telematics data across roughly 80 carriers and 2,500 drivers. That two-hour convention is a research threshold, not your contract. Your free time is whatever the rate confirmation says, and it is the only number that decides the charge.

What a defensible arrival record contains

A timestamp on its own is an assertion. A timestamp that survives challenge has three properties: it was recorded when it happened, it can be tied to a specific vehicle and facility, and it was visible to the other party at the time rather than produced afterward.

1. Arrival at the gate, not arrival at the dock. Record both if they differ — the gap is often where the dispute lives.
2. Who was told. Name of the person checked in with, or the gate system reference. A record naming nobody is hard to stand behind.
3. The appointment it was made against, and whether the truck was inside the window.
4. Start and finish of loading or unloading, separately from arrival and departure. This is precisely the distinction the OIG said electronic data cannot make for you.
5. Departure, with the same care as arrival.
6. Anything that moved the clock: a door not ready, a missing pallet, a reweigh, a lumper, a corrected document.

Where the facility runs a gate system, ask for its record early rather than at claim time — many purge on a short cycle. Where it does not, a driver-entered time plus a photograph with a legible clock or gate sign is worth more than a memory. If the receiver signs the proof of delivery, get the in and out times onto the same document they signed.

Sending the charge

A detention invoice is far likelier to be paid when it is boring: the contractual free time quoted, the two timestamps, the arithmetic between them, the rate, and the supporting record attached. Send it inside whatever window the contract sets. If your agreement is silent on how detention is evidenced, that is the clause to fix before the next season rather than the next invoice.

Ocean demurrage and detention work differently and are governed by their own billing rule — see demurrage and detention invoices for what that requires. What the two have in common is the point above: the charge is only ever as good as the timestamps behind it.

Why this sits with custody

Arrival and departure are custody events. They are the moments responsibility moves, and they are already being recorded — on a phone, in a dispatcher's notes, on a gate log, in a message thread — just not in one place, and usually not in a form anybody can produce six weeks later. Cargovate's platform models a journey as legs and checkpoints, so the times attached to a stop stay attached to it rather than living in whichever system happened to capture them. That does not win an argument by itself. It means the argument starts from a record instead of a recollection.