. My understanding is our 12 digit load number is sufficient to be used in lieu of BOL #.
no it's not,
you carrier is making the rules as they pleased,
no such things on the books,
it's an "blood sucking lawyer" in the making,
and you will be the one footing the bill.
BTW, :
§395.8(d)(11) dose not say "carrier trip #" or nothing like that.
"Question 14: What documents satisfy the requirement to show a shipping document number on a record of duty status as found in §395.8(d)(11)?
Guidance: The following are some of the documents acceptable to satisfy the requirement: shipping manifests, invoices/freight bills, trip reports, charter orders, special order numbers, bus bills or any other document that identifies a particular movement of passengers or cargo.
In the event of multiple shipments, a single document will satisfy the requirement. If a driver is dispatched on a trip, which is subsequently completed, and then is dispatched on another trip on that calendar day, two shipping document numbers or two shippers and commodities must be shown in the remarks section of the record of duty status."
good reading of a FMCSA published Q&A here :
Interpretation for 395.8: - Federal Motor Carrier Safety Administration