But surely he has clearly stated that he “worked a total of 6 hrs & 12 mins” (including 3h 20m driving) - He didn’t say he was “at work” for 6h12m. If he worked for a total of 6h 12m on that day then he should have taken at least 30 minutes break (or 2x 15 minutes) at some point in the shift. He didn’t, so he got an infringement.