elds: an overview
TRANSCRIPT
United States ElectronicLogging Device Mandate
Presented By: Joel BealManaging Partner & COO, JBA Telematics
eMaint Best Practices Webinar • March 2016
1. Brief Background of Electronic Logging Devices2. The New ELD rule 3. Technical Requirements4. The Certification Process for ELD Vendors5. What to Expect During an Audit
The Electronic Logging Device Mandate
Poll Question #1
How familiar are you with the Electronic Device Mandate? 1) Not familiar at all 2) Somewhat familiar3) Very familiar, I work with ELDs everyday
The Background of Electronic Logs
The BackgroundIt is more interesting than it looks……
1987 – Frito Lay implements electronic logs under a US DOT waiver
1988 – US Code of Federal Regulations Section 49, 395.15. The Automatic Onboard Recording Device, “AOBRD”.
1994 – Transportation Authorization Act specifies “supporting documents”
2003 – Hours of Service NPRM proposed an Electronic Onboard Recorder (EOBR) mandate for some. Not included in final.
The BackgroundIt is more interesting than it looks……
2004 – Work begins on the second phase of EOBR rulemaking, “EOBR2”
2010 – EOBR2 Notice of Proposed Rulemaking (NPRM).
2011 – EOBR rule vacated as a result of law suits. The issue – driver harassment.
2012 – MAP-21 Requires “Electronic Logging Devices” (ELDs) for all who currently are required to keep drivers logs
The Background
MAP-21 – “Moving Ahead for Progress in the 21st Century”. Passed by a bi-partisan Congress and signed into law by the President
Deadline of October 2013 for publication December 16 2015 - published in the Federal
Register; 12/16/2019: deadline for AOBRD users 12/18/2017: deadline for paper log users
Why Require ELDs?
• FMCSA estimates annually:– Avoid 1844 crashes– Prevent 562 injuries– Save 26 lives
• Improve HOS compliance• Automate, to some extent, compliance audits
The New ELD Rule
And the Rule Is?
• SNPRN published February 2014• Rule published December 16 2015• Four areas covered in SNPRN;1. Minimal technical standards for ELDs2. Directs all drivers who use logs to begin using an
ELD3. Establishes exact requirements for Supporting
Documents4. Prohibits driver harassment. Establishes a driver
complaint process, and a carrier due process.
Alphabet Soup
We’re all running under the AOBRD rule in the US – since September 30, 1988.
There never was an EOBR – it died before it started.
The next rule is ELD.
Rule Timeline
Rule Published
Year 2All Paper-Log
Drivers Comply
Year 4All AOBRD
Drivers Comply
What is an ELD?
Take an existing device that automates HOS logging – modernizes the rule and mandates use
Captures all CMV MovementDoes not allow deletion of driving timeDoes not capture all drivers’ time – thus the need
for supporting documentationTamperproofGive drivers more control of their logs than the
current AOBRD rule
Who?
• Everyone who keeps paper logs
Exceptions:• Timecard drivers – if they do not use paper
logs for more than 8 out of any 30 day period• Driveaway / towaway• CMVs manufactured before 2000
Supporting Documents
• Up to 8 supporting documents for a 24 hour period
• Submit within 8 days• Must produce at roadside if requested• Carrier must retain for 6 months
What is a supporting document?
• BOL• Dispatch and Trip Reports• Expense Receipts• Mobile Communications• Payroll
What does a supporting document contain?
• Driver name• Date • Time• Location
Technical Requirements
Technical Requirements
Connected to ECM1. Engine Power Status2. Distance3. Motion Status4. Engine Hours
Technical Requirements
GPS Location Recording1. Every 60 minutes2. At engine on/off3. At beginning/end of yard moves4. At beginning/end of personal use5. Location accuracy decreases when
used for personal conveyance or off duty.
Technical Requirements
In the Cab1. Graph/Grid Display or Printout2. Information must be accessed
outside of cab. 3. Driver Name and ELD user name4. Carrier name/address5. Engine hours and distance for
each driving period6. Malfunction and diagnostic status7. Unassigned driver miles/time
warning8. On Duty Not Driving when no
motion > 5 minutes, or driver has not responded to ELD prompt in > 1 minute.
9. Mounted and secured when moving
Technical RequirementsOnboard Communicating to Enforcement
Upon demand - at least two of:1. USB2. Web Services3. Blue Tooth4. Email5. Printout
Technical Requirements
Log Edits1. Drive time cannot be edited2. Driver edits, office approves3. Office edits, driver approves4. All edits are tracked and original
record retained
Technical Requirements
Tamper Resistance1. Self-diagnostics and reporting via
flat file2. Reasonably resistant to
tampering3. Original data must be unalterable
and not erasable
Limited Automatic Status Changes
• Drive when wheel motion is detected• If stopped for more than 5 minutes –warn the
driver. If no response, then driver auto-switched to On Duty Not Driving
• All other automatic duty status changes are prohibited
Driver Harassment Provisions
• Mute audible alerts when in sleeper• Personal conveyance GPS accuracy shown on
logs is 10 mile radius – instead of 1 mile radius with other statuses
• Driver certifies any log edits• Driver has access to all logs
ELD Certification
ELD Supplier Certification
• Create system that complies with the rule• Onboard flat files that report on faults, tampering,
and power events• Certification proof marked visibly on device• FMCSA developed a certification checklist • Electronic Logging Device Vendor Registration –
online portal within FMCSA• Vendor provides user documentation to FMCSA• Chance of non-compliant devices?
Picking a Supplier
• Use only a supplier that is certified • Ask for documentation on testing protocols and
processes that the supplier used to self-certify• Make sure they fit YOUR rules – intrastate and
interstate federal exemptions/exceptions. • Ability to audit and report on HOS without
looking at every log every day• Don’t wait until the last day
Audits
Roadside Inspections
1. Is the ELD device compliant? Decal Drivers Handbook2. Show me your logs… Electronic transfer of logs to ASPEN system Print out of logs Email logs3. Paper logs accepted if; Casual driver Rental truck Device failure
Office Inspections
1. Same conditions will trigger an audit2. Logs may be viewed or printed3. May ask to see original logs where edits are
made4. Supporting documents required5. Six previous months plus current month in the
office6. 13 days to get logs from truck to office7. 7 previous days plus current day on the road
Why Adopt Now?
1. It’s Not the Good Old Days2. Progressive fleets have always focused on
safety and profitability. Compliance follows.3. Those other guys – they’ll comply at the last
minute with as little money as possible
Questions?
Joel BealManaging Partner & COO, JBA Telematics