Motor carriers researching systems for compliance with the US Electronic Logging Devices and Hours of Service Supporting Documents rule will have to do their homework in terms of what ELDs need to do and what type of device or system is best for their fleets, especially given that the manufacturer self-certification system for the technology is also just being established.
1. How will you know that an ELD is compliant?
The ELD rule includes standards for devices and systems that individual manufacturers and vendors will need to decide how to meet with their products (functional specifications are listed in Appendix A to Subpart B of Part 395).
Because of the number of existing automatic onboard recording devices and systems available, and the likelihood there will be more introduced to meet the ELD standard, the US Federal Motor Carrier Safety Administration has chosen not to approve or disapprove ELDs. Instead, it has established a registration and self-certification process for manufacturers to follow, with a public website listing those that have completed the process. Self-certification is an honour system, but according to the rule, carriers will be able to use only ELDs from the list. FMCSA will investigate ELD models on the list based on complaints and will give the manufacturer the opportunity to correct the problem or be removed from the list.
2. How do you choose an ELD system from an incomplete list?
At time of writing, the list only contains three providers claiming to meet the ELD standard. Rather than waiting for more to appear, carriers should become familiar with requirements of the rule and be prepared to ask lots of questions about systems that fit your needs and budget.
Because existing AOBRDs that carriers install before December 16, 2017, are grandfathered (meaning they don’t need to comply with the ELD standard until December 16, 2019), AOBRDs may be a viable early-adoption strategy for carriers still using paper logs. AOBRD system providers have more time to ensure their products comply with the ELD standard and to register them with FMCSA, but carriers that invest in AOBRDs now still meet the initial December 16, 2017, ELD compliance deadline. Ideally, the AOBRD supplier will also be working on a solution for their products for compliance in 2019. This is where it pays to understand:
the broad requirements of the rule and ask how the system will meet them over time;
what steps the provider is taking to register the product with FMCSA and self-certify; and
the expected timeline for doing so.
Carriers that already use AOBRDs should be asking these questions as well.
Taking the step to adopting an electronic system now allows your drivers and other staff to become familiar with a major change in process over a longer period, including in terms of enforcement.
In addition, it pays to be wary: FMCSA (aka the US Department of Transportation) will not certify ELDs and systems – manufacturers that claim to be certified should be speaking only in terms of self-certification and be ready to share any documentation or information used in the certification process, to show how their technology is compliant. “USDOT-approved” systems won’t exist.
3. Minimum ELD requirements
At a minimum, the standards require ELDs to be integrally synchronized with the commercial vehicle engine to automatically record the following data elements at certain intervals:
vehicle miles; and
identification information for the driver, the authenticated user, the vehicle, and the motor carrier.
The driver must be able to log in and select a duty status as required: On-duty, Off-duty, or On-Duty Not Driving. The device should also allow the driver to easily see hours in the record of duty status.
For roadside inspections, ELDs must also provide data in a way that’s standardized, via one of two options for electronic data transfer:
A telematics option, via wireless Web services and e-mail; or
A local transfer option, via USB2.0 and Bluetooth (both are necessary in case an officer has one or the other)
Each option must also allow the driver to provide either the display (by handing the device to an officer from the cab) or a print-out when an authorized safety official requests a physical display of the information.
The ELD rule does not require devices to have any back office functionality or to otherwise integrate with a fleet management system. They do not need to provide communications between the driver and the motor carrier.
Carriers that already use AOBRDs may just need an upgrade to that system for compliance in December 2019, but those using electronic logging software that doesn’t synchronize with the engine, including tablet or phone-based e-logs, will need to look at investing in AOBRDs or ELDs.
FMCSA noted the annualized cost for a wireless ELD system is about $419 vs. the annualized cost of a local transfer system at $166 in the US. The cost also varies depending on what the system does, the size of fleet, and how it integrates with existing systems and so on. Each commercial vehicle will require an ELD (drivers will have a unique login identifier so are not tied to a specific device).
4. Other considerations
In planning for the transition to ELDs, carriers should think about future needs and long-term use of the system to avoid buying twice in a short period.
The functionality of telematics vs. local transfer methods is worth investigating in addition to price; Bluetooth technology reportedly has a limited range (about 30 feet – which isn’t far considering a patrol car could park behind a 52-foot trailer).
Consider interoperability of systems if working with owner-operators or thinking about acquisitions in future. Owner-operators using different systems could require work on a back office system to allow integration. Owner-operators required to use a specific system may object.
Ask about repair and maintenance services provided by the vendor as well.
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