Motor carriers that still use paper logs will have the most work to do to meet the requirements of the US Electronic Logging Devices and Hours of Service Supporting Documents final rule by the December 2017 deadline, but indications are the transition won’t necessarily mean an exodus of drivers hanging up their keys.
Nevertheless, there are a number of shifts that will need to take place, not only for operations new to electronic logs but for those already using them and adjusting to changes required by the new rule. One shift is the idea that the driver “owns” the data; only the driver can make changes to an electronic log (and those changes are annotations to the data, rather than actual changes; no one change the original record). As well, dispatchers will need to manage loads and drivers more precisely, but depending on the ELD system (and whether it’s integrated with the back end), will also have better, real-time data to work with.
Because ELD systems that meet all the new requirements are still under development, no one can yet provide commentary based on experience with completely compliant technology. However, carriers with experience in using automatic onboard recording devices or another type of electronic logging have useful comments to share about the transition that may help with planning. Generally, users emphasize the need for training, not just for drivers but for other employees like dispatchers and safety and fleet managers, who will access or use the ELD data for decision making as well (in making the decision to purchase ELD systems, carriers should also consider the type of training support provided by the supplier).
During an ELD panel session BCTA hosted on April 6, 2016, carriers using AOBRDs shared their experience in transitioning to this technology with the audience. We’ve summarized the information they shared below, along with other details from recent coverage on similar events and interviews in the trade media (links to related articles follow under Resources).
Tips for the transition
Start the transition with hands-on training for a small group of your best drivers, who will act as advocates for the new technology, followed by the middle of the pack, then the drivers who are most resistant to the change. Some carriers also offer an ELD bonus.
Based on the experience of the two carriers represented on BCTA’s panel, once the best drivers buy in, the process of converting the remaining drivers is much easier. Carriers who’ve made the transition say that once drivers use ELDs, they don't want to go back to paper logs.
Some carriers have their drivers use the new technology alongside paper logs for the first month, to ease the transition.
Keeping details on any positive impacts to driver pay and productivity may also help convince drivers to accept the change more willingly.
Training for drivers should cover how to produce the ELD for inspections, including transferring data to officers (via e-mail, USB or Bluetooth transfer, depending on the system), providing printed copies, or handing the device over, if possible. Since enforcement officers are also still learning the technology, making sure drivers know what to do to ease the inspection will make things go more smoothly (until the technology becomes commonplace, inspectors may still prefer to see HOS data on a print out or screen).
Educating drivers is only part of the work; carriers also have to educate dispatchers, sales people, and their customers.
Training back office staff usually requires having some driver data for them to review, so starting with a small group of drivers can help provide a manageable amount of data to start. Staff will need to know how to deal with alerts when a driver goes over his or her hours, annotations to account for unassigned miles and time, and so on.
Some carriers appoint a compliance officer for ELD data, someone who is detail oriented, has a sound knowledge of HOS rules, some technical knowledge, and can be trusted to take ownership of monitoring, annotating, and maintaining the data generated by the system, trouble-shooting non-compliance issues, and taking the necessary follow-up/corrective action.
ELDs will also require a contingency plan if the system is down, and training should include putting this plan into practice (drivers need to keep a paper log in their vehicles for backup).
Some practical considerations ELD changes
There are two new, non-mandatory duty statuses: “yard moves” and “personal conveyance.” Since ELDs will be integrated with the vehicle engine, carriers will need to consider having separate accounts for the device for anyone other than the driver (e.g., a mechanic) who needs to move the vehicle, to avoid adding to the driver’s HOS. The personal conveyance status allows drivers to operate the vehicle for authorized personal use while still tracking HOS compliance (but with position accuracy limited to a 10-mile radius, for privacy).
According to the rule, driving time (the beginning of the trip) starts as soon as the vehicle is going faster than 5 mph, which is when the ELD must automatically start to record data.
Some drivers have expressed concern that ELDs provide no way to deal with delays at the border or through other events, including inclement weather. Although carriers will need to consider how to deal with more precise tracking of drivers running out of hours, the ELD does not in any way change current HOS rules, which still provide some provisions for extra driving time.
Drivers will need to enter data about the duty status when the vehicle is stopped or parked, and ELDs will provide the same duty status options as for paper logs. Depending on the ELD system/vendor, there may also be the opportunity for supervisors acting as administrators to enter “on duty, not driving” status, as required. In the US, for example, drivers who work for multiple employers (for jobs other than driving) must still note all paid hours (ODND) via an ELD. (In Canada, drivers need only record time working for a carrier for HOS compliance.)
These tips and considerations serve as a starting point for planning. One other factor to consider in adopting ELDs as soon as possible is that as the initial December 2017 compliance deadline approaches, more carriers will be purchasing individual ELD devices and systems, making ELD suppliers and their technical and training support systems potentially very busy.
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