Generative Artificial Intelligence: How generative AI works.pdf
ELDs: An Overview
1. United States Electronic
Logging Device Mandate
Presented By: Joel Beal
Managing Partner & COO, JBA Telematics
eMaint Best Practices Webinar • March 2016
2. 1. Brief Background of Electronic Logging Devices
2. The New ELD rule
3. Technical Requirements
4. The Certification Process for ELD Vendors
5. What to Expect During an Audit
The Electronic Logging Device Mandate
3. Poll Question #1
How familiar are you with the Electronic Device
Mandate?
1) Not familiar at all
2) Somewhat familiar
3) Very familiar, I work with ELDs everyday
5. The Background
It 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.
6. The Background
It 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
7. 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
8. Why Require ELDs?
• FMCSA estimates annually:
– Avoid 1844 crashes
– Prevent 562 injuries
– Save 26 lives
• Improve HOS compliance
• Automate, to some extent, compliance audits
10. And the Rule Is?
• SNPRN published February 2014
• Rule published December 16 2015
• Four areas covered in SNPRN;
1. Minimal technical standards for ELDs
2. Directs all drivers who use logs to begin using an
ELD
3. Establishes exact requirements for Supporting
Documents
4. Prohibits driver harassment. Establishes a driver
complaint process, and a carrier due process.
11. 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.
13. What is an ELD?
Take an existing device that automates HOS
logging – modernizes the rule and mandates use
Captures all CMV Movement
Does not allow deletion of driving time
Does not capture all drivers’ time – thus the need
for supporting documentation
Tamperproof
Give drivers more control of their logs than the
current AOBRD rule
14. 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
15. 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
16. What is a supporting document?
• BOL
• Dispatch and Trip Reports
• Expense Receipts
• Mobile Communications
• Payroll
17. What does a supporting document contain?
• Driver name
• Date
• Time
• Location
20. Technical Requirements
GPS Location Recording
1. Every 60 minutes
2. At engine on/off
3. At beginning/end of yard moves
4. At beginning/end of personal use
5. Location accuracy decreases when
used for personal conveyance or off
duty.
21. Technical Requirements
In the Cab
1. Graph/Grid Display or Printout
2. Information must be accessed
outside of cab.
3. Driver Name and ELD user name
4. Carrier name/address
5. Engine hours and distance for
each driving period
6. Malfunction and diagnostic status
7. Unassigned driver miles/time
warning
8. 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
23. Technical Requirements
Log Edits
1. Drive time cannot be edited
2. Driver edits, office approves
3. Office edits, driver approves
4. All edits are tracked and original
record retained
24. Technical Requirements
Tamper Resistance
1. Self-diagnostics and reporting via
flat file
2. Reasonably resistant to
tampering
3. Original data must be unalterable
and not erasable
25. 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
26. 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
28. 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?
29. 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
31. Roadside Inspections
1. Is the ELD device compliant?
Decal
Drivers Handbook
2. Show me your logs…
Electronic transfer of logs to ASPEN system
Print out of logs
Email logs
3. Paper logs accepted if;
Casual driver
Rental truck
Device failure
32. Office Inspections
1. Same conditions will trigger an audit
2. Logs may be viewed or printed
3. May ask to see original logs where edits are
made
4. Supporting documents required
5. Six previous months plus current month in
the office
6. 13 days to get logs from truck to office
7. 7 previous days plus current day on the road
33. Why Adopt Now?
1. It’s Not the Good Old Days
2. 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
Supporting documents include scale tickets, fuel and toll receipts, motel records, dispatch records, bills of lading. Purpose; validate time and location as entered on drivers’ logs.
What is an NPRM? It is a checks and balances system where an agency proposes a regulation. It is posted for comments, The White House Office of Management and Budget reviews and revises, then it’s sent to the agency for publication.
Decision to vacate by a Federal Court of Appeals based on a law suit by the owner Operator Independent Drivers Association (OOIDA) over driver harassment.
The Truck and Bus Regulatory Reform Act of 1988 requires that any electronic monitoring devices are not used to harass drivers.
The court found that the FMCSA did not address these concerns as directed by Congress in 1988.
Therefore, the NPRM could not rely on the 2010 technical specifications that was jointly produced by carriers, technology suppliers, and the Agency.
Supporting documents requirements are new and different – and are meant to validate non-driving time.
Rule effective immediately upon publication
Paper log drivers have 2 years compliance period
AOBRD drivers have 4 years compliance period
Driver by driver, vehicle by vehicle enforcement. Not carrier-wide.
Drivers must certify their logs – including when an edit is made. Harassment is meant to include unwarranted log edits, disturbing drivers’ sleep, activity monitoring when in an off duty status.
Timecard drivers: 100 air miles CMVs, 150 air miles smaller vehicles
Sorted by driver by day, so they match the driver’s log.
Connected to ECM – more reliable than GPS-derived distance.
How is GPS distance calculated? Point by point – breadcrumb resolution discrepancy
GPS reliability depends on physical environment
Urban canyons
Canyons and valleys
Heavy foliage
Less prone to tampering and failure than consumer grade devices
We expect no changes here
GPS
Location only
Not used for movement or distance
We expect no changes or minor changes to GPS accuracy when driver is not actively on duty.
No other status assumption is allowed other than ODND from DRV
We expect no changes here
We will see changes to the allowed or perhaps preferred method of onboard communications to enforcement.
We expect no changes here.
We expect no changes here.
What if driver refuses to certify edit? Nothing – it’s a marker for enforcement to ask questions.
Driver must have access to all 6 months’ logs – even if they leave a carrier.
FMCSA has contracted with ITSI, a Beltway contractor, to develop a checklist. ELD vendors will register on the portal and self-confirm against the checklist.
First FMCSA test procedures webinar had a lot of discussion about obviously non-compliant devices already listed as certified