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The ABC’s of the Looming ELD Mandate
Part 1
March 3rd, 2016
Christopher P. Nelson, Vice President
Who Is ISE?
Solutions:
Vehicle Telematics
Big Data
Engineering Process
Mobile App Dev
Value:
Trusted partner
Tailored solutions
Experience and process
Professional Services eFleetSuite Product
Offerings:
Licensed compliance
software
Tailored Integrations
Value:
Extensive domain experience
Speed to market
Integration flexibility
Apps:
HOS, DVIR, Fuel Tax
Vehicle & driver location
Value:
Low cost
Easy to install
Easy to use
Compliance focused
ISE Fleet Services
eFleetSuite Software Platform
Tailoring
Licenses Integrations In-Cab Product
ELD Perspective
500+ Page Document
Carrier/Supplier Perspective
 ATA – TMC ELD Task Force
Enforcement Perspective
 Commercial Vehicle Safety Alliance – ELD Final Rule Ad-Hoc Work Group
FMCSA Perspective
 https://www.fmcsa.dot.gov/hours-service/elds/electronic-logging-devices
ELD Mandate – What does it address?
• Requires ELD use by commercial drivers who are required to prepare hours-of-service (HOS)
records of duty status (RODS).
• Sets ELD performance and design standards, and requires ELDs to be certified and registered
with FMCSA.
• Establishes what supporting documents drivers and carriers are required to keep.
• Prohibits harassment of drivers based on ELD data or connected technology (such as fleet
management system). The rule also provides recourse for drivers who believe they have been
harassed.
ELD – Who must use them?
Who must use an electronic logging device (ELD)?
The ELD rule applies to motor carriers and drivers who are currently required to keep records of duty service (RODS)
on paper or with an Automatic Onboard Recording Device (AOBRD) under the hours-of-service (HOS) regulations.
The following drivers may keep paper RODS:
• Drivers who keep RODS no more than 8 days during any 30-day period.
• Driveaway-towaway drivers (transporting a vehicle for sale, lease, or repair), provided the vehicle driven is part
of the shipment.
• Drivers of vehicles manufactured before model year 2000.
*Drivers who use the timecard exception, and don’t keep paper RODs, will not be required to use ELDs.
However, a carrier can choose to use an ELD, even if it is not required.
ELD - Timeline
February 16th, 2016
Effective Date
December 18th, 2017
Compliance Date
December 16th, 2019
Full Compliance
Phase 1: Awareness and
Transition
Carriers and drivers subject to
the rule can use any of the
following for records of duty
status (RODS):
• Paper logs
• Logging software
• AOBRDS (Automatic On
Board Recording Devices)
• ELDs that are registered and
listed on the FMCSA website
Phase 2: Phased-In Compliance
Carriers and drivers subject to
the rule can use:
• AOBRDS that were installed
prior to December 18, 2017
• Certified, registered ELDs
following rule publication
December 16, 2015
Phase 3: Full Compliance
After December 16, 2019 all
drivers and carriers subject to
the rule must use certified,
registered ELDs that comply
with requirements of the ELD
regulations
December 18, 2015
Publication Date
ELD Changes – Display Requirements
• Additional Information
 Vehicle Vin
 Exempt Status
 ELD Malfunctions
 Etc.
• Yard Moves
• Personal Conveyance
 No line 5 specified
 Identify by color, dotted lines, dashed lines, etc.
ELD Changes – Transfer Method
Telematics Transfer Method
• Web Service
• Email SMTP
Local Transfer Method
• Bluetooth, Web Service, Local Network
• USB 2.0
• ELD Supplier must do both within one of the categories
• State Enforcement must pick one from each category
ELD - FAQs
Would a motor carrier be non-compliant with the ELD rule if the data cannot be sent electronically to an
authorized safety official at roadside?
FMCSA Response -
No, if electronic transfer is unavailable or not working, the driver can comply by showing the ELD display or a
printout of the RODS.
4.8.1.2. Display Requirements
(a) This section does not apply if an ELD produces a printout for use at a roadside inspection.
(b) An ELD must be designed so that its display may be reasonably viewed by an authorized safety official
without entering the commercial motor vehicle. For example, the display may be untethered from its mount or
connected in a manner that would allow it to be passed outside of the vehicle for a reasonable distance.
ELD - FAQs
In a scenario where there are two pieces of hardware making up an ELD system (i.e. ELD black box connected and
collecting engine data + separate ELD display); if the ELD display is NOT present or is NOT working (i.e. battery dead,
etc.) what is the FMCSA expectations/guidance regarding the below various indicator requirement(s)?
Does the absence of the ELD display, or the ELD display not working meet the below various visual indicator
requirements or will a stand-alone indicator separate of the ELD display be required?
FMCSA Response –
The missing or dead battery display would not meet the malfunction indicator requirement. If the display normally
darkens while in operation, the driver may not know for hours that the display is no longer communicating with the
“black box”. If the black box is the connected/collecting hardware, that should provide the prompt. The display is
only the driver interface.
https://www.fmcsa.dot.gov/hours-service/elds/faqs
ELD Implementation
• Prepare for initial challenges: There will be a couple of challenging aspects to ELD adoption.
• Ensure your fleet’s compliance: For those companies that do not have any technology in place
today, they might be unsure of how to navigate the vast number of technology options to choose
from. An important question to ask is whether or not the technology complies with what the
mandate requires.
• Go beyond the minimum: In addition to ensuring compliance, companies need to look at what
they want to get out of their technology.

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2016 STS - Chris Nelson: The ABC’s of the Looming ELD Mandate

  • 1. The ABC’s of the Looming ELD Mandate Part 1 March 3rd, 2016 Christopher P. Nelson, Vice President
  • 2. Who Is ISE? Solutions: Vehicle Telematics Big Data Engineering Process Mobile App Dev Value: Trusted partner Tailored solutions Experience and process Professional Services eFleetSuite Product Offerings: Licensed compliance software Tailored Integrations Value: Extensive domain experience Speed to market Integration flexibility Apps: HOS, DVIR, Fuel Tax Vehicle & driver location Value: Low cost Easy to install Easy to use Compliance focused ISE Fleet Services eFleetSuite Software Platform Tailoring Licenses Integrations In-Cab Product
  • 3. ELD Perspective 500+ Page Document Carrier/Supplier Perspective  ATA – TMC ELD Task Force Enforcement Perspective  Commercial Vehicle Safety Alliance – ELD Final Rule Ad-Hoc Work Group FMCSA Perspective  https://www.fmcsa.dot.gov/hours-service/elds/electronic-logging-devices
  • 4. ELD Mandate – What does it address? • Requires ELD use by commercial drivers who are required to prepare hours-of-service (HOS) records of duty status (RODS). • Sets ELD performance and design standards, and requires ELDs to be certified and registered with FMCSA. • Establishes what supporting documents drivers and carriers are required to keep. • Prohibits harassment of drivers based on ELD data or connected technology (such as fleet management system). The rule also provides recourse for drivers who believe they have been harassed.
  • 5. ELD – Who must use them? Who must use an electronic logging device (ELD)? The ELD rule applies to motor carriers and drivers who are currently required to keep records of duty service (RODS) on paper or with an Automatic Onboard Recording Device (AOBRD) under the hours-of-service (HOS) regulations. The following drivers may keep paper RODS: • Drivers who keep RODS no more than 8 days during any 30-day period. • Driveaway-towaway drivers (transporting a vehicle for sale, lease, or repair), provided the vehicle driven is part of the shipment. • Drivers of vehicles manufactured before model year 2000. *Drivers who use the timecard exception, and don’t keep paper RODs, will not be required to use ELDs. However, a carrier can choose to use an ELD, even if it is not required.
  • 6. ELD - Timeline February 16th, 2016 Effective Date December 18th, 2017 Compliance Date December 16th, 2019 Full Compliance Phase 1: Awareness and Transition Carriers and drivers subject to the rule can use any of the following for records of duty status (RODS): • Paper logs • Logging software • AOBRDS (Automatic On Board Recording Devices) • ELDs that are registered and listed on the FMCSA website Phase 2: Phased-In Compliance Carriers and drivers subject to the rule can use: • AOBRDS that were installed prior to December 18, 2017 • Certified, registered ELDs following rule publication December 16, 2015 Phase 3: Full Compliance After December 16, 2019 all drivers and carriers subject to the rule must use certified, registered ELDs that comply with requirements of the ELD regulations December 18, 2015 Publication Date
  • 7. ELD Changes – Display Requirements • Additional Information  Vehicle Vin  Exempt Status  ELD Malfunctions  Etc. • Yard Moves • Personal Conveyance  No line 5 specified  Identify by color, dotted lines, dashed lines, etc.
  • 8. ELD Changes – Transfer Method Telematics Transfer Method • Web Service • Email SMTP Local Transfer Method • Bluetooth, Web Service, Local Network • USB 2.0 • ELD Supplier must do both within one of the categories • State Enforcement must pick one from each category
  • 9. ELD - FAQs Would a motor carrier be non-compliant with the ELD rule if the data cannot be sent electronically to an authorized safety official at roadside? FMCSA Response - No, if electronic transfer is unavailable or not working, the driver can comply by showing the ELD display or a printout of the RODS. 4.8.1.2. Display Requirements (a) This section does not apply if an ELD produces a printout for use at a roadside inspection. (b) An ELD must be designed so that its display may be reasonably viewed by an authorized safety official without entering the commercial motor vehicle. For example, the display may be untethered from its mount or connected in a manner that would allow it to be passed outside of the vehicle for a reasonable distance.
  • 10. ELD - FAQs In a scenario where there are two pieces of hardware making up an ELD system (i.e. ELD black box connected and collecting engine data + separate ELD display); if the ELD display is NOT present or is NOT working (i.e. battery dead, etc.) what is the FMCSA expectations/guidance regarding the below various indicator requirement(s)? Does the absence of the ELD display, or the ELD display not working meet the below various visual indicator requirements or will a stand-alone indicator separate of the ELD display be required? FMCSA Response – The missing or dead battery display would not meet the malfunction indicator requirement. If the display normally darkens while in operation, the driver may not know for hours that the display is no longer communicating with the “black box”. If the black box is the connected/collecting hardware, that should provide the prompt. The display is only the driver interface. https://www.fmcsa.dot.gov/hours-service/elds/faqs
  • 11. ELD Implementation • Prepare for initial challenges: There will be a couple of challenging aspects to ELD adoption. • Ensure your fleet’s compliance: For those companies that do not have any technology in place today, they might be unsure of how to navigate the vast number of technology options to choose from. An important question to ask is whether or not the technology complies with what the mandate requires. • Go beyond the minimum: In addition to ensuring compliance, companies need to look at what they want to get out of their technology.

Editor's Notes

  1. The first will be to educate drivers on this new technology, since filling out paper logbooks is all that many drivers know. It is important for fleets to point out the benefits of these new devices to their drivers to help them understand that this mandate is aimed at making their jobs easier by saving them time, speeding up inspections and reducing accidents. Another challenge is the implementation of this new technology. Transitioning from manual to electronic logging systems means more than simply changing the hardware and software—the change will affect most aspects of the company, including the culture. For this reason, leadership must establish a clear vision and transparent implementation plan. Implementation is a total team effort. By making sure everyone involved knows why implementation is occurring as well as the benefits of adding ELDs, it will be easier to smoothly introduce the technology within a fleet. Fleets should actively review and familiarize themselves with the content included in the Electronic Logging Devices and Hours of Service Supporting Documents final rule. Per the rule, all suppliers will be required to certify their ELD devices.  These approved devices will then be available to the public on a FMCSA-managed website. Fleets need to ensure that the systems they chose to implement are listed on the ELD approved website. For those fleets using a current 395.15 certified AOBRD, it is important to keep in mind that they will have four years to comply with the ELD Mandate. It is crucial that they work with their suppliers to understand the migration path to ensure that they are utilizing compliant systems come December 2019. Some organizations, whether due to financial constraints or because they want a quick fix, will only aim to meet the minimum requirements to become compliant. By just reaching the minimum, fleets are missing out on the numerous benefits of going beyond and implementing a more scalable ELD. By selecting a more comprehensive technology solution, you can address a wider scope of issues beyond compliance to improve safety and efficiency. An scalable ELD solution can help a fleet meet a broader range of goals through capabilities like speed monitoring, IFTA reporting and analytics reports, just to name a few. This is an opportunity to not only become compliant, but to also improve how a company does business and generate a greater return on investment. By keeping these things in mind, you should feel confident in making a decision on ELDs. At ISE, we have seen our customers experience the difference ELDs make, not only in achieving compliance but in improving safety.