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Electronic Logging Device (ELD) Final
Rule Overview
Fred Fakkema – Vice President of Compliance
Summary of Final Rule
Final Rule was published to Federal Register on December 16, 2015
Rule addresses
• ELD Use
• ELD Technical Standards
• Retention of Supporting Documents
Carrier is responsible for ensuring ELD has been registered with FMCSA
2015 20192015 2016 2017 2018 2019
ELD Final
Rule
Published
All CMV's must have either an AOBRD or
ELD installed
12/18/2017
All devices
must be ELD
compliant
12/16/2019
2 YearsAOBRD or ELD Device may be installed
2 YearsOnly ELD devices may be installed
2 YearsContinue to use AOBRD devices installed
ELD TIMELINE
12/16/2017
Comparison of Technical ELD Specifications
Feature/Function 1988 AOBRD Rule 2015 ELD Final Rule
Integral Synchronization Integral synchronization required, but term
not defined in the FMCSRs.
Integral synchronization interfacing with the CMV engine ECM to automatically
capture engine power status, vehicle motion status, miles driven, engine hours.
* (CMVs older than model year 2000 exempted)
Recording Location
Information
Required at each change-of-duty status.
Manual or automated.
Require automated entry at each change-of-duty status at 60-minute intervals
while CMV is in motion, at engine-on and engine-off instances, and at beginning
and end of personal use and yard moves.
Graph Grid Display Not required – “time and sequence of duty
status changes.”
ELD must be able to present a graph grid of driver’s daily duty status changes
either on a display or on a printout.
HOS Driver Advisory
Messages
Not addressed. HOS limits notification NOT required.
“Unassigned driving time/miles” warning provided upon login.
Device “Default”
Duty Status
Not addressed. On-duty not driving, when CMV has not been in motion for 5 consecutive minutes,
and driver has not responded to an ELD prompt within 1 minute.
No other nondriver-initiated status change is allowed.
Feature/Function 1988 AOBRD Rule 2015 ELD Final Rule
Clock-time Drift Not addressed. ELD time must be synchronized to UTC, and absolute deviation must not exceed 10
minutes at any point in time.
Communications
Methods
Not addressed – focused on interface between
AOBRD support systems and printers.
Two Options:
1. “Telematics”: At minimum, ELD must transfer data via both wireless Web
services AND wireless email.
2. “Local Transfer”: At minimum, the ELD must transfer data via both USB
2.0 AND Bluetooth.
Both types of ELDs must be capable of displaying a standardized ELD data set to
authorized safety officials via display or printout.
Resistance to
Tampering
AOBRD and support systems must be, to the
maximum extent practical, tamperproof.
ELD must not permit alteration or erasure of the original information collected
concerning the driver’s ELD records or alteration of the source data streams used
to provide that information.
ELD must support data integrity check functions.
Identification of Sensor Failures
and Edited Data
Must identify sensor failures and edited data. ELD must have the capability to monitor its compliance (engine connectivity,
timing, positioning, etc.) for detectable malfunctions and data inconsistencies.
ELD must record these occurrences.
Comparison of Technical ELD Specifications
Exemptions from the Rule
Drivers who conduct driveaway-towaway operations, where the vehicle is the product being delivered
Drivers of vehicles manufactured before model year 2000 (due to vehicle connectivity concerns; this is a change from the
proposed rule)
Short-Haul Drivers are generally exempt
• Includes both large CMV and smaller CMV drivers that currently use the “time card” exception
• Exclusions to the exemption:
― May only use paper logs up to eight days in any 30-day period when the air-mile exemption is exceeded
― Any driver that exceed the air-mile radius exemption more than eight days in a 30-day period must then
have an ELD installed on the CMV
ELD Device Certification
Federal Register for ELD Registration (April 2015)
• Register Online
• Online Certification
• Manufacturers are required to test and certify to FMCSA that their devices meet the new standards
• FMCSA will create a public (i.e., Internet) registry of compliant devices and conduct tests to verify manufacturers’ claims
• Carriers may only use ELD devices from a manufacturer that has registered and “self-certified” with the FMCSA and is listed
on the FMCSA website
ELD Device Design
• Display size not specified
• Portable ELDs must be mounted during operation of CMV
• Display must be available to enforcement outside of the cab of the truck
• System must have an option for mute or volume control when the driver is in sleeper berth
Security and Tampering Resistant
ELD must provide secure access to data recorded and stored on the system
• Require user authentication during login
• Data must be encrypted to ensure security when transferred to safety officials
Driver accounts only have access to data associated with specified driver
• Protects authenticity and confidentiality of the collected information
• Support employees must have own account
ELD must not allow any individual to tamper with the data
• Incorrect date, time, and location changes to on-duty driving status
• Alter a record created by that ELD
ELD Display Requirements
Identical to current requirements AND
• Driver’s First and Last Name
• ELD Username
• Total Engine Hours
• Miles for Each Driving Period
• ELD Malfunction Status
• Data Diagnostic Status Indicator for the Authenticated Driver
ELD Technical Requirements
Events record these data elements:
• Date and Time
• Location
― One mile while on duty
― 10 miles during personal use
• Engine Hours and Vehicle Mileage
• Driver Login
• Vehicle Identification
• Authorized Carrier Identification
• Engine Hours, Speed, and Distance
Events are recorded:
• At startup and shutdown
• Change of Duty Status
• Once per hour while the vehicle is
operating
• At the start and end of Personal Use or
Yard Time
ELD Account Creation
• Unique identifier and Driver’s License
number
• Drivers must not have administrative rights
• Support and Administrative employees must
have own account
• Owner-Operator – will have two accounts:
driver account and administrative account
Unidentified Driving & Special Driving Conditions
• ELD must include unassigned driver account
• All unassigned driver time must be assigned OR accounted for on the system and displayed
• Personal Conveyance
– Not Limited
– Recorded as Off-Duty
• Yard Moves
– Recorded as On-Duty not Driving
– Use as Carrier Determines
ELD Driver Interaction
Driver prompted for entry if one of the following occurs:
– If the vehicle is in motion with no driver logged in
– Duty status change if stopped for five minutes or longer (system default is to go into On Duty)
– Location if there is no GPS signal at the time of duty change
Driver prompted only when vehicle is stopped
Driver does NOT have to be prompted when approaching HOS limits
Automatic Duty Status Change
Change to Drive Duty Status when motion is detected
Require an alert if the vehicle stops moving after five minutes;
prompt driver, if no response within one minute change to On
Duty Status
Other automatic duty-status actions are prohibited
Driver Edit & Log Approval
• Driver can edit log, except Drive line
• All edits require a comment in order to accept the
changes made
• Back office changes must be approved/accepted
by the driver
• Original Records must be preserved
• Driver MUST be able to get copies of all records
for the past six months from the carrier or system
Roadside Data Transfer Process
• One step process for data transfer
• The ELD must now support ONE of two options for electronic data transfer. At a minimum, it must electronically transfer data
to an authorized safety official on demand via…..
• Telematics – via wireless Web services and email
• Local transfer – via USB2.0 and Bluetooth
• Both types must be capable of displaying a standardized ELD data set in the format specified in this rule to an authorized
safety official on demand, the authorized official selects method of transfer
• Backup requirements:
– Drivers must be able to show a roadside inspection officer a graph-grid of his/her hours of service compliance, either on
the ELD’s display or on a hardcopy paper printout.
– The display must be visible to the officer without entering the vehicle, such as handing the display to the officer.
5 Categories of Supporting Documents
• Origin and Destination (BOLs)
• Dispatch and Trip Reports
• Expense Receipts
• Mobile Communication
• Payroll
Supporting Documents
Required Data Elements
– Driver Name
– Date
– Time
– Location
• Max of eight records in a 24-hour period
• Drivers must submit within eight days
• Drivers must produce at roadside (those that are in possession)
• Must retain information so that it matches the log
• Carrier must keep minimum of eight supporting documents per
driver per day if they have them
• If the carrier does not have eight supporting documents with all the
elements, they must keep those that have all elements except “time”
ELD Implementation – Guide to Enforcement
Publication Date
The date the rule was published in the Federal Register
December 16, 2015
Effective Date
The date the rule goes into effect; 60 days after the publication date.
Enforcement Phase 1 begins
February 16, 2016
Compliance Date
The date that all carriers must be compliant with the rule; two years
from the publication date; CMVs must have AOBRD or ELD
installed.
Enforcement Phase 2 begins
December 18, 2017
Full Compliance Date
CMVs must have ELD installed
Enforcement Phase 3 begins
December 18, 2019
Phase 1
• Awareness and Transition Phase: The two-year period following publication of the ELD rule February
16, 2016 to December 18, 2017.
• During this time, carriers and drivers subject to the rule should prepare to comply, and may voluntarily use
ELDs.
• 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
• Logging software roadside requirements for LE:
– Display and printout required per inspector’s request. Graph grid required.
• ELD Roadside requirements for LE:
– Display or printout required, per driver’s choice. Graph grid required.
– (Optional: Fax or email may be provided.)
• AOBRD Roadside requirement for LE:
– Display required. Allowed to have chart, electronic display, or printout.
– (Optional: Fax or email may be provided.)
Phase 2 and 3
• Phase 2: Phased-In Compliance Phase: The two-year period from the Compliance Date to the
Full Compliance Phase (four years following ELD rule publication) December 18, 2017 to
December 16, 2019.
• 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.
During this second phase, information technology software tools will be available to securely
transmit ELD record of duty status (RODS) information to FMCSA officials and law
enforcement for enforcement and compliance purposes. The rule’s new supporting document
requirements for drivers and motor carriers using either device will also begin during this
phase, on the rule’s compliance date.
• Phase 3 - Full Compliance Phase:
– 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.
The ELD Puzzle – Compliance Components
Unidentified
Driving
Auto Status
Changes
Personal
Conveyance
Editing Logs
Driver’s
User Accounts
Diagnostics
Authentication
Yard Moves
Geo-Location
Roadside
Process
Data Transfer
Output File
Registration
Engine SyncEvents
Certification
Display
Questions?

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Eld final rule overview

  • 1. Electronic Logging Device (ELD) Final Rule Overview Fred Fakkema – Vice President of Compliance
  • 2. Summary of Final Rule Final Rule was published to Federal Register on December 16, 2015 Rule addresses • ELD Use • ELD Technical Standards • Retention of Supporting Documents Carrier is responsible for ensuring ELD has been registered with FMCSA
  • 3. 2015 20192015 2016 2017 2018 2019 ELD Final Rule Published All CMV's must have either an AOBRD or ELD installed 12/18/2017 All devices must be ELD compliant 12/16/2019 2 YearsAOBRD or ELD Device may be installed 2 YearsOnly ELD devices may be installed 2 YearsContinue to use AOBRD devices installed ELD TIMELINE 12/16/2017
  • 4. Comparison of Technical ELD Specifications Feature/Function 1988 AOBRD Rule 2015 ELD Final Rule Integral Synchronization Integral synchronization required, but term not defined in the FMCSRs. Integral synchronization interfacing with the CMV engine ECM to automatically capture engine power status, vehicle motion status, miles driven, engine hours. * (CMVs older than model year 2000 exempted) Recording Location Information Required at each change-of-duty status. Manual or automated. Require automated entry at each change-of-duty status at 60-minute intervals while CMV is in motion, at engine-on and engine-off instances, and at beginning and end of personal use and yard moves. Graph Grid Display Not required – “time and sequence of duty status changes.” ELD must be able to present a graph grid of driver’s daily duty status changes either on a display or on a printout. HOS Driver Advisory Messages Not addressed. HOS limits notification NOT required. “Unassigned driving time/miles” warning provided upon login. Device “Default” Duty Status Not addressed. On-duty not driving, when CMV has not been in motion for 5 consecutive minutes, and driver has not responded to an ELD prompt within 1 minute. No other nondriver-initiated status change is allowed.
  • 5. Feature/Function 1988 AOBRD Rule 2015 ELD Final Rule Clock-time Drift Not addressed. ELD time must be synchronized to UTC, and absolute deviation must not exceed 10 minutes at any point in time. Communications Methods Not addressed – focused on interface between AOBRD support systems and printers. Two Options: 1. “Telematics”: At minimum, ELD must transfer data via both wireless Web services AND wireless email. 2. “Local Transfer”: At minimum, the ELD must transfer data via both USB 2.0 AND Bluetooth. Both types of ELDs must be capable of displaying a standardized ELD data set to authorized safety officials via display or printout. Resistance to Tampering AOBRD and support systems must be, to the maximum extent practical, tamperproof. ELD must not permit alteration or erasure of the original information collected concerning the driver’s ELD records or alteration of the source data streams used to provide that information. ELD must support data integrity check functions. Identification of Sensor Failures and Edited Data Must identify sensor failures and edited data. ELD must have the capability to monitor its compliance (engine connectivity, timing, positioning, etc.) for detectable malfunctions and data inconsistencies. ELD must record these occurrences. Comparison of Technical ELD Specifications
  • 6. Exemptions from the Rule Drivers who conduct driveaway-towaway operations, where the vehicle is the product being delivered Drivers of vehicles manufactured before model year 2000 (due to vehicle connectivity concerns; this is a change from the proposed rule) Short-Haul Drivers are generally exempt • Includes both large CMV and smaller CMV drivers that currently use the “time card” exception • Exclusions to the exemption: ― May only use paper logs up to eight days in any 30-day period when the air-mile exemption is exceeded ― Any driver that exceed the air-mile radius exemption more than eight days in a 30-day period must then have an ELD installed on the CMV
  • 7. ELD Device Certification Federal Register for ELD Registration (April 2015) • Register Online • Online Certification • Manufacturers are required to test and certify to FMCSA that their devices meet the new standards • FMCSA will create a public (i.e., Internet) registry of compliant devices and conduct tests to verify manufacturers’ claims • Carriers may only use ELD devices from a manufacturer that has registered and “self-certified” with the FMCSA and is listed on the FMCSA website
  • 8. ELD Device Design • Display size not specified • Portable ELDs must be mounted during operation of CMV • Display must be available to enforcement outside of the cab of the truck • System must have an option for mute or volume control when the driver is in sleeper berth
  • 9. Security and Tampering Resistant ELD must provide secure access to data recorded and stored on the system • Require user authentication during login • Data must be encrypted to ensure security when transferred to safety officials Driver accounts only have access to data associated with specified driver • Protects authenticity and confidentiality of the collected information • Support employees must have own account ELD must not allow any individual to tamper with the data • Incorrect date, time, and location changes to on-duty driving status • Alter a record created by that ELD
  • 10. ELD Display Requirements Identical to current requirements AND • Driver’s First and Last Name • ELD Username • Total Engine Hours • Miles for Each Driving Period • ELD Malfunction Status • Data Diagnostic Status Indicator for the Authenticated Driver
  • 11. ELD Technical Requirements Events record these data elements: • Date and Time • Location ― One mile while on duty ― 10 miles during personal use • Engine Hours and Vehicle Mileage • Driver Login • Vehicle Identification • Authorized Carrier Identification • Engine Hours, Speed, and Distance Events are recorded: • At startup and shutdown • Change of Duty Status • Once per hour while the vehicle is operating • At the start and end of Personal Use or Yard Time
  • 12. ELD Account Creation • Unique identifier and Driver’s License number • Drivers must not have administrative rights • Support and Administrative employees must have own account • Owner-Operator – will have two accounts: driver account and administrative account
  • 13. Unidentified Driving & Special Driving Conditions • ELD must include unassigned driver account • All unassigned driver time must be assigned OR accounted for on the system and displayed • Personal Conveyance – Not Limited – Recorded as Off-Duty • Yard Moves – Recorded as On-Duty not Driving – Use as Carrier Determines
  • 14. ELD Driver Interaction Driver prompted for entry if one of the following occurs: – If the vehicle is in motion with no driver logged in – Duty status change if stopped for five minutes or longer (system default is to go into On Duty) – Location if there is no GPS signal at the time of duty change Driver prompted only when vehicle is stopped Driver does NOT have to be prompted when approaching HOS limits
  • 15. Automatic Duty Status Change Change to Drive Duty Status when motion is detected Require an alert if the vehicle stops moving after five minutes; prompt driver, if no response within one minute change to On Duty Status Other automatic duty-status actions are prohibited
  • 16. Driver Edit & Log Approval • Driver can edit log, except Drive line • All edits require a comment in order to accept the changes made • Back office changes must be approved/accepted by the driver • Original Records must be preserved • Driver MUST be able to get copies of all records for the past six months from the carrier or system
  • 17. Roadside Data Transfer Process • One step process for data transfer • The ELD must now support ONE of two options for electronic data transfer. At a minimum, it must electronically transfer data to an authorized safety official on demand via….. • Telematics – via wireless Web services and email • Local transfer – via USB2.0 and Bluetooth • Both types must be capable of displaying a standardized ELD data set in the format specified in this rule to an authorized safety official on demand, the authorized official selects method of transfer • Backup requirements: – Drivers must be able to show a roadside inspection officer a graph-grid of his/her hours of service compliance, either on the ELD’s display or on a hardcopy paper printout. – The display must be visible to the officer without entering the vehicle, such as handing the display to the officer.
  • 18. 5 Categories of Supporting Documents • Origin and Destination (BOLs) • Dispatch and Trip Reports • Expense Receipts • Mobile Communication • Payroll
  • 19. Supporting Documents Required Data Elements – Driver Name – Date – Time – Location • Max of eight records in a 24-hour period • Drivers must submit within eight days • Drivers must produce at roadside (those that are in possession) • Must retain information so that it matches the log • Carrier must keep minimum of eight supporting documents per driver per day if they have them • If the carrier does not have eight supporting documents with all the elements, they must keep those that have all elements except “time”
  • 20. ELD Implementation – Guide to Enforcement Publication Date The date the rule was published in the Federal Register December 16, 2015 Effective Date The date the rule goes into effect; 60 days after the publication date. Enforcement Phase 1 begins February 16, 2016 Compliance Date The date that all carriers must be compliant with the rule; two years from the publication date; CMVs must have AOBRD or ELD installed. Enforcement Phase 2 begins December 18, 2017 Full Compliance Date CMVs must have ELD installed Enforcement Phase 3 begins December 18, 2019
  • 21. Phase 1 • Awareness and Transition Phase: The two-year period following publication of the ELD rule February 16, 2016 to December 18, 2017. • During this time, carriers and drivers subject to the rule should prepare to comply, and may voluntarily use ELDs. • 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 • Logging software roadside requirements for LE: – Display and printout required per inspector’s request. Graph grid required. • ELD Roadside requirements for LE: – Display or printout required, per driver’s choice. Graph grid required. – (Optional: Fax or email may be provided.) • AOBRD Roadside requirement for LE: – Display required. Allowed to have chart, electronic display, or printout. – (Optional: Fax or email may be provided.)
  • 22. Phase 2 and 3 • Phase 2: Phased-In Compliance Phase: The two-year period from the Compliance Date to the Full Compliance Phase (four years following ELD rule publication) December 18, 2017 to December 16, 2019. • 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. During this second phase, information technology software tools will be available to securely transmit ELD record of duty status (RODS) information to FMCSA officials and law enforcement for enforcement and compliance purposes. The rule’s new supporting document requirements for drivers and motor carriers using either device will also begin during this phase, on the rule’s compliance date. • Phase 3 - Full Compliance Phase: – 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.
  • 23. The ELD Puzzle – Compliance Components Unidentified Driving Auto Status Changes Personal Conveyance Editing Logs Driver’s User Accounts Diagnostics Authentication Yard Moves Geo-Location Roadside Process Data Transfer Output File Registration Engine SyncEvents Certification Display