ELDs: An Overview
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ELD Mandate: A review of the technical specifications and operational considerations. Part of the eMaint "Best Practices" series.
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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
- 4. The Background of Electronic Logs
- 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
- 9. The New ELD Rule
- 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.
- 12. Rule Timeline Rule Published Year 2 All Paper-Log Drivers Comply Year 4 All AOBRD Drivers Comply
- 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
- 19. Technical Requirements Connected to ECM 1. Engine Power Status 2. Distance 3. Motion Status 4. Engine Hours
- 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
- 22. Technical Requirements Onboard Communicating to Enforcement Upon demand - at least two of: 1. USB 2. Web Services 3. Blue Tooth 4. Email 5. Printout
- 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
- 30. Audits
- 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
- 34. Questions? Joel Beal Managing Partner & COO, JBA Telematics JoelBeal@JBATelematics.com www.JBATelematics.com
Editor's Notes
- 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