Are you Ready for Electronic Logs?
In March, 2014, the Federal Motor Carrier Safety Administration proposed an electronic logging device mandate (ELD) to replace its 395.15 rule for voluntary use of Automatic Onboard Recording Devices (AOBRDs).
After reading the proposal, technology suppliers estimated they would need 12 months or more to update their products to ELDs once the final rule was published.
The date came on December 16, 2015. Suppliers are now gearing up to roll out ELDs before the December 2017 enforcement deadline. There is no need to panic, however. Fleets that purchase AOBRD technology by Dec. 2017 will have until Dec. 2019 to convert to ELD technology.
Most AOBRD products in the market today will be transformed to ELDs with over-the-air software updates. When suppliers begin to release new ELD versions, possibly later this year, AOBRDs will not be going away. Some may still be in the market in 2019.
A very likely possibility is that suppliers will be releasing updates for ELDs through a phased-in approach. This will give fleets and drivers time to become familiar with changes, one step at a time.
Here are six areas where the changes will start to happen between now and 2017:
1. Data Transfer
One reason the FMCSA created the ELD rule is to make roadside inspections more efficient and accurate. The agency wants logbook data from ELDs to be wirelessly transmitted to its auditing software. This software, ERODS, is currently under development and will enable law officers to instantly detect hours-of-service violations.
To data from ELDs, technology suppliers will have to use a telematics method or a local method — or both.
The telematics method has to include two options: e-mail and web services. Many suppliers already have an e-mail feature drivers use to send a summary report of their 8-day duty cycle to law enforcement upon request. What they still need to develop is the web services option for logbook data to go directly to ERODS.
For suppliers that choose to use a local transfer method, their ELDs must have both a Bluetooth and a USB option. This will allow officers to capture and upload data into ERODS and eliminate the need to enter the cab to view a dash-mounted display or a mobile device.
As a fallback, ELDs can still use the traditional logbook grid display or print out a summary report during a roadside inspection.
The FMCSA currently is working on the technical specifications for file transfers and the calculations ERODS will use to detect violations. This process will last for six months or more, at which time ELD suppliers will be able to begin developing the new transfer features, says Elise Chianelli, director of safety and compliance for PeopleNet, which provides electronic driver logs and other mobile fleet management applications.
. Tighter Standards
The new ELD rule establishes fixed thresholds for recording of duty status changes. Drivers will automatically be put into driving status once a vehicle’s speed hits 5 mph. Should a driver not login to an ELD, the record will be presented to the driver during the next login as an “unassigned driving” event that needs to be reconciled.
Another threshold is when a vehicle comes to a stop. After five seconds, ELDs will ask drivers if they want to remain in drive or change to an on-duty status. They will have one minute to respond. In the event a driver comes to a stop in traffic congestion, the driver will be able to switch over to on-duty time and not lose his available drive time, explains Tom Cuthberson, vice president of regulatory affairs at Omnitracs, which offers in-cab and mobile fleet management systems.
Similarly, the rule adds a new element to on duty status called “yard times.” When drivers are on private property such as a shipping or receiving dock, ELDs will give drivers the option to log their movements as on duty, not driving.
ELDs must distinguish yard moves in the on-duty section of the log by using a colored or dotted line, he says.
3. Driver Accountability
One of the most significant changes with the new rule is that drivers can accept or reject edits to their logbook records. AOBRDs currently treat unassigned driving time as a back-office management function to assign to driver logs. ELDs require all unassigned activities and edits be reported to drivers each time they login, Chianelli says.
For instance, suppose a mechanic takes a truck for a test run but doesn’t login to the ELD. The driving record will be stored as an unassigned driving event and presented to the driver assigned to the tractor at login. The driver will have to reject or accept that movement as part of their records.
“What the rule has stated is that the driver is responsible for their hours of service,” says Fred Fakkema, vice president of compliance for Zonar Systems, a provider of fleet telematics systems. “They need to have access to their logs whether through the ELD device or through the back office.”
4. Personal Privacy
AOBRDs have always been able to track events where drivers use vehicles for personal conveyance, if the fleet allows it. The ELD rule ensures that drivers who use this provision are given more privacy in their logbook records.
When using personal conveyance, ELDs will have to record GPS locations to the second decimal place. This will narrows the accuracy of location to approximately 10 miles.
Meanwhile, fleet management systems can continue to capture location data to the fourth decimal point for applications like navigation and fuel tax reporting for accuracy of approximately 30 feet.
5. Supporting documents
With the ELD rule, drivers will be required to have supporting documents to verify their on-duty versus off-duty time. Electronic logs are only capable of determining when a vehicle is stopped and a driver is not in driving status, adds Chianelli.
The reason the FMCSA will continue to require supporting documents is “to make sure drivers are tracking their on duty time,” she says.
The number of supporting documents will be less than what drivers are required to have with AOBRDs, says Zonar’s Fakkema. The number has been reduced to 8 documents within a 24-hour period and can include a variety of items, from receipts to dispatch records.
Some AOBRD applications, such as PeopleNet’s eDriver Logs, can prompt drivers to specify what they are doing during their on-duty statuses such as loading and fueling. Through its Vusion subsidiary, fleets can use an auditing service that captures data from supporting documents — bills of lading, dispatch records, vehicle inspection reports and more — to make sure drivers are logging these activities as part of their on-duty time.
With the ELD rule, any edits made to drivers’ on-duty status as a result of such audits still have to be approved by the driver.
“Drivers will have full editing access to anything but the drive line,” she says.
6. More Data
Drivers will be presented with more information on their displays when the new systems hit the market. The rule requires additional fields in the main header such as the motor carrier’s name, DOT number, address, vehicle number, and the beginning and ending odometer. ELDs will also show the driver’s CDL number and state among other details.
For a cost and feature breakdowns, as well as real-world reviews of AOBRD products that will become ELDs in coming months, visit this chart , Overdrive.
Contact Transportation Risk Management at 586-726-7800 to find out more information about ELDs, we can help save you time and money!
Huff is the Senior Editor of Commercial Carrier Journal