The ABC’s of the Looming ELD MandatePart 1

March 3rd, 2016

Christopher P. Nelson, Vice President

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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 - TimelineFebruary 16th, 2016

Effective DateDecember 18th, 2017

Compliance DateDecember 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, 2015Publication 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 - FAQsWould 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 - FAQsIn 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.