The Rapidly Approaching ELD Mandate: What you need to know, When you need to know it, and Why 51st Annual Contractors Transportation Management Association Conference Susan Reszczynski, Western Sales Engineer/Product Advocate| May 24, 2017| Point Clear, Alabama eroad.com
Focus for today’s session Overview What is an ELD? Who needs it and who will be exempt? What must the ELD do Timelines When does it apply? Compliance phases Lastly Things to ponder Self-Certification & the FMCSA ELD Registry Agenda and goal today is sharing knowledge to give you a basic overview in order to prepare you for the upcoming months in which you will need to make a big decision for your company.
What is an ELD? §395.2: “ELD means a device or technology that automatically records a driver’s driving time and facilitates the accurate recording of the driver’s hours of service, and that meets the requirements of subpart B of this part.” Key requirements: Date, time and location automatically captured Must be integrally connected to the CMV’s engine All driving time is captured – No log in = ‘unassigned driving time’ Allow for annotation and editing, driver and carrier (carrier suggests edits) ELD data to be displayed or printed for enforcement away from the vehicle ELD data transfer capability of either: Telematics (Wireless Web Services + Email) or Local (USB + Bluetooth) Final rule can be found here: https://www.fmcsa.dot.gov/hours-of-service/elds/electronic-logging-devices
ELDs must…… Meet all the technical and functional specs set by FMCSA (over 400) Automatically record driving status (cannot be edited/removed) Automatic drive status at 5mph Special driving categories: Personal Conveyance (PC) and Yard Moves (YM) Ensure driver has more control over the RODS (certification and edits) Edits are suggested; must be approved by the driver Have mute function while driver in sleeper berth (driver harassment) Make records available to enforcement Display requirement Have the ability to transfer records roadside Be self-certified and on FMCSA ELD Registry
Who needs it and who is exempt? All drivers that require RODS must transition to ELDs by compliance date(s). Exemptions: Drivers currently allowed to use timecards could continue to do so under § 395.1(e) unless… Fall outside of short-haul no more than 8 days in any 30 day period (rolling, not set) Drivers who conduct driveaway-towaway operations, where the vehicle being driven is the commodity being delivered Drivers of vehicles manufactured before model year 2000. https://www.fmcsa.dot.gov/hours-service/elds/faqs Exempt: trucks pre 2000 (based on VIN #); Drive-away towaway operations; timecards used more than 8 days (magic number 9) in any 30 day period. For most recent FAQs, see link below (updated 3/6/2017). Also hand-outs
When does it apply? December 18, 2017 Phase 1 Phase 2 Phase 3 February 16, 2016 Effective Date ELD providers with compliant product can apply to be on the FMCSA registry December 18, 2017 Compliance Date ELD becomes mandatory for qualifying-non/exempt carriers and drivers December 16, 2019 End of AOBR Grandfathering / Full Compliance Date All drivers and motor carriers must abandon AOBRs and use ELDs
Awareness and Transition Compliance phases PAPER ELS AOBR ELD Awareness and Transition Carriers and drivers subject to the ELD mandate should prepare to transition and may voluntarily adopt ELDs. Phased-in compliance Unless carriers and drivers using AOBRs, must adopt ELDs. Full compliance All carriers and drivers must adopt ELDs. Phase 1 Phase 2 Phase 3 Right now After 12/2017 NO PAPER LOGS AFTER 12/18/2017 unless being used for short-haulers on those days that they fall outside the requirements and for drivers whose ELDs or AOBRDs are not working. After 12/2019
Things to ponder….. How much time will it take to onboard ? Number of drivers, Training, Installation Does the ELD meet safety, security and regulatory requirements? FedRAMP and FMCSRs Transference, storage and safety of data Encrypted vs unencrypted FIPS, Common Criteria How much will this cost me? Buy or rent equipment Monthly maintenance What type of device can I use? Hardwired vs BYOD Not all ELDs are created the same
Why is “Ping” rate important?
EROAD’s Ping Rate 1x per second
EROAD vs. “Other”: Visual Accuracy
Self Certification and FMCSA Registry https://3pdp.fmcsa.dot.gov/ELD/ELDList.aspx 47 ELD Providers as of 5/18/2017 EROAD is #30 Multiple entries/products – same provider (@44) Read User Manuals to verify compliance Independent certification https://www.fmcsa.dot.gov/hours-service/elds/eld-checklist-carriers
Susan Reszczynski (503) 509-1240 Susan.Reszczynski@eroad.com Andy Black (951) 553-5139 Andy.black@eroad.com