Electronic Log Mandate for 2015
This year, the Department of Transportation (DOT) is expected to publish a Final Rule mandating the use of electronic logging devices (ELD) or electronic onboard recorders (EBOR) for drivers and fleets. According to the January 2015 DOT report on significant rulings, the mandate (MAP-21) is expected to be released September 30, 2015, but actual enforcement of the mandate would begin two years later, in September of 2017.
DOT claims that the rulemaking will establish the following:
- Minimum performance and design standards for hours-of-service (HOS) electronic logging devices (ELDs)
- Mandatory requirements for the use of ELDs by drivers currently required to prepare HOS records of duty status (RODS)
- Requirements concerning HOS supporting documents
- Measures to address concerns about harassment resulting from the mandatory use of ELDs
DOT notes that the effects of the new mandate will be economically significant and raise issues of privacy through information collection, which is still garnering attention. Like many new DOT mandates, the ELD rule will present a series of challenges and benefits for fleets and their drivers. But what exactly is the Electronic Log Mandate, and how will it affect your company?
ELD Mandate Defined
Essentially, all commercial vehicle drivers who file a Record of Duty Status (RODS) and who are currently subject to paper logs will be required by federal law to enter their Hours of Service (HOS) with an ELD. The mandate is expected to affect 3.1 million trucks and 3.4 million truck drivers. Exemptions of ELDs include short-haul drivers operating within a 100 mile radius and non-CDL drivers operating within 150 mile radius.
Every HOS driver or commercial truck will have to be furnished with an electronic device compliant with regulations. The ELD data set is founded on the date, time, CMV location, engine hours, vehicle miles, driver or authenticated user identification data, vehicle identification data, and motor carrier identification data.
What exactly a compliant device looks like may vary from specially enabled smartphones to computer systems. Regardless of what the device is, the ELD vendor (of apps or devices) must register with the FMCSA and prove that its products meet the technical and performance standards required.
Some notable ELD / EOBR requirements include the following:
- For trucks manufactured after the year 2000, “integral synchronization” is required, meaning that a GPS enabled smartphone will not suffice. Engine power status, vehicle motion status, miles driven, and engine hours will all be automatically recorded.
- Data must be transferable to enforcement officers via at least one of the following: wireless web services, Bluetooth 2.1, USB, email or by print and be available as a graph grid display for easy reading.
- The device must be resistant to tampering, preventing erasure or alteration of original data submitted to the ELD.
Preparing for Change
Although two years may seem like a reasonable preparatory period, given the complication and intensiveness of the mandate, it is highly advisable that fleet owners address the mandate sooner rather than later. To avoid disruptions in day-to-day business, it’s critical that drivers and fleet owners begin researching possible ELD solutions and creating an integrated plan for using them as soon as possible. Carriers should consider their goals and ROI when selecting an ELD partner.
With a range of options available, from low-cost single-function systems to more complex comprehensive recording devices, carriers need to consider the best ways to meet their long term safety goals for the best ROI.
For example, the behavioral performance data generated by ELDs could notify carriers and authorities of habits that pose potential safety threats, making the carrier system safer and possibly less expensive.Harassment ConcernsIn response to concerns over the potential harassment of drivers, the FMCSA released a report in November 2014 stating that carrier harassment of drivers using ELDs is minimal. The report is based off of surveys of over 600 drivers. However, exactly what intensity of driver-carrier interaction warrants the term “harassment” is up for debate. Many of the survey findings were positive.
More than 70% of the drivers surveyed reported that with ELDs, they have less paperwork, hours compliance is easier, their relationship with their fleet manager had been “enhanced” and they felt better protected from overbearing management.
However, the survey also reported that more than half of the drivers felt they were providing their carriers with too much information and were forced to act with less autonomy and freedom to do their job as they saw fit. The intricacies of the new mandate will likely see new emerging concerns over privacy and harassment as the ways in which driver data is used expands in unexpected ways.
ELDs present the opportunity for a variety of safety and operational benefits, but carriers are faced with weighing those benefits against the cost of implementing new technology and training. ELDs could potentially save carriers hundreds of hours of administrative work each year, saving both time and money.
It’s been noted that ELDs can also improve driver satisfaction and reduce stress by improving time management and logging accuracy. With safety always a top priority, ELD’s offer the promise of a safer and better regulated carrier community. There’s no doubt that carriers and their affiliates have a lot to benefit from technology, the key will be finding a smooth transition from the old to the new. The earlier each carrier begins the search for a certified ELD partner catering to its specific needs and financial goals, the easier the transition process will be.