So, what now, you ask?
At the moment we’re in a period of “soft enforcement”. This is not to say that drivers and fleets cannot be issued with citations for non-compliance. The good news, however, is that the Federal Motor Carrier Safety Administration (FMCSA) and Commercial Vehicle Safety Administration (CVSA) have both previously noted that commercial vehicles would not be placed out-of-service for non-compliance until April 1, 2018. It should also be mentioned that non-compliance does not affect CSA (Comprehensive, Safety, Accountability) scores – at least in the short term.
Time is running out, which is why we want to offer some advice for “late adopters” of ELDs, especially regarding what key areas to focus on as devices get deployed. If there is one advantage to being late in transitioning to ELDs, it is the ability to learn from the experiences and mistakes of others.
Understand the grandfather clauseIf you are currently using automatic onboard recording devices (AOBRDs), then you don’t have to move to true ELDs until December 2019. While you can transfer existing AOBRDs to replacement vehicles, any “net-new” vehicles added to your fleet must have ELDs installed. Many fleets we’ve talked with didn’t know about the “net-new” rule.
Decide on an implementation approachIf your fleet has one domicile, it’s relatively simple to switch over all vehicles to ELDs all at once. If your fleet has multiple domiciles, we recommend a “phased” approach, installing ELDs at one domicile at a time. If you are grandfathered-in and have multiple domiciles, you’re in luck – you can spread your ELD implementation out over time to allow for proper planning and training of drivers and administrators.
Provide adequate trainingRegardless of which ELD vendor you use, they should provide training tools to support your ELD transition. Training staff are likely to be spread thin over the next six months as many fleets scramble to comply, so book your training early. For some fleets, online training may provide a better, less time-consuming training option. Online training will allow your employees to go at their own pace; even repeat training sections as necessary.
Highlight driver ownership of ELD logsDriver training should highlight the differences between AOBRDs (if you currently have them) and ELDs, or paper logs and ELDs. The biggest change for drivers in both cases is that with ELDs, drivers own responsibility for HOS logs. Administrators can edit the electronic log, but drivers have final say over accepting those edits. Every time a driver logs on to their ELD, they will need to review and confirm:
- Their HOS log for the past 24 hours.
- Any edits to their HOS log that someone else made.
- Unidentified mileage (which must then be assigned).
Train drivers on handling roadside inspectionsYour ELD system will likely offer one or both of these options for sharing ELD data with inspectors:
- Remote file transfer via email or wireless transfer, or
- Local file transfer via USB or Bluetooth.
Prepare administrators for the transitionAgain, the biggest change for administrators is that in an ELD world, they no longer own HOS logs – drivers have the final say. Administrators should plan on reviewing HOS, edits and unidentified mileage daily to make sure missing or incomplete data doesn’t get out of hand. Most ELD solutions have an audit trail in place – this feature is crucial as it will help administrators track down and fix any issues.
Once everyone gets used to the new ELD system, administrators may be able to back down to reviewing HOS weekly, but we recommend making daily reviews of edits and unidentified mileage a long-term habit. Think of this like reconciling your bank account – if you get behind by a few months, it gets very difficult to track down discrepancies.
Have a policy in place for HOS editsSometimes, HOS logs need to be edited. For example, consider a common scenario where a driver forgets to go off duty during a stop for a meal or even overnight. Fleets should have a policy in place for who is responsible for making edits to HOS logs. Some fleets have decided that administrators are responsible for edits, although drivers still have final say to accept or reject them. Other fleets have decided that since drivers own the logs, they must do their own editing.
Our recommendation: make fleet administrators responsible for making HOS edits, and have drivers accept or reject them. Administrators will do this more consistently, with fewer mistakes, because they will do it more often.
Find out more about MiX’s ELD solution.