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How to Prepare for the Electronic Logging Device Mandate

Posted on 7/1/2014 by Mecca Howe

The Federal Motor Carrier Safety Administration (FMCSA) announced on March 12, 2014 a Supplemental Notice of Proposed Rulemaking to mandate electronic logging devices. While the rule’s effective date and publication date in the Federal Register are still unknown, it is likely that the rule will go into effect two years after the final rule is issued, presumably later this year.

The development of the Electronic Logging Device mandate is part of the transportation reauthorization bill MAP-21 that was signed into law in 2012.

Decoding the Difference Between AOBRDs, EOBRs and ELDs
The terms AOBRD, EOBR and ELD are often used interchangeably. While their technology platform can be very similar, there are specific characteristics that differentiate them from each other. 

AOBRD: The current FMCSA regulation for HOS compliance (FMCSA 395.15) uses the language “Automatic On-Board Recording Device” when outlining the requirements that an electronic device must meet in order to be utilized in lieu of traditional paper log books. AOBRDs is the correct terminology when referring to technology regulated in 49 CFR 395.15.

EOBR: “Electronic Onboard Recorder” is the term that has been commonly used throughout the industry over the past decade when referring to the device that houses electronic log applications. The FMCSA used EOBR as part of the language that was published within the 2010 Final Rule – 395.16, which was vacated in August of 2011.

ELD: “Electronic Logging Device” is the language that the FMCSA is using as part of its current rulemaking when referring to systems defined by the new mandate. ELDs, as opposed to their EOBR and AOBRD predecessors, sync with a truck’s engine to capture power status, motion status, miles driven and engine hours. Additionally, the FMCSA uses the term “ELD data” to mean each data element captured by an ELD that is compliant with the specified requirements and that would be available to authorized safety officials during roadside inspections and as part of on-site or other reviews. The following data elements are the specific items that makeup the ELD dataset: 
  • Date
  • Time
  • CMV location
  • Engine hours
  • Driver identification data
  • Vehicle identification data
  • Motor carrier identification data
  • Vehicle miles

Determining if Your Fleet is Affected

The mandate will apply to all drivers who are currently required to keep paper Records of Duty Status. Drivers who are required to keep RODS in eight or more days out of every 30 days must use an ELD. While drivers that fall under the HOS exemption, such as short haul drivers operating within a 100-mile radius or non CDL drivers operating within a 150-mile radius, are not required to have an ELD, the mandate is estimate to affect approximately 3.1M trucks and 3.14M drivers according to the FMCSA.

Timeline for Carrier Compliance
Carriers and drivers will be required to install or use a compliant ELD two years after the effective date of the final rule. Carriers who already have AOBRDs installed prior to the ELD mandate, however, have two additional years to comply.

Weighing ELD options
In addition to meeting compliance of the ELD Mandate, there are a myriad of safety and operational benefits for fleets when deploying onboard technology. A wide range of capabilities and prices makes it imperative that carriers consider their goals and ROI when selecting an onboard technology partner. There are, and will be, many new low-cost, single-function systems with limited capabilities that simply address regulation requirements, and there are more comprehensive solutions that address a wider range of issues (onboard event recording, speed monitoring, engine fault code monitoring, speed alarms and more) to help companies meet a broader range of safety goals. In addition, there are professional services organizations that help customers understand how to use ELD and onboard technology to assess, measure, and impact safety performance.

Cost/Benefit Considerations
Carriers and drivers have so much at stake under the new regulatory landscape that the cost of non-compliance is far more expensive than the cost of compliance. In addition to avoiding the unnecessary expense of heavy fines, EOBR-based HOS solutions offer cost-saving opportunities in improved safety, as well as high-efficiency compliance with the ELD mandate.

Carriers wondering if more sophisticated bundled EOBR systems are worth the investment should understand the potential for additional ROI across their entire operation. For instance, the driver behavior/performance data generated by EOBRs creates an early warning system about habits that pose safety threats; without this information, these risks may go undetected until they cause an accident. The data (hard braking, lane departure, speed, etc.) provides managers the information they need to dialog with driver, raise awareness, and correct negative behaviors. In addition to uncovering the root causes of undesirable behaviors that may not only lead to safety violations and accidents, the value of this and additional engine-generated data can help reduce fuel consumption.

Fleets that have implemented EOBR technology have reaped impressive ROI data and made operations more efficient. They have reduced overhead, insurance premiums, fuel and other operational costs, and improved customer service and driver efficiency- adding up to better their bottom line. 

Fleets can also time and money with their FTS Plus+ membership. You don’t have to waste time researching all the E-Logging companies in the industry to try to find the best fit your business. We have the answer for you, and we can save you money, too. 

Through FTS Plus+ and PeopleNet, fleets can receive free service for one month, free remote installation training, or choose a 36-month service contract, the lowest in the industry. To learn more, visit ftsplus.com/peoplenet.