December Deadline for ELD Mandate:
Quick Reference Guide to Stay Compliant
On December 18, 2017, the Federal Motor Carrier Safety Administration (FMCSA) will be implementing a final rule for electronic logging devices (ELD’s). ELD’s will directly affect commercial buses and trucks, as well as Canadian and Mexican-based drivers. Title 49 – Part 395 Hours of Service of Drivers: Subpart A—§395.8 “Driver's record of duty status” now establishes all rules and regulations for carriers and drivers to comply with this new standard. Read the full standard here. This article will cover 3 key objectives to inform and prepare your fleet on the upcoming December 2017 mandate.
Those carriers who have implemented ELD systems and programs within their fleets, dependent upon certain guidelines we will discuss later, should translate to the new mandate set forth in December 2017. With that said, the updated ELD ruling can be a bit confusing to carriers and drivers, but the following key objectives should help you start rolling in the right direction.
Long Haul, Short Haul, Regional and Local Carriers: Do I need to update my Hours of Service Program, and How?
This list of key requirements will help in easing FMCSA’s must-haves for introducing ELD’s into your fleet:
1.) Applicability of the ELD Rule & Exemptions
Who does this apply to? The ELD Mandate begins December 2017 and affects all commercial buses and trucks. Right? Sort of. December 2017 is the start date for all commercial carriers (buses and trucks alike), but there are some exemptions within this mandate:
· Drivers who operate under the short haul exceptions. These drivers may continue using timecards. They are not required to keep RODS (Records of Duty Status) and will not be required to use ELD’s.
Ø Short haul exceptions: 49 CFR 395.1(3)
· Drivers who use paper RODS for not more than 8 days out of every 30-day period.
· Drivers who conduct drive-away-tow-away operations, in which the vehicle being driven is the commodity being delivered.
· Drivers of vehicles manufactured before 2000. (source: fmcsa.dot.gov)
2.) Records of Duty Status (RODS) & Retaining Hours of Service (HOS) Records
Nothing has changed in the realm of general operating hours of service (70/80-hr work week) or retention of records. If your company is required to transition to using an ELD though, there are some considerations that should be made:
· Ability to have distinct driver and administrative login versions.
Ø This gives your fleet of drivers the ability to have unique login ID’s and passwords to keep their hours of service separate and secure.
Ø You might have teams of two people operating a truck together. These unique ID’s and passwords eliminate operating on one another’s e-log.
· Driving time is recorded at a minimum cyclical period of 60-minutes. This will require updating and recording of date, time, location, engine usage, mileage, and driver identification.
· Inability to erase or manipulate data collected.
· Transfer of data to either a wireless or direct source.
Ø This is primarily used for DOT inspections, when a local or state authority requests to see electronic logs (fmcsa.dot.gov)
3.) Implementation of an ELD Training Program
A new HOS training program may seem daunting, but if recordkeeping is established, the actual use of your new electronic logging device will prove to be the greatest obstacle.
The following steps are intended to act as a baseline for those companies who will have to comply with the December 2017 ELD Mandate:
· Formal classroom or on-the-job (or road) training at initial purchase of ELD program.
Ø Quizzes are a great way to recognize any gaps in driver retention.
Ø Most programs have customer service departments, who will assist in equipment functionality.
· Annual (if necessary) and refresher training to determine your fleets’ competency of the program and HOS recordkeeping.
Ø Training should mimic the initial, formal training with an emphasis on proficiency and efficiency.
· Evaluation of training program.
Ø Develop a questionnaire asking questions to determine the effectiveness of the training program for all drivers to complete (e.g. – Perception Survey).
Ø Perform program audits.
§ Most ELD programs have web-based portals to search fleet-wide and specific driver HOS violations.
With all the intricacies in operating a transportation company, the new ELD mandate, seems like another “flat tire” during daily operations. With the three topics mentioned earlier, you have an upper-hand on the December 18, 2017 ELD Mandate. All in all, your drivers need to be confident in basic recordkeeping requirements (e.g. – OTR Drivers: 80-hr Work Max; 11-Hr Driving/On-Duty Max, 14-Hr On-Duty Max, etc.). You are the one to help create an effective and realistic program that will benefit your company, and more importantly your fleet of drivers.
References:
Drivers and Carriers. (2015, September 03). Retrieved June 30, 2017, from https://www.fmcsa.dot.gov/hours-service/elds/drivers-and-carriers
Hall, C. (n.d.). Fourth Quarter 2014. Retrieved June 30, 2017, from http://www.safetyresources.com/evaluating-your-safety-training-program
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