In December 2015, the Federal Motor Carrier Safety Administration (FMCSA) published the final version of the anticipated Electronic Logging Device (ELD) mandate, providing a two-year window for organizations to become compliant. As of December 18, 2017, that two-year window will come to a close, and it’s time for drivers and fleet owners to embrace compliance with the new ELD mandate.
Who Falls Under the Mandate?
Even though the official date is just around the corner, there is still a lot of confusion around what it means to be ELD compliant and who exactly falls under the mandate. ELD solutions enable all drivers who are required to keep a Record of Duty Status to easily track and report their Hours of Service (HOS). This mandate not only affects companies operating in the trucking industry, but also those working within the construction industry and other auxiliary industries. Anyone operating or managing commercial vehicles that weigh more than 10,000 pounds must electronically log their HOS and Driver Vehicle Inspection Reports (DVIRs) using an ELD, which complies with the FMCSA certification requirements. According to the FMCSA, the mandate is estimated to affect approximately 3.1 million trucks and 3.4 million drivers.
Companies who have Automatic On-Board Recording Devices (AOBRDs) installed and operational by December 16, 2017, will have until December 2019 to fully comply, at which time they will need to adopt an ELD solution. Most solution providers plan to upgrade their existing AOBRD customer base to full ELD compliance via over-the-air software updates. As black and white as these rules may seem, there is still a lot of gray surrounding the conversation.
There are several exemptions allowed within the mandate. For example, drivers who conduct drive-away-tow-away operations, where the vehicle being driven is the commodity being delivered, are not required to use an ELD, however they are still required to keep records of duty status and must prepare logs on paper or using an AOBRD. Various exemption scenarios have been detailed by the FMCSA, including a recently announced exemption for short-term truck rentals.
Commonly Asked Questions
Numerous resources are available to answer questions around the ELD mandate, including the FMCSA website, ELD educators and trusted solution providers that have taken the lead to develop compliant products. Here are some of the questions we are hearing most frequently from those who need more clarification around the specific details of ELD compliance, deadlines and next steps:
1. If my vehicle is not over the 10,000 pounds weight, but goes over the 10,000 pounds when I hook up a trailer, do I still need an electronic log?
Yes. If the combined weight exceeds the limit, the driver is required to maintain an electronic log. If the driver operates the commercial vehicle more than eight days in a month, they must account for their on-duty and off-duty time.
2. If my drivers do not cross state lines, do they need to comply with the ELD mandate?
Generally, if drivers are operating within a state, they must comply with state rules versus federal rules. However, it is advisable always to be compliant with the federal mandate. The ELD mandate requires each state to create their own ELD rules for intrastate drivers that are compatible with the federal rules.
3. If my drivers stay within the 100 air-mile radius rule, do they need to maintain electronic logs?
There are several exceptions to the ELD mandate that can be applied to specific business conditions, including the short-haul exception for a 100 air-miles radius.
4. I have my own mobile device; can I use this for electronic logs in my vehicle?
Each solution provider has a preferred approach for mobile devices, so that it will be dependent on the solution architecture. Dedicated, in-cab devices are generally considered more reliable solutions for ease of use and driver safety.
5. What if I also drive my vehicle for personal reasons? Do I still need to maintain electronic logs?
You must still log when you are operating your vehicle for personal use. Personal use driving time does not count towards cycle duty time.
6. What happens if I take a break for less than 30 minutes?
You must take a break for at least 30 consecutive minutes for the break to count towards your cycle duty time.
7. Should I delay my ELD implementation because of the proposed legislation to push out the deadline?
Solution providers are not altering their product development plans as a result of recent attempts by some members of Congress to delay the ELD compliance date. Once a solution is selected, full implementation can take several months, and companies that wait risk delays in being compliant by the deadline.
8. I have a team of workers that leave together in the same truck but come back in different vehicles throughout the day. Can an ELD system help me track my employee hours, for more than just the main driver?
Yes, using the ELD compliant in-cab tablet allows employees to log their hours to bring more transparency to payroll operations. The main driver can log in as “On Duty – Driver,” and all other employees in the truck can log in as “On Duty - Not Driving.” During lunch and at the end of the day, all drivers can use the in-cab tablet to sign out. This gives the office a digital record of hours thus cutting down on the inefficient process of collecting and entering paperwork.
Benefits to Drivers & Fleet Owners
Though many companies view the upcoming mandate as a burden, others see it as an opportunity to make better-informed business decisions. Not only do ELD solutions keep the real-time record of HOS and DVIR activities, but most are integrated with broader fleet management systems that also provide alerts of possible violations, driver behavior and safety monitoring, automatic assignment of driver availability based on assigned rules, and record storage to remain in compliance with FMCSA requirements.
In addition to streamlining recordkeeping, making the switch to an ELD solution means roadside inspections will be much faster, as drivers will simply need to provide a screen display of their e-logs or take part in a roadside data transfer. Drivers will have the tools and data necessary to avoid stiff financial penalties.
Companies hesitant to invest in an ELD solution because of the uncertainty around whether they fall under the mandate should take the plunge and think of it as a soft nudge to implementing a system that will improve overall fleet management and driver safety.