For those of you who have trucks in your fleet, the term ELD Mandate may be a familiar one. But do you know what it really means for you and your fleet?
ELD Mandate History
Beginning December 2017, Federal Motor Carrier Safety Administration (FMCSA) Rule 395 – Hours of Service of Drivers required drivers to report their Records of Duty Status (RODS) through an Electronic Logging Device (ELD) instead of using a paper log book. This regulatory change affects every truck fleet that should be maintaining driver logs.
For fleets still operating with paper logs, this will require an investment in the technology and resources to meet the mandate. However, there have been a number of challenges to the regulation, leaving fleet managers with a dilemma: Do they invest in the technology now and risk the mandate being changed or overturned, or do they wait and have to play last minute catch up, or perhaps be non-compliant when the deadline arrives?
Comply With ELD Now Or Catch Up Later?
When should you comply? It’s understandable that companies may have been hesitant to make the investment while there was a possibility that the regulation could be changed. But keep in mind that most challenges to the mandate have been submitted, and so far the need for the hardware and reporting still stands.
The more important consideration should be “can compliance be done on time?” Several factors make this a valid question.
- Equipping the trucks – At an industry conference earlier this year sources acknowledged that more than a million trucks may still need to be equipped to support ELD. This will put significant pressure on hardware manufacturers, suppliers and installers to meet the market need by the end of year deadline.
In addition almost all of these trucks will have to be up-fitted in the field. This will require scheduling the truck out of service for the installation, and if done by a mobile installer, coordinating the location as well as the time.
- Training – A large number of fleet managers, operations supervisors and drivers will need to be educated on the mandate and on the ELD operations and requirements, including data revisions, data retention requirements and data management.
- Software requirements – The hardware self-certification requirement of the ELD itself has not been done by all of the providers as many await final requirements.Today, in most cases, drivers can present their ELD to the inspector to view the records and graph log. FMCSA has not communicated the software requirements to deliver the driver RODS information to the inspector’s database once the new mandate goes into effect. The ELD hardware companies are waiting for this decision so they can then write their code needed to meet those data requirements.
- Hardware decisions – As a fleet manager it is understandable to have hesitancy to deploy hardware that is not yet certified as compliant by the company that made the device. While cost is an important factor, it should not be the only consideration. It may make more sense to go with a recognized supplier who is more likely to have done their homework and may be better able to adapt to last minute changes to requirements.
- Resources – The mandate will bring a level of formality and rigor to some operations which had not previously been regimented in their log auditing and regulatory compliance management. Companies currently using paper logs may find that electronic logging will make it easier to identify issues that may arise.This may lead more companies to engage regulatory compliance providers in support of driver log auditing and data management, which will add some up-front cost to the operation. However, managing driver and vehicle compliance and acting on the data that indicated action is needed will result in a safer fleet and reduced cost associated with unsafe behavior and non-compliant vehicles.
- Exemptions – Some fleet contacts I’ve spoken with are asking if their operation may be exempt from having to use ELDs. There are rules in place about operation requirements and some industry activity which has some level of exemption in place. These are well defined in the regulation but it may be a good practice to have these operators maintain ELD logs and not need them than to find that due to an unexpected event, a driver who does not normally log hours has exceeded the exemption criteria and is now required to report operating hours or RODS but has not maintained records.
Given everything mentioned above, the majority of truck fleet managers have taken a thoughtful approach to complying with the ELD mandate. Now it’s time for those operations that are required to log HOS to move forward with coming into compliance. The longer you wait, the harder it will be to bring your fleet into compliance while minimizing the negative impact on your operation. Wheels has taken a proactive approach to helping clients get ready for the ELD mandate by providing a solution through our telematics offering. In addition, we will be providing a series of communications to help you understand the impact of the ELD mandate on your fleet and determine if you need to comply.
Are you ready for the ELD mandate? Join the conversation: Email me at bclark@wheels.com