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A Comprehensive Guide To ELD Mandate

A COMPREHENSIVE GUIDE TO ELD MANDATE

Ever since the Federal Motor Carrier Safety Administration (FMCSA) introduced the ELD mandate in December 2015, the trucking industry has been busy understanding the technology, its uses, and its implications. According to the mandate, all carriers were required to install ELD by the end of 2017, with a few exceptions. Commercial Motor Vehicles (CMV) that have AOBRD are required to shift to ELD technology by the end of 2019.

Even though a lot has been documented and explained about the electronic logging device (ELD), several owner-operators and drivers are still in confusion. It is important to understand this mandate and its significance as there hasn’t been a regulation that could cause a nation-wide effect as this one. One of the major reasons behind this humongous effect is the fact trucking is one of the most common jobs in all the states.

Matrack Incorporation has therefore created this guide to give all necessary information about ELDs in one place. This guide will help you understand the technology, its uses, features, and its benefits for your company. Here is what will help you:

  • What is ELD and how it works?
  • ELD Mandate – A history
  • Enforcement of ELD
  • ELD violations
  • ELD exemptions
  • Choosing the best ELD for your company
  • Benefits of ELD for your company

What is ELD? How does it work?

An ELD or electronic logging device is small hardware that can be easily installed in a vehicle, usually in its OBD II port. It is easy to install, and once integrated with the vehicle’s engine, an ELD can collect and record data whenever the engine is turned on. ELD mandate was introduced by the Federal Motor Carrier Safety Administration, with the purpose of making a recording of hours of service data authentic and accurate. As the electronic logging device automatically records data, it is more reliable than paper logs.

Many carriers that have been using automatic onboard recording devices, generally known as AOBRDs, they have been given an extension in switching to ELD till December 16, 2019. Carrier 18, 2017.

The only reason ELDs using paper logs, however, were required to make the change by December are replacing the AOBRDs is because they are more advanced, technologically. Also, with a proper fleet management system, ELDs can record a lot more valuable data. AOBRDs can document data regarding the use of engine, speed, mileage, date and time. ELDs that are certified by FMCSA can record all the data that AOBRDs can along with information for power status of the engine, vehicle’s location and engine diagnostic, health and malfunctions.

ELD has two important elements – the hardware device and the software application. The device is installed within the vehicle’s OBD port II, and then it is integrated with the software application, available on a mobile device (smartphone or tablet) of choice. The two aspects work together to generate and document data for engine status, hours, idle time, mileage, vehicle movement and vehicle’s location. The hours of service information along with all other required data collected by the ELD can be seen on the screen of the smartphone, tablet or any other wireless device. Also, such data can be shared through email or printouts to the inspection officer, whenever required.

ELD Mandate – a history

The Federal Motor Carrier Safety Administration had been conducting various studies and research to understand and identify the threats to driver safety, and ways to make their work environment safer. Following the research, the FMCSA tried to introduce e-logging, which was met with opposition from federal courts. Various groups like Owner-Operator Independent Driver Association (OOIDA) also objected to e-logging as they thought it would encroach on driver’s privacy and cause grounds for workplace harassment.

FMCSA wanted to adopt e-logging system as early as 2000. It was believed that electronic system for logging of hours of service would ensure that drivers do not overwork, maintain a healthier lifestyle, and also comply with the DOT rules. The fundamental reason for adopting an electronic system was to decrease the number of accidents involving trucks, as most of these accidents were caused by overworked and fatigued drivers.

Until 2012, FMCSA had a hard time moving ahead with the e-logging system. A breakthrough came when Congress passed MAP-21, a transportation bill that included provision for an ELD mandate to be followed by all commercial motor vehicle drivers and carriers. Because of this step, the ELD gained popularity and support from many truck driver associations and other groups. This encouraged many truck drivers to install electronic logging devices in their vehicles.

The December 2015, the ELD mandate was finalized. But it was introduced in the industry in December of 2017 as OOIDA had launched a legal battle against the mandate. However, the mandate found favor in appeal courts as well as the U.S. Supreme court.

Enforcement of ELD Mandate

FMCSA declared that by December 18, 2017, all commercial motor vehicles were necessarily required to install ELD. CMVs using AOBRD were given an extension up to December 16, 2019, to make a switch to ELDs. FMCSA also updated the CSA’s Safety Measurement System with ELD-related violations and corresponding severity weightage. The updated SMS was fully enforced from April 1, 2018, and heavily penalized non-exempt CMVs for non-compliance of the ELD mandate during roadside inspections. Time and again, FMCSA and its officials have emphasized the significance of the mandate and strict adherence to its rules and regulations.

ELD Violations

Federal Motor Carrier Safety Administration added 22 ELD-related violations to CSA’s Safety Measurement System.

SECTION VIOLATION DESCRIPTION VIOLATION GROUP SEVERITY WEIGHT
395.8A-ELD ELD-No record of Duty Status (ELD required) Incomplete/Wrong Log 5
395.8A –NON-ELD No record of Duty Status when one is required (ELD not required) Incomplete/Wrong Log 5
395.8A1 Not using the appropriate method to record hours of service Incomplete/Wrong Log 5
395.11G Failing to provide supporting documents in the driver’s possession upon request False Log 7
395.20B The ELD’s display screen cannot be viewed outside of the commercial motor vehicle Incomplete/Wrong Log 5
395.22A Operating with a device that is not registered with FMCSA Incomplete/Wrong Log 5
395.22G Portable ELD not mounted in a fixed position and visible to driver EOBR-related 1
395.22H1 Driver failing to maintain ELD user’s manual EOBR-related 1
395.22H2 Driver failing to maintain ELD instruction sheet EOBR-related 1
395.22H3 Driver failed to maintain instruction sheet for ELD malfunction reporting requirements   EOBR-related 1
395.22H4 Driver failed to maintain supply of blank driver’s records of duty status graph-grids   EOBR-related 1
395.24C1I Driver failed to make annotations when applicable Other Log/Form & Manner 1
395.24C1II Driver failed to manually add location description Other Log/Form & Manner 1
395.24C1III Driver failed to add file comment per safety officer’s request Other Log/Form & Manner 1
395.24C2I Driver failed to manually add CMV power unit number Other Log/Form & Manner 1
395.24C2II Driver failed to manually add the trailer number Other Log/Form & Manner 1
395.24C2III Driver failed to manually add shipping document number Other Log/Form & Manner 1
395.28 Driver failed to select/deselect or annotate a special driving category or exempt status Other Log/Form & Manner 1
395.30B1 Driver failed to certify the accuracy of the information gathered by the ELD Other Log/Form & Manner 1
395.30C Failing to follow the prompts from the ELD when editing/adding missing information Other Log/Form & Manner 1
395.32B Driver failed to assume or decline unassigned driving time Incomplete/Wrong Log 5
395.34A1 Failing to note malfunction that requires use of paper log Incomplete/Wrong Log 5

To know more about ELD-violations, penalties, and ways to avoid them, read ‘A Comprehensive Guide to ELD Violations

ELD Exemptions

Although the ELD mandate applies to almost all commercial motor vehicle drivers and carriers, there are a few exemptions. Motor carriers that have AOBRD have an extension up to December 16, 2019, to shift to ELD. There are currently six important exemptions as discussed below:

  1. Vehicles manufactured before 2000: Most vehicles that have been manufactured before the year 2000 do not have an engine control module (ECM), and thus an ELD cannot be installed in such vehicles. However, it was later made clear that the exemption applies to models of the engine rather than the model of the vehicle. So if a vehicle was manufactured before the year 2000 and has an engine that was manufactured in or after 2000, the vehicle will be required to have an ELD and will not be exempted.
  2. Drive-away/tow-away drivers: Federal Motor Carrier Safety Administration describes a drive-away/tow-away operation as transportation of an empty vehicle (with more than one set of wheels on the surface of the road):
  3. Between different facilities of the manufacturer of the vehicle
  4. Between the facilities of the manufacturer and dealer/buyer
  5. Between dealership and buyer/ lessee
  6. To repair the facility after a major accident or failure of an important vehicle component.
  7. By saddle mount or tow-bar.

Any vehicle that falls under the above-mentioned categories of operation is not required to have an ELD.

  • 100 air-mile radius: The 100-mile radius or short- haul exemption applies to a driver who is allowed to use time records instead of electronic logging device under the following conditions:
  • The driver traveled within a 100-mile radius of the work reporting location.
  • The driver is released from duty for an 8-10 hour break from the work reporting location within 12 hours.
  • The driver maintains a precise log of hours of service, correctly mentioning the time of start and end of driving a shift in the time records.
  • If the driver travels outside the 100-mile radius boundary, he/she will be required to fill out the paper log for that particular day. But if this happens more than 8 times throughout a period of 30-days, the driver will have to use ELD for further travel.
  • Drivers maintaining RODS (Record of Duty Status) for 8 or fewer days: This exemption is an extension to the 100-mile radius rule. Any commercial vehicle driver who maintains RODS for 8 or fewer days during a period of 30 days is not required to use an electronic logging device. So if a driver doesn’t take long trips regularly is exempted from ELD mandate.
  • Farm Vehicles: Vehicles used on a farm for private transportation of commodities like livestock, machinery, or other supplies are exempt from ELD mandate.

150 Air-mile radius: This is similar to the 100 air-mile radius exemption, but it applies to non-CDL (Commercial driver’s license) drivers as well. If they take a trip within a 150-mile radius of their reporting work location and return to the same location at the end of the driving shift, they are exempt from ELD mandate. However, the driver will be required to use an ELD,

  1. if they drive a vehicle that requires CDL,
  2. drive after 14 hours of duty for 5 days in a period of 7 consecutive days, or
  3. drive after 16 hours of duty for 2 days in a period of 7 consecutive days.

Choosing the right ELD for your business:

The most important thing to consider while choosing an ELD provider is to identify the needs of your business. Your ELD solution must not only be FMCSA compliant but also offer safety and help in improving the efficiency of your operations. Here are a few things to consider while selecting an ELD solution:

  1. FMCSA- compliant: Federal Motor Carrier Safety Administration has a list of registered ELD manufacturers. However, the criteria to be on the list is for the device to be self-certified, which means that even though it is on the list, it not might be completely in compliance with FMCSA rules and regulations. You would want to select an ELD solution that is completely in compliance with FMCSA in order to avoid violations and penalties.
  2. One ELD for all: Many motor carrier companies have various sizes and types of vehicles – light-duty, bucket or tractor trucks, electric vehicles, and more. For the sake of convenience of operations and ease of use for drivers, it is best to choose an ELD that can be installed for the entire fleet.
  3. Economic and easy to install: For fleets as well as for standalone CMVs, having an electronic logging device that can be easily installed allows saving time, as well as makes it easier to use the same ELD in case a vehicle is replaced. For fleets of any size, implementing ELD solution requires more than just installing them in vehicles – they also need to train their drivers in using them. That is why it is best to choose an ELD which is user-friendly and economic at the same time.
  4. Efficient: There are several ELD solution providers in the industry that offer a host of added functionalities as a part of an all-inclusive fleet management solution. These solutions are valuable in realizing business goals by streamlining operations and the maximum utilization of available resources. For best outcomes and have a greater ROI (Return on Investment) choose an ELD that offers better efficiency.
  5. Compatible Technology and upgrades: As smartphones, tablets and other wireless devices are very commonly used these days, and ELD solution that is compatible with these devices ensures easier operation and understanding for the drivers and well as inspection officers. Also, make sure to choose an electronic logging device service provider that can offer upgraded solutions as and when regulations change in the future.
  6. Customer service and Vendor reputation: However good and technologically advanced an ELD may be, there is always a chance of it malfunctioning or facing any other problems. As drivers are mostly out on the roads, they need customer support round-the-clock for continual documentation of their driving status and avoid violations during an inspection. Choosing a vendor that has been in the industry for longer than others, offers 24/7 valuable customer support, has better reviews from other clients, and has a competitive edge over other service providers is crucial for every motor carrier and driver.
  7. Security: According to the National Motor Freight Traffic Association, it is best to opt for an ELD solution that has secure platforms to avoid hacking and theft of important fleet and vehicle data.

It is important that you thoroughly consider all your requirements and available options of ELD providers in the market before deciding. Several ELD manufacturers offer custom-made solutions to best suit your needs.

Benefits of ELD:

One of the obvious benefits of an ELD is compliance with FMCSA and DOT regulations. However, ELD can benefit a motor carrier in various ways apart from being compliant.

  1. Paperwork: ELD has massively reduced, and in some cases, made it absolutely redundant to maintain paper logs. This not only saves time but is more efficient, accurate and authentic. As most ELD solutions are cloud-based, the records are not required to be physically stored and can be accessed easily at any point of time by authorized users.
  2.  Fuel Management: ELDs when integrated with fleet management applications, provide information regarding idle time and help in planning better route options. This information can be used to reduce fuel wastage and save hundreds of dollars each month.
  3. Vehicle Health: ELDs are installed in a vehicle through OBD port, which allows them to generate alerts whenever a fault in the vehicle’s diagnostic is identified. With proper analysis of data hence available, a maintenance plan for vehicles can be created as a preventive measure.
  4. Driver behavior: ELD offers to track driving behavior and records occurrences of hard braking, speeding, and more. Drivers frequently engaging in bad driving can be warned and given proper training. Identification of high-risk drivers in a fleet and providing them with better guidelines can also help in reducing the chances of accidents, as well as increase productivity. Rewarding good drivers can lead to motivation in others to perform well.
  5. Accidents and Liabilities: Often, when a truck or another commercial motor vehicle is involved in an accident, the truck driver is blamed for it. As ELD records data of driving behavior, it can be presented as evidence to prove the case in favor of the driver.
  6. IFTA Calculations: IFTA or International Fuel Tax Agreement is a cooperative initiative taken by 48 U.S. states and 10 provinces in Canada to unify the payment of fuel tax by truck drivers engaging in interjurisdictional travel under a single license. Prior to IFTA, the truck drivers had to apply for a permit as well as report and pay fuel tax to every state they traveled, separately. Most ELDs provide an automated calculation of IFTA, thereby reducing administrative work, and also ensuring that the calculations are accurate.
  7. Insurance: Several insurance companies offer discounted premium rates for vehicles and drivers that use ELD because they make the vehicle safer and easy to track in case of theft or hijacking.
  8. Safety: ELDs can track location, and alert operators and motor carriers in case of an accident, theft or hijacking. Also, as ELDs can monitor driver behavior, it leads to improved road safety and lesser accidents.

ELDs also help in following rules and regulations as laid down by FMCSA, DOT, and other related governing bodies. This can significantly improve CSA score and offer better work opportunities for drivers and carriers.

In conclusion, ELD definitely has revolutionized the trucking industry and improved fleet management. By opting for an ELD solution that is FMCSA-compliant, efficient, economic, and best suited to operational needs, any motor carrier and driver can make their business process more profitable.

Matrack Incorporation has been equipping various commercial vehicles with technologically advanced, easy to install ELD and fleet management solutions. Our experience of over a decade in the trucking industry can be visualized in our constantly upgraded hardware and software applications. We offer solutions that are perfect for any motor carrier and driver. Our USP is round the clock valuable customer service and FMCSA compliant devices and applications. To know more about our services and products, feel free to contact us. We will be delighted to assist you!

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