As the second phase of the Electronic Logging Device (ELD) Mandate ends on December 16, 2019, a new interim phase will begin. In this new phase, carriers and drivers that meet the ELD requirement criteria must be using ELDs that are self-certified and registered with the Federal Motor Carrier Safety Administration (FMCSA), or automatic on-board recording devices (AORBD’s) that were installed and in use prior to December 18, 2017. On December 16, 2019, all devices will need to meet the ELD final rule requirements.
As with any technology transformation, hiccups can be expected during this next phase of the ELD Mandate. For one, many AOBRD users are waiting until the fourth quarter of 2019 to make the switch. Fleets that waited until December of 2017 to initially implement ELDs/AOBRDs often experienced substantial delays and challenges with their implementations.
Additionally, moving from AOBRDs to ELDs will create hours of service (HOS) logging changes for drivers and changes in workflow for managers that will require education and time for adoption. It is important for any fleet that needs to make this transition to do so well before the expiration date to avoid creating unnecessary hardships for all stakeholders.
Major differences between AOBRDs and ELDs include:
- Recorded information: AOBRDs and ELDs both record the date, vehicle mileage, engine hours, location information and driver's duty status. AOBRDs are not required to record information about the driver, whether the vehicle is on or off, or engine diagnostics.
- Speed: ELDs automatically record drive time when the vehicle is moving at 5 mph or more; AOBRDs require operators to manually set a speed threshold that engages drive time.
- Edit functionality: AOBRDs and ELDs both record who made an edit and when. ELDs require every edit to include an annotation and edit history, available to DOT inspectors.
- Data transference: ELD data must be able to transfer via both wireless web services and email or via USB and Bluetooth. ELDs must also be able to display all standard data to roadside inspection officers via display or printout.
|Feature||1988 AOBRD Rule||2015 ELD Final Rule|
|Vehicle integration||Required||Interfaces with the CMV engine ECM to capture engine power status, vehicle motion status, miles driven, engine hours|
|Location information||Required manual or automated entry at: change-of-duty status||Required automated entry at: change-of-duty status, 60-minute intervals while CMV is in motion, engine-on and engine-off instances, start and end of personal use and yard moves|
|Grid display||Not required||Required|
|HOS driver messages||Not addressed||HOS limits notification is not required, "Unassigned driving time/miles" warning must be provided upon login|
|Device duty status||Not addressed||Defaults to ‘on duty not driving’ when vehicle is not in motion for 5 minutes or longer or if driver has not responded to an ELD prompt within 1 minute|
|Clock-time drift||Not addressed||Time must be synchronized to UTC, absolute deviation must not exceed 10 consecutive minutes|
|Resistance to tampering||Tamperproof||Tamperproof with increased monitoring capabilities|
|Identification of sensor failures and edited data||Must identify sensor failures and edited data||Must record compliance and monitor malfunctions or inconsistencies|
How should your team prepare?
- Partner with an ELD/telematics vendor that has an excellent reputation, a scalable platform that can grow with your fleet’s needs and provides extensive support. Items such as camera capabilities and compatibility with dispatch software may not have been part of the initial AOBRD consideration, but it should be now.
- Select a number of driver and dispatch champions that are familiar with the chosen platform and the differences between the AOBRD and ELD platforms. These individuals can assist with creating a positive culture of change and educating field personnel.
- Conduct formal training for all staff. Make sure drivers are knowledgeable about how to use the system before they leave the terminal. Make online training available for drivers having challenges in the field.
- Identify what is needed for physical installation and technology implementation. Consider who will carry out your installs and what the timeline will look like.
- Ensure there is positive communication between the dispatch and safety departments to address any initial concerns.
Contact your HUB transportation specialist for more information on transitioning to Phase II of the ELD Mandate.