EOBR Defined Success, Challenges and Embracing the Change

Transcription

1 EOBR Defined Success, Challenges and Embracing the Change 1 1

2 Session Learning Objectives 1. Understand FMCSA Rules and Update, Including Hours of Service for Commercial Drivers 2. EOBR to ELD (Electronic Logging Device) 3. Understand the Benefits of Utilizing ELD s and Practical Application/Integration into your Organization. 4. Realize the Value Proposition of ELD s 2 2

3 Session Speakers Deborah Freund FMCSA Glenn Bramer Trimble Scott Vanselous TMW Systems Henry Prentice (Moderator) Noregon Systems 3 3

4 Session Guidelines One Hour Session Presentations Questions & Discussion 4 4

5 Electronic Hours-of-Service Recording Devices Rules: Past, Present, Future Deborah M. Freund Senior Transportation Specialist Federal Motor Carrier Safety Administration 5 5

6 Outline of Today s Presentation History of legislation on HOS recording History of ELD and related rulemaking Highlights of Supplemental Notice of Proposed Rulemaking (SNPRM) Next Steps 6 6 6

7 Legislative Background Truck and Bus Safety and Regulatory Reform Act (1988) Required Agency rules on electronic recorders ensure that such devices not be used for driver harassment. HMTAA (1994) Required Agency HOS rules to specify number, type, & frequency of supporting documents to be maintained. MAP-21 (2012) Required Secretary to adopt rules requiring CMVs involved in interstate commerce and operated by drivers required to keep RODS, be equipped with ELDs. Set deadline for prescribing regulations by Oct. 1,

8 Rulemaking History 1988: AOBRD final rule : HOS NPRM proposed HOS recorders for long-haul/regional carriers; final rule did not include this provision : EOBR 1 rulemaking February 2011: EOBR 2 NPRM August 2011: EOBR 1 Final Rule vacated : MCSAC activity; listening sessions February 2014: ELD SNPRM 8 8 8

9 April 5, 2010 Final Rule New performance-oriented standards for recorder technology. Mandatory use of recorders to remediate HOS non-compliance. Incentives promoting voluntary recorder use. Applicable to all motor carriers in interstate commerce Mandatory only for carriers subject to Remedial Directive on/after June

10 February 2011 NPRM Drivers currently using RODS: Must use HOS recording devices; Would not have to maintain and retain certain categories of HOS Supporting Documents. All motor carriers (RODS users and timecard users) must maintain HOS management system Lead time: 3 years after publication of final rule

11 Court Decision to Vacate Owner-Operator Independent Drivers Association OOIDA filed suit in the Seventh Circuit to invalidate 2010 final rule. In August 2011, the Court vacated the rule based on FMCSA s failure to address the issue of driver harassment. For this reason, 2011 NPRM could no longer rely on April 2010 technical specifications for future ELD rulemaking

12 Overview of SNPRM Four primary components: (1) Prescribes minimum technical standards for ELDs; (2) Requires drivers who need to keep RODS to use ELDs, per MAP-21 direction; (3) Establishes explicit requirements for HOS supporting documents, specifying the number, type & frequency in accordance with statute; (4) Prohibits harassment of drivers and establishes a complaint process for drivers, due process for carriers, and civil penalties

13 Applicability MAP-21 (2012) Required Secretary to adopt rules requiring CMVs involved in interstate commerce operated by drivers required to keep RODS be equipped with ELDs. (Details to be added after SNPRM is published) 13 13

14 Timeline SNPRM published February xx, day comment period Comment analysis Development of final rule FMCSA, USDOT, OMB reviews Publication of final rule Implementation activities Compliance date 14 14

15 For more information Refer to Reg. ID No AB20 FMCSA website: USDOT General Counsel Significant Rulemakings Federal e-rulemaking Portal: Federal Digital System:

16 Electronic Logging Devices in Practice Glenn Bramer Marketing Director Trimble Construction Logistics 16 16

17 Electronic Logging Devices No Final Ruling yet, so EVERYTHING is subject to change What we do know: 1. ELD Requirements from MAP Who it applies to 3. Similar requirements in the European Union 17 17

18 ELD Requirements from MAP-21 Section (b)(1) Electronic logging devices (A)(i): to accurately record commercial driver hours of service; (A)(ii): to record the location of a commercial motor vehicle; (A)(iii): to be tamper resistant; (A)(iv): to be synchronized to the operation of the vehicle engine or be capable of recognizing when the vehicle is being operated; (B): Allow law enforcement to access data contained in the device during a roadside inspection Needs to be able to manage current inforce HOS rules GPS-enabled To ensure validity of collected data To automate collection of vehicle operational data Data needs to be portable, and available on-demand in the field 18 18

19 ELD Requirements from MAP-21 Section (b)(2) Performance and Design Standards (A) (B) Defining standardize user interface to aid vehicle operator compliance and law enforcement review Establishing a secure process for standardized (i) and unique operator identification; (ii) data access; (iii) data transfer for vehicle operators between motor vehicles (iv) data storage for a motor carrier (v) data transfer and transportability for law enforcement officials (C) Establishing a standard security level for an electronic logging device and related components to be tamper resistant by using a methodology endorsed by a nationally recognized standards organization (D) Identifying each driver subject to the hours of service and record of duty status requirements under part 395 of title 49, Code of Federal Regulations Everyone will be required to conform to minimum usage interface requirements Portability of data will be universal for all certified Electronic Data Loggers Electronic Data Loggers will have to be Tamper Resistant, conforming to a national standard Each driver will have a universally unique identifier 19 19

20 Similar solutions in EU In the European Union, digital tachographs became mandatory as part of EU Regulation 1360/2002, effective August 1, 2005 Although similar in some respects to ELD, digital tachograph requirements: Do not mandate recording location Do not have standardization regarding user interface Speed data is stored at 1-Hertz intervals, but not stored on driver s card Does require universally unique driver identification in the form of a EU Driver s License Requires motor carriers to report electronically both vehicle usage hours and individual driver hours Requires data to be delivered to law enforcement agencies by use of a special control card 20 20

21 ELD Value Proposition Scott Vanselous Chief Marketing Officer TMW Systems 21 21

22 Increased Value Obtaining Higher Value from ELD s Analytics Making sense of all the information take the right action at the right time Integration with Maintenance Systems What is going on with the vehicle? Integration with Dispatch Systems Communications between Operations and the Driver ELD s Electronic Logging Devices More features provide increased benefit 22 22

23 The Value of ELD s as standalone Automatic Capture of hours Driver and Vehicle Insight Increased data accuracy More hours to drive No paperwork, 15 1 min increment Less time at DMV Checkpoint GPS Positional data Speeding, Idling, Braking Tire Pressure Monitoring Systems Fault codes edvir s Pre/Post Inspection Compliance Conformance to Inspection Process 23 23

24 Integration with Dispatch Systems Planning based on available HOS Planning to maximize hours remaining Increase driver satisfaction higher pay Increase asset utilization less idle time In-Route Improve Driver behavior and performance Decrease out-of-route fleet tracking Early equipment diagnostics Confirmation of Delivery More accurate ETA s Driver Confirmation Message Automatic alerts via Geodocding 24 24

25 Integration with Maintenance Systems Fault code analysis and remedy Improved equipment performance Early detection of potential failures Automatically schedule work to be done Increase asset utilization less down time edvir s Automatically schedule work to be done Increase compliance higher CSA score 25 25

26 Analytics Operations Performance How did we perform to KPI s What was planned versus what happened Factors involved (e.g. equipment failure, non compliance, ) Driver Behavior Identify best and worst performers Reduce speeding violations Productivity Equipment Performance Predictive Maintenance reduce downtime Fuel Savings Fuel Tax Identify Cherries and Lemons in your fleet 26 26

27 ELD Value - Summary More than just Hours of Service (HOS) Higher Features = Higher Value Integrated with Operational Systems = Higher Value Analytics Provide tremendous insight to: Driver Performance Equipment Utilization and Performance Compliance Safety 27 27

28 Questions / Discussion Deborah Freund FMCSA Glenn Bramer Trimble Scott Vanselous TMW Systems Henry Prentice Noregon Systems 28 28