1 ELD Mandate Review Tom Cuthbertson TTA Safety Management Council and Maintenance Council Omnitracs, LLC. All rights reserved.
2 Agenda Final ELD Mandate Timeline What is in ELD Mandate Supporting Documents Changes in the final rule o Who must comply o Enforcement transfer requirements o Display requirements What is in the final rule? o Driver control of RODs o Security / Certification requirements Operational Considerations
3 ELD Short Glossary of Terms AOBRD Automatic Onboard Recording Device DOT Department of Transportation ELD Electronic Logging Device EOBR Electronic Onboard Recorder FIPS Federal Information Processing Standards FMCSA Federal Motor Carrier Safety Administration
4 ELD Short Glossary of Terms HOS Hours of Service NPRM Notice of Proposed Rulemaking NIST National Institute of Standards and Technology OMB Office of Management and Budget OST Office of the Secretary of Transportation PKI Public Key Infrastructure Encryption Certificates RODS Record of Duty Status SNPRM Supplemental Notice of Proposed Rulemaking
5 ELD Mandate Final Timeline AOBRD Automatic Onboard Recording Device December 16, 2015 Final published December 2017 Compliance date January 16, 2016 Effective date December 2019 Last date to be able to use AOBRD AOBRD can be installed from any time before published date up to the compliance date..transfer of AOBRD after compliance date not allowed
6 Final Federal Register Dates Prohibition of Coercion o $16K Penalty - 11/30/2015 ELD Mandate used of electronic logging devices o Final date 12/16/2015
7 What is this ELD Regulation? Does not change Hours of Service Technical update Address Harassment Supporting Documents Security More formal Certification Information electronically transferred to enforcement
8 Definition of an ELD 1 ELD Function describes an ELD as follows: The ELD discussed in this appendix is an electronic module capable of recording the electronic records of duty status for CMV drivers using the unit in a driving environment within a CMV and meets the compliance requirements in this appendix. This means that any and all components that are required for compliance in an ELD will have separate certification and registration Omnitracs, LLC. All rights reserved.
9 Supporting Documents Submit employer supporting documents 13 days of either the 24-hour period to which the documents pertain or the day the document comes into the driver s possession, whichever is later. TYPES OF DOCUMENTS IDENTIFIED Each bill of lading, itinerary, schedule, or equivalent document that indicates the origin and destination of each trip; Each dispatch record, trip record, or equivalent document; Each expense receipt related to any on-duty not driving time Each electronic mobile communication record, reflecting communications transmitted through a fleet management system; and Each payroll record, settlement sheet, or equivalent document that indicates payment to a driver. 8 Documents in 24-hour period
10 Supporting Documents Cont. Each Document A. Driver or Tractor ID B. Date of transaction C. Location of transaction D. Time Zone Fewer than 8 containing elements if have A,B,C qualify
11 Who is Affected? Who is Affected? Any driver that is required to keep Records of Duty Status (approx. 3.1 million) o Includes drivers who keep RODS for more than 8 days in any 30 day period. Short haul regulation remains the same, no RODS required o Includes rental equipment (no reference to short term rental) Exemptions Vehicles manufactured prior to 2000 o Answer to mechanical engines comment RODS still needed o If truck has ECM, may use ELD Driveaway - Towaway, provided the vehicle driven is part of shipment, RV, Motor Home Fast Act If using RODS less than 8 days in 30
12 Introduction of Events Login/Logout Power-up and Power-down Yard Move Personal Conveyance Intermediate position Diagnostic Event Malfunction Event Omnitracs, LLC. All rights reserved.
13 Display Options in Final Rule Increase Additional Information Vehicle VIN Beginning and Ending Odometer and Engine hours Driver CDL # and State Exempt status Data Diagnostics ELD Malfunctions Unidentified Driver Records Body of Log Detail to display all events and duty status DISPLAY STILL VALID for Roadside Inspection if can be viewed without enforcement entering the vehicle Omnitracs, LLC. All rights reserved.
14 New Display Requirements Display Options in Final Rule Increase
15 ELD final rule Yard Moves Not Drive, Only On-Duty Drive Starts at up to 5 MPH Only Auto On-Duty when stopped 5 minutes Driver Interaction Traffic Considerations Proposed item of Interoperability between providers Significant More Driver Control Create transfer file for roadside - erods ELD must be repaired within 8 days.
16 erods File Transmission Acceptable methods to transmit data Telematics Transfer Method Web Services SMTP Or Peer to Peer Transfer Method Bluetooth Web service local network USB 2.0 Safety official will select method Enforcement must be capable of one from each
17 Driver Log Certification Drivers must certify logs 24 hour of operation Must certify log edits even if out of window of the 8 days When accepting or rejecting back office edits - annotation Omnitracs, LLC. All rights reserved.
18 ELD Final Items Specific For Drivers (address harassment) Allow drivers to edit their logs and create annotations on all entries and edits cannot reduce drive time Drivers must approve all edits from Support Systems before applied Require that drivers have direct access to the log information Personal Conveyance do not record all engine information 10 mile accuracy on GPS Audible muting of devices by driver Driver reviews unassigned vehicle moves Daily certification of logs and for all edits - by driver or carrier
19 ELD Certification Process ELD providers register their ELD with FMCSA Request a user account Register an ELD Provide required information Device Name, Model Number, Software Version, ELD Identifier, Image, User Manual, Company, Contact Company (Phone), Contact Company ( ), Company Website Self-certify that the ELD meets the technical spec Process to update when modifications made
20 ELD Certification Process FMCSA will provide Authentication key(s) Authentication file(s) Registration number Used in ELD log file for verification Currently available for certification
21 ELD Certification Process Shortcomings of the Process Anyone can claim to be certified Anyone can register an ELD If FMCSA finds that an ELD listed on its website does not comply with the technical specifications, FMCSA may initiate removal of an ELD model or version from its list by providing written notice to the ELD By then it may be too late for the carrier that may have spent tens of thousands of dollars 454 page test document to pass
22 Transfer Security Telematics Transfer Method Web Services SMTP Peer to Peer Transfer Method Bluetooth USB 2.0 Web Service and FIPS publication 197 NIST SP Bluetooth Discoverable Generate random code USB thumb drive AES 256 Security
23 Unassigned Driving Time Unassigned Driving Presented to Driver What are operational causes? Driver forgets to login Mechanic road test Relocating tractor to another yard not by driver Correction after the fact Upon login, a driver is prompted to accept or decline unassigned driving time Any declined time must be reconciled by carrier by annotating the record
24 Unassigned Driving Time ELD states each driver needs a driver ID Prevention EXEMPT DRIVER Create login for each use of vehicle Mechanics that road test have CDL Relocation of vehicles Make sure drivers log in Devices can provide warning upon wheel move EXEMPT DRIVER CAN BE USED FOR SHORT HAUL
25 Auto Duty Status & Yard Move Drive From any other duty status to Drive when motion is detected and the speed reaches a maximum of 5 MPH There is NO TIME / NOR DISTANCE consideration On-Duty From Drive after 5 minutes of no detected motion and after 1 minute of driver being prompted Yard Move this an event that the driver puts themselves in as a duty status In RODS it is to be recorded as on duty time and NOT DRIVE
26 Yard Move Shortcomings of the event There are no limits around it There are no defined thresholds for it There are no automatic duty status changes allowed Possible Solutions FMCSA only offers log editing as an alternative Vendors could implement warnings around it
27 Recent FMCSA Verbal Communications Discussion on AOBRD grandfather Discussion on Web Services certification Omnitracs, LLC. All rights reserved.
28 Join the Conversation Today! Omnitracs, LLC. All rights reserved.
29 Frequently Asked Questions What about gliders? VIN number Where can I use yard moves? Are there specific mounting requirements for the ELD device? What happens when a driver is in a break and is forced to move the vehicle? ELD and Short Haul? How should we handle rentals? What restriction on fleet management systems? Shipper makes leave out of hours?
30 QUESTIONS? Omnitracs, LLC. All rights reserved.