ELD Compliance Standard & Best s 2016 Safety Issues Update Soona Lee, Strategy & Market Development January 28, 2016 Monarch Hotel, Clackamas, OR eroad.com
Key questions in today s session 1. What is an ELD? 2. What is the differences between ELD, EOBR, AOBR and ELS? 3. Who needs it and who will be exempt? 4. When does it apply? 5. Should I comply now? What are the benefits of early compliance? 6. How to select the best ELD solution? What factors shall I consider? 1
Setting the regulatory scene
US Federal rule to mandate use of ELDs April 2010 FMCSA introduced technical specifications for EOBRs and mandated use by carriers demonstrating serious non-compliance with HOS rules August 2011 2010 EOBR rule vacated by Court of Appeal based on petition filed by OOIDA regarding issues around driver harassment. July 2012 MAP-21 enacted by Congress requiring FMCSA to adopt regulations requiring interstate CMV carriers and drivers be equipped with ELDs to record change in duty status. March 2014 In the SNPRM, FMCSA proposed technical standards and required use of ELDs for interstate CMV carriers and drivers. December 2015 FMCSA published Final Rule which address and incorporate comments submitted on the SNPRM by industry stakeholders. 3
Policy rationale for ELDs Improve compliance with HOS rules; Reduce paperwork burden associated with HOS record keeping; and Improve the quality of logbook data and reduce HOS record falsification. 4
Getting into the detail
1. What is an ELD? 6
Definition of an ELD 395.2 - Electronic Logging Device (ELD) means a device or technology that automatically records a driver s driving time and facilitates the accurate recording of the driver s hours of service, and that meets the requirements of subpart B of this part. Key requirements: Not necessarily a physical device but a technology platform Integrally connected to the CMV s engine to automatically track vehicle movement and operation Date, time and location automatically captured Satisfies display and data transfer requirements Resistant to tampering and ability to monitor compliance and detect malfunctions Allow for annotation by both driver and carrier to explain or correct records 7
ELD compliance requirements Must be registered with the FMCSA registry; and Must be certified by the provider that it meets all technical specifications. The ELD registry will be available from February 16, 2016. Technically there are only ELD-like devices in use today, as an ELD did not exist in regulation before today s rule. The Agency assumes that many ELD-like devices could be made compliant with the ELD rule at relatively low-cost, but existing devices would likely need some modification. 8
2. What are the differences between ELD, AOBR and ELS? 9
Comparing the technical specifications Features / Functions Engine connection integral synchronization Electronic Logging Device (ELD) SNPRM issued March 28, 2014 Engine power and hours, motion, miles driven ECM or other electronic device connected to CMV Recording location At change of duty status Engine on and off Every 60 min while moving unless Personal or Yard Use Automatic Driving status Default to Driving when CMV in motion Graph grid display Must be able to present graph grid on unit or print Timezone and drift Sync to UTC Absolute deviation no more than 10 min Automatic On-board Recording Device (AOBRD) 395.15 1988 Electronic Logging System (ELS) FMCSA guidance issued July 10,2014 Required but not defined Not required At change of duty status Manual or automatic At change of duty status Manual or automatic Not addressed Not required Not required Time and duty change sequence sufficient Must be able to present graph grid on unit or print Not addressed Not addressed 10
Comparing the technical specifications Features / Functions Electronic Logging Device (ELD) Annotations and edits Driver must accept all edits proposed by carrier Tamper resistant No alteration of original ELD records Require data integrity check functions Require record versioning Identifying sensor failures Capable of detecting malfunctions and data inconsistencies and gaps Audit record of these occurrences Enforcement and data transfer methods Display or print out Option 1 Telematics, or Option 2 Local connectivity type Automatic On-board Recording Device (AOBRD) Not addressed Driver or carrier edits Electronic Logging System (ELS) Not addressed Driver or carrier edits Must be tamper-proof Not addressed Must identify sensor failures and edited data Not addressed Outlined print out format Not addressed Display Print version to be available upon request 11
3. Who needs an ELD? 12
All drivers that require RODS must transition to ELDs Except for the following drivers: Drivers currently allowed to use timecards could continue to do so under 395.1(e) Drivers that are intermittently required to record HOS duty status (because they go outside of the specified short haul criteria), but for no more than 8 days in any 30 day period Drivers who conduct driveaway-towaway operations, where the vehicle being driven is the commodity being delivered Drivers of vehicles manufactured before model year 2000. 13
4. When does it apply? 14
Key dates Phase 1 February 16, 2016 Effective Date ELD providers with compliant product can register on the FMCSA registry Phase 2 December 18, 2017 Compliance Date ELD becomes mandatory for qualifying carriers and drivers Phase 3 December 16, 2019 End of AOBR Grandfathering / Full Compliance Date All drivers and motor carriers must abandon AOBRs and use ELDs 15
Compliance phases PAPER ELS AOBR ELD Phase 1 Awareness and Transition Carriers and drivers subject to the ELD mandate should prepare to transition and may voluntarily adopt ELDs. Phase 2 Phased-in compliance Unless carriers and drivers using AOBRs, must adopt ELDs. Phase 3 Full compliance All carriers and drivers must adopt ELDs. 16
5. Should I comply now? What are the benefits of early compliance? 17
Support drivers with HOS compliance Automatically generates required graph grid and RODS information Automatic alerts and messages to assist compliance with selected HOS rule set Electronically certify and submit RODS to carrier for real time recordkeeping 18
Go electronic and modernize Electronic record keeping in real time Ability to view and monitor total hours worked in the day and week to manage dispatch and job assignments Generate timesheet reports and upload to payroll system 19
Prepare and be ready for the transition Installation and setup of technology Training for drivers and support users Review of business processes to ensure compliance 20
EROAD Electronic Logbook solution 21
6. How to select the best ELD solution? What factors shall I consider? 22
Simpler the better Driver acceptance is crucial to successfully transition and manage the change from paper to electronic HOS compliance. Drivers are willing to accept ELD solutions that are: Intuitive and simple to navigate Reliable Able to assist drivers with compliance 23
Tailored to suit the business Technology must be adaptable and capable of supporting different types of business operations. Can the ELD support: Mixed fleets with pre and post 2000 vehicles? Owner operators? Leased trucks in the fleet for peak seasons? Team driving? Multiple terminals? Outsourcing back office administration? Personal and yard use? 24
Accurate, reliable and secure Inconvenience for drivers and carriers if the ELD malfunctions: Driver to revert to paper logbooks and reconstruct current and last 7 days to be carried to satisfy roadside enforcement Carrier to repair or replace ELD within 8 days of notification ELD solution must have self-monitoring functionality to detect malfunctions and data inconsistencies. Advanced solutions may include data back-up capability, additional data validations and enhanced encryption capability. 25
Strong core platform; multiple applications Cost effective and high ROI solution platforms: are highly scalable and agile modularized by application leverage higher security standards. EROAD uses one advanced technology platform to deliver electronic tax, compliance and commercial services. 26
Interstate Wood Products 27
Soona Lee Regulatory Compliance Manager Strategy & Market Development 971-804-3260 soona.lee@eroad.com 28