For fleets whose trucks use AOBRDs (Automatic On-Board Recording Devices) to track driver hours-of-service (HOS), the deadline to transition over to ELDs (Electronic Logging Devices) is Dec. 16, 2019 – but the time to act is now.
The call for immediate action has come from U.S. Transportation Secretary Elaine Chao, from Federal Motor Carrier Safety Administration (FMCSA) Administrator Ray Martinez, and from Collin Mooney, executive director of the Commercial Vehicle Safety Alliance (CVSA).
Why? December 16 may be the legal deadline to switch to ELDs – but it can take time to get it done and done right. As of the deadline, trucks not equipped with ELDs or truck drivers not trained in using ELDs and transferring data to law enforcement risk receiving citations.
Citations can impact a carrier’s safety record – which may disqualify a fleet from participating in electronic bypass programs like PrePass.
How many trucks still have AORBDs? No one quite knows. AORBDs were approved by FMCSA beginning in 1988, following petitions from larger, technically-advanced motor carriers. Those carriers, in turn, have lots of trucks. Because those carriers made the early investment in HOS technology, they were granted extra time to adopt ELDs. The time that runs out soon and is not expected to be extended.
Many carriers and drivers may not be sure if they have an AORBD or an ELD. The differences are basically between generations of other technologies. See this comparison chart from FMCSA. In the meantime, the transition must be made, so let’s take it step-by-step:
Step 1 – Contact your HOS technology vendor.
Ask them if you have an AORBD and what model. If yes, what is the process to switch over from your particular AORBD to a compliant ELD? At least one HOS technology vendor says some AORBD models can be updated via over-the-air (OTA) transmissions. Other AORBDs will require a trained mechanic or technician to physically make the adjustments needed… which takes us to the next step.
Step 2 – Whether done OTA or physically, the switchover requires planning.
Over-the-air changes begin with a truck equipped to receive those signals. The truck must also be in an area with strong reception and stay there till the update is complete. The HOS technology vendor can provide that timeframe.
When the switchover is performed physically, the truck must be routed to the location where the work is to be performed – the carrier’s shop, a vendor facility or a third-party installer location – and stay there until completion.
Either way, the truck may be out of service (and maybe out of route) for some time, however short. That truck may be unavailable to handle freight and unavailable for use by drivers – you must plan for those impacts on your operations. Multiply those impacts by the number of trucks making the switch, and consider that the closer you approach the Dec. 16th deadline, the busier will be your HOS technology vendor’s customer service reps and the more likely a parts shortage may occur. Better start the planning and transitioning now.
Step 3 – Congratulations! Your trucks now have ELDs by the deadline, but you’re not done.
Your drivers must be trained on the ELDs. And your trucks, by regulation, must carry certain materials.
Drivers need to be trained in using your specific ELD. They must know how to log on and log off, how to edit mistakes, how to annotate those edits and explain yard moves and “personal conveyance,” and definitely how to transfer data to roadside inspectors. See this PrePass story for more discussion and information about common ELD errors.
That same PrePass blog also discusses the “ELD information packet” your trucks must carry:
- A user’s manual detailing how to operate the ELD.
- An instruction sheet describing the data transfer mechanisms supported by the ELD being used, and step-by-step instructions to transfer the driver’s hours-of-service records to a safety official.
- An instruction sheet with ELD malfunction reporting requirements and recordkeeping procedures.
- A supply of blank driver’s records of duty status (RODS) graph-grids to record the driver’s duty status and related information for a minimum of 8 days. Items 1, 2 and 3 can be in electronic form.
Finally, there’s one option to consider.
Perhaps it’s time to consider the PrePass ELD. It has all the electronic logging benefits you need, and nothing you don’t. Simple, secure, with great savings. Just plug the OBD device into your truck’s diagnostic port, download the app on your mobile device, log in, follow instructions and you’re done.
The PrePass ELD is fully compliant by the Dec. 16 deadline. For more information or to sign up, go to the PrePass ELD website.