Flip a switch. Seems easy enough, but for those truck drivers and fleets that think that’s all they have to do with their electronic logging device (ELD) come December 16, 2019, they may quickly find their truck driver sitting idle with a non-compliant ELD. Why? It turns out that switching from AOBRD to ELD is not the difficult part, it is the learning curve that trips up so many, and a mistake there can result in a driver being put out of service by enforcement personnel for not meeting the ELD regulation.
A CarrierLists survey earlier this year conducted on behalf of FreightWaves found that 40 percent of respondents are still running AOBRDs, and 52 percent of those responding plan to complete their conversion to ELDs in the fourth quarter of this year. A surge of conversions at the last minute could complicate the process and leave well-meaning fleets non-compliant, which is why many providers are urging AOBRD customers to make the switch now. J.J. Keller has published a guide to help fleets with the planning process. The “2019 Hours of Service Blueprint: Your Strategy for Meeting the Final ELog Deadline” addresses questions on topics such as what is involved in switching, how to know if you are using an AOBRD or ELD today and future system requirements.
The company is also scheduling sessions with its AOBRD users to assist with the transition and driver training. Many AOBRD users, such as those with J.J. Keller devices, can make the switch to ELD compliance with a simple over-the-air update, while other providers may need fleets to acquire new hardware. Even those switching over-the-air, though, still need training on how to properly use an ELD.
There is no singular process, which makes planning even more critical. Ensuring compliance and that there is no interruption for customers means dealing with the ELD switchover sooner rather than later. Here’s why you should start the changeover now.
1. You may have hardware, but that doesn’t mean you have an ELD
Some drivers may think they are using an ELD but are, in actuality, using an AOBRD. Determine first which device you have, and if you have an AOBRD, is it one that requires just an over-the-air update or do you need a new device? ELD providers are required to “self-certify” their devices to meet the technical requirements of the rule. The Federal Motor Carrier Safety Administration (FMCSA) maintains a list of these devices. Choosing a device not on this list is the equivalent of not having an ELD at all – a violation. Just because it is on the list, though, doesn’t mean it is compliant. Reputable providers should be able to demonstrate that their devices meet all the requirements, including the ability to transmit data through a local transfer (USB or Bluetooth) or via a telematics system.
2. An ELD will change how you manage your operation and you need implementation and adjustment time
An ELD will impact your operations, and you need to know what those impacts will be before they happen. At the first deadline, fleets suffered through unnecessary delays, missed delivery and pickup windows, and business pain as drivers and management adjusted to the new set of technical specifications and regulations. Adapting to these changes may require additional training on how to effectively use this new data the ELD device will generate. With early-adopter fleets, those who ran freight lanes in the 500-mile to 700-mile range saw significant impact. Because of stricter adherence to allowable driving hours, many of these routes turned from one-day runs to two-day runs. If your fleet runs in this range, making the switch to an ELD sooner will provide additional time to make structural schedule changes and communicate the reasons for those changes to customers.
3. It’s not just a flip of a switch, there is training involved
Depending on the size of your operation, transitioning may take only a day or two, or weeks or months. How many vehicles/drivers do you have? Do you need to install new hardware devices or is a software download to a tablet or smartphone sufficient?
When scheduling your AOBRD to ELD transition, consider driver schedules and customer schedules. These considerations can add significant time to the conversion process. If you are working with the device provider, that needs to be factored into the process as well; they are juggling multiple customers and need to be able to provide support to all. Waiting to transition will shorten the timeframe, but it also increases the likelihood your provider may be unable to provide a level of immediate support you need.
Many fleets have been tripped up by another issue that should be addressed in training. Each driver needs a unique ELD log in, as will any technicians or anyone else that may drive a vehicle. When a technician test drives a vehicle after repair, if they don’t have a separate ELD login, that unidentified driving time could be mistakenly charged to the next driver. This can happen if the unidentified driving time is not properly rejected by the next driver to log into the ELD and the back office properly processed the event. That is just one of the many training situations that must be covered. Depending on how the ELD will be used, there may be additional training required, and that includes non-driving staff that would be interacting with the ELD data – down to and including accounting and sales personnel who may be able to use the insights ELD data provides to improve customer scheduling and improve bidding processes.
Depending on the company and the provider, training can take several forms. The fleet may conduct the training at a single time and location or through smaller group sessions either in person or online; or the provider may offer training (this is more likely for fleets that do not wait until the deadline to switch to ELDs) onsite or via webinars.
According to FMCSA, drivers have several things they must know regarding an ELD. Training should start with these basics:
Respond to unassigned driving hours the ELD records
Record duty status changes
Add notes to records to explain any edits or additions
Certify records – to indicate that they are complete and accurate
Access RODS data from the ELD
Review and understand the ELD printout/display information
Transfer ELD data by email or Bluetooth to inspectors or law enforcement
Identify and correct or report data diagnostic issues
Report ELD malfunctions
There are also several document requirements drivers must follow, as well as certain documents that must be kept in the vehicle at all times, and they must be trained on this as well.
FMCSA has a rundown of what drivers should be required to do at: https://www.fmcsa.dot.gov/hours-service/elds/using-elds.
Are you taking full advantage of your ELD?
When deploying ELDs, users should consider how they will be used – do you just plan on monitoring driving hours, or do you expect additional benefits? Basic systems will provide the required hours-of-service compliance, but more robust systems can offer additional benefits for fleets, including vehicle inspection reports, driver qualification recordkeeping, idle time reporting and payroll assistance. GPS data might be used to track vehicles (eliminating check calls), for instance, or to document detention time. Given this data, fleets may be able to gain some leverage with shippers for more flexible delivery/pickup windows or through better rates or detention pay.
ELD data can also help with possible insurance premium reductions as fleets can use the information to show their level of safety.
There is also likely to be an administrative burden lifted as some ELDs, used with a larger management system, can auto-populate back-office systems such as payroll and International Fuel Tax Agreement (IFTA) reporting. ELDs do bring a new set complexities including the management of unassigned driving events and how edits and log annotations are managed.
There is a learning curve related to how to use them and how they alter your business operations. How long that learning curve is will depend on the individual and waiting to the last minute could be detrimental to the productivity of your operation.