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ELECTRONIC LOG COMPLIANCE

What Are The Requirements Of The Electronic Logging Device Rule?

    The ELD Rule:

  • Requires ELD use by commercial drivers who are required to prepare hours-of-service (HOS) records of duty status (RODS).
  • Sets ELD performance and design standards, and requires ELDs to be certified and registered with FMCSA.
  • Establishes what supporting documents drivers and carriers are required to keep.
  • Prohibits harassment of drivers based on ELD data or connected technology (such as fleet management system). The rule also provides recourse for drivers who believe they have been harassed.

What Are the Current Regulatory Requirements?

The current HOS regulations limit the average work week to 70 hours and require mandatory 30-minute breaks to ensure drivers have adequate rest. To comply with these regulations, drivers have two options for preparing logs that detail their shifts.
• Drivers can manually prepare paper-based logs using pre-printed forms.
• Under section 395.15 of the HOS regulations, drivers can use an automatic on-board recording device (AOBRD) to prepare hours of service logs.
If drivers use an AOBRD, it must be integrally synchronized with the vehicle and record engine use, road speed, miles driven, and date and time of day. The vehicle-derived data is only used to determine when the vehicle is being driven. The device must not allow the driver to make status changes while driving.
Additionally, if requested by law enforcement, an AOBRD must be capable of reporting:

  • Total driving hours
  • Total distance driven on any particular day
  • Total on-duty hours for 7 days, including the day the report is requested
  • Times and locations of duty status changes

The HOS regulations are expected to prevent approximately 1,400 crashes, 560 injuries, and 19 fatalities per year. That will result in an estimated $280 million in savings from fewer large truck crashes and $470 million in savings from improved driver health. Companies that operate fleets stand to be among the main beneficiaries, as employee accidents result in substantial costs for employers.

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Who Must Comply With the ELD Mandate?

All drivers covered by the current HOS regulations will be required to comply with the upcoming ELD mandate.
HOS regulations and the ELD mandate apply to:

  • Drivers of commercial vehicles, with or without a trailer.
  • Drivers who engage in interstate commerce. If the goods being carried will move between different states, the driver is engaging in interstate commerce even if the driver’s vehicle never crosses state boarders.
  • Drivers who engage in either interstate or intrastate commerce AND transport hazardous material that requires a placard.
  • Driver of vehicles that weigh 10,001 lbs. or more (including any loads) or have a total weight rating of 10,001 lbs. or more.
  • What Specific Requirements of the ELD Mandate?

    Carriers that still use paper logs must implement a compliant ELD system. Carriers that have already implemented AOBRDs must upgrade those devices to meet the new ELD standard.
    It is crucial that all effected carriers understand the technical requirements so that they can select the right ELD solution.
    These requirements include:

    • The ELD solution must have a direct connection with the vehicle’s engine if the vehicle was manufactured after the year 2000. Any black box or smartphone solution that does not include that direct connection will not comply with the mandate.
    • The ELD solution must include the capability to electronically transfer HOS data to law enforcement. Acceptable communication methods include wireless web services, Bluetooth 2.1, USB, email, and compliant printouts.
    • The ELD solution provider must be certified by the FMCSA. This means that the vendor must register with the FMCSA and document that its solution meets both the technical and performance mandates for the ELD mandate.
    • Carriers currently using an AOBRD are covered by a limited “grandfather” clause, which extends two years after the effective date of the rule–a total of four years from the time the final ELD rules are published.
    • Drivers that are required to keep Record of Duty Status (RODS), but fall under an Hours of Service exemption, such as short haul, are not required to use an ELD.