Remember the ELD mandate? It feels like we were just talking about it and now we are approaching a year with it in effect. Yet, there is one aspect still yet to take place, and that is the automatic on-board recording device (AOBRD) conversion. These devices were grandfathered in for two years when the ELD mandate was put into place, which means fleets now have less than a year to make the switch. As of December 16, 2019, these devices will need to be converted to ELDs.
And although the December 16 deadline may still seem far away, it is important that fleets begin the transition now, and there are several reasons why. For starters, it will take time to train truck drivers on the new ELD devices. When it comes to unassigned logs, yard moves, and data transfers, there is a learning curve that truck drivers will have to go through.
Second, fleets want to stay ahead of the competition. Making the move to an ELD before your competitors could give fleets an advantage over those that switch at the last minute. By the time the deadline hits, you want to have worked out all the kinks and figured out how to offset any productivity losses.
Finally, fleets can expect easier roadside inspections. The FMCSA eRODS software will receive data from ELD devices in a standardized format. AOBRDs thus slow down the inspection process and result in your truck drivers spending more time waiting on the side of the road and cutting into profits.
AOBRD vs ELD
No matter what, ELDs will be replacing AOBRDs. While there are some exemptions, electronic device logging is now the industry standard and it will continue o become a vital part of normal day-to-day operations. The good news is that ELDs offer many benefits, the largest being access to real-time data. Advanced ELD devices also allow fleets to monitor fuel usage, truck driver behavior, arrival and departure times, and more.
An AOBRD is pretty much the ELD’s precursor. These devices were created to remain in compliance with FMCSA regulation Section S 395.15. The AOBRD need only log time for hours of service purposes. An ELD, on the other hand, does so much more. While both AOBRDs and ELDs effectively record a truck driver’s duty status, ELDs do so much more.
Internal synchronization is much more clearly defined in ELDs. ELDs can also track duty cycle changes and record when the vehicle is in motion or not, as well as provide a graph of every duty status change. If there are any unassigned truck driver times or miles once logged in, the truck driver receives a warning. ELDs will also default to on-duty/not driving status whenever the vehicle is stopped for five consecutive minutes and the truck driver has not responded to the ELD prompts.
ELDs also provide truck drivers with two electronic options for transferring data. They can go through either a wireless web transfer or a web service and email. Another method is through a local USB 2.0 transfer or Bluetooth. Whichever method is used, the data is transmitted directly into the FMCSA’s eRODS database.
One of the major sticking points when it comes to transitioning to ELDs has been that of special driving categories. Special categories include personal conveyance and yard moves. With the new FMCSA guidance arriving November of 2017, ELDs must now be able to account for personal conveyance time even if the tractor-trailer is loaded up with freight. While the status is considered on-duty, it does not count towards a truck driver’s operational time limit.
ELDs can now also factor in unassigned truck driver time. The FMCSA requires that unassigned truck driver time records must be either annotated or reassigned to another truck driver. Since both the truck driver and the motor carrier are responsible for unassigned time, it is critical that ELDs are able to accurately record this information.
The fact is, ELDs must capture more data than AOBRDs. Whether it be the date and time, to an accurate location, engine hours or vehicle miles, ELDs must simply do more. In fact, the FMCSA even lists on their website all of the features that ELDs should have to remain in compliance. And while the FMCSA requires that ELD manufacturers self-certify, fleets must do their due diligence to ensure they are investing in a device that won’t result in a big fine.
Making a Transition Plan
For fleets or independent owner-operators transitioning from an AOBRD to an ELD, it is critical that one makes a comprehensive transition plan. Still, that does not mean it needs to be an all-or-nothing approach. By setting out the transition plan now, motor carriers can complete the process well before the December 2019 deadline.
First, a motor carrier will need to conduct a pilot program to review the different ELDs on the market today. They also need to make sure their fleet management needs coincide with the ELD they are choosing. Fleet managers will also need to select the truck drivers who form the first users for the pilot program. They will want to select truck drivers who are technology-savvy and motivated to try new things.
Once the truck drivers have been chosen, it will be important to give them a couple of weeks to train on the new ELD. Once they have been trained and feel comfortable using the device, they will be motivated to talk it up and help other fleet operators get used to it as well.
This initial step is called pre-deployment. This is when fleet managers reinforce the benefits of transitioning to ELDs and make sure that the fleet vehicles are ready to have the ELDs installed. This pre-deployment period is also a good time to review and update hours of service policies and make sure everyone understands that the goal is 100% compliance.
Once the pre-deployment period is over, the pilot program should begin. The truck drivers selected for the pilot need to be set up with accounts, know how to operate the devices, and ensure all the required documentation is in the cab of the vehicle.
There are two training sets that trucking companies must focus on. The first is truck driver training. Truck drivers need to understand the difference between the AOBRD devices they are used to and the new ELD devices. Trainers must be sure to emphasize everything from duty status changes to personal conveyance and yard moves, as well as how to complete proper data transfers and edits.
The next set of training should be for the back-office staff. They need to know both how the devices work as well as the ability to suggest changes to logs and ensure they can transfer logs if an audit is on the horizon. It is critical to remember that truck drivers are not the only affected party making the transition.
Ensuring Effective Training
To ensure a successful transition, fleets need to employ an effective training strategy. When focusing on training, the top areas should be making sure truck drivers know the thresholds for automatic duty status and how to successfully transfer data from the ELD if law enforcement is requesting it.
Even more than learning how the ELD works, truck drivers should also know how the ELD might malfunction. Fortunately, the FMCSA has also placed information on their website regarding what to do when an ELD malfunctions. Back office staff will also need to be educated on policies and procedures to follow if a malfunction occurs, as well as reporting processes.
A step-by-step approach to training staff on the ELD transition will be vital to making sure the transition goes down without a hitch. A plan needs to be laid out that outlines what steps need to be taken prior to deploying the ELDs, what truck driver training will entail, and what edits will need to be approved or allowed.
More than anything, truck drivers must be given enough time to learn the new devices and how to operate them. The last thing a fleet needs is to wait to the final minute when operators won’t have enough time to learn the devices and buy-in to the transition. If coaching and ongoing training is needed, it should be provided.
While making the switch from an AOBRD to an ELD may seem like a huge task, it doesn’t need to be. With the December deadline now less than a year away, all a fleet needs to do is put together a solid plan that involved basic training, planning and follow-through. With the mandate in full effect, there will be no getting around the need to ensure the right device is purchased and everyone in the organization is aware of how it works, and the processes associated with its usage.