The date has come and gone and yet there are still plenty of trucking companies out there that have not yet made the switch from AOBRD to ELD. Well, let this be the Quick TSI blog’s last primer on what you need to do to make the switch and why it matters. After this, it is up to you!
A deadline is only as flexible as its breaking point. Among the least flexible are compliance dates for government regulations. And when you have a fixed date for a final rule that no one in a federal agency or in Congress has the desire to slacken even a tad at the 11th hour, you have a deadline so tight that violating it will snap back at you very quickly and could result in fines or other actions.
A Look at the Data
As of December 17 of last year, amidst the freight-happy holiday shopping season, every carrier operating in the U.S. that is not exempt from keeping truck driver logs must have a functioning ELD onboard its trucks, per the final rule issued in late 2017 by the Federal Motor Carrier Safety Administration.
And although some trucking companies interpreted it as such, the agency’s intention to ease the changeover burden with the two-year grandfathering was most certainly not to encourage waiting until the last minute to comply. On the other hand, one’s definition of “last minute” can vary widely by such factors as general ignorance, risk tolerance, over confidence, and fear of change.
A recent survey conducted in 2018 found that one in three fleets were not yet ELD-compliant. When the survey was repeated in the spring of 2019, that number was down to one in eight. Now, some unofficial surveys point to around 15% of trucking companies left who have not adopted an ELD policy or made the switch from an AOBRD.
It seems that the larger fleets — 500-plus vehicles — are for the most part done. It is primarily the smaller fleets that haven’t yet complied. A lot of them struggle with whether to go with a bare-bones, compliance-only tool or something full-featured that requires a larger upfront investment but has the potential to pay for itself over time. The most important thing is to have a plan. The main reason being that some AOBRDs are ELD-ready — but there are others that are not.
Waiting even longer to make the transition could potentially result in a lack of driver training/acceptance and reporting glitches as well as last-minute capital expenditures if required to upgrade devices.
Still, for many fleets the delayed transition could simply be the result of confusion about the underlying technology, where fleets may have questions about what the transition requires them to do, like fully transition all hardware in a fleet versus only a few vehicles. This is especially true for smaller fleets that might be working with a decreased revenue stream.
Other Important Considerations
Trucking companies should have already finalized their implementation and transition plan. Fleets need three to four months to get fully implemented and more importantly, to get your truck drivers trained. Ample time is especially critical for larger carriers that have multiple terminals. There really is no reason why large carriers with more resources are not already switched over.
Smaller carriers may experience issues if they choose to wait even longer. It’s a big change, and ELD providers are already dealing with a high level of support from client carriers. When the mandate started in 2017, the technical support departments at ELD vendors inadvertently became many motor carriers’ ELD training departments, meaning call wait times were longer than expected.
There is also the sunset of the 3G mobile network cell band to consider, which is expected to be done by 2022, according to AT&T. That will affect the use of some older [electronic log] units by this summer. In other words, if you are not careful, you could end up transitioning to ELDs twice in relatively short order.
And there will be a lot of training to do. Who’s going to be affected with training? It is going to be everyone at the company. And if you are a small carrier, everybody wears multiple hats, and you may have to have different disciplines and understandings of ELD and how that affects different people. But no matter what size you are, everybody needs to have participation in this migration.
Truck driver buy-in is a big pain point and it’s something that fleets should start on well in advance of the transition. It’s important for drivers to understand that ELDs are primarily for their own safety — for tracking hours of service so that overworked and exhausted drivers aren’t on the road.
You Have Options
One way to comply with the electronic logging device mandate is to issue drivers a connected tablet uploaded with software to provide ELD functions along with GPS navigation and other features. For example, Samsung offers an ELD bundle that combines its Galaxy Tab Active 2, Tab A or Tab E tablets, which includes its built-in “defense-grade” Knox security platform and choice of 4G LTE or wi-fi connectivity; and Omnitracs XRS Relay software license.
However, portable devices must be mounted in the cab while the vehicle is in use. The ELD regulation notes that a portable ELD must be mounted in a fixed position during vehicle operation and visible to the driver from a normal seated driving position. That’s why the Samsung ELD bundle also includes a Ram Mounts IntelliSkin tablet case and vehicle dock, both of which deploy that firm’s GDS technology, and a step-down converter charger.
Ram’s GDS platform provides protection, charging, and data-sync compatibility across a range of phones and tablets. Mounting is done through various methods, including a ball-and-socket system with a high degree of adjustability and vibration dampening. Other options include drill-down, adhesive, suction-cup and Ram No-Drill bases for securing the mounting system.
Another company called GPS Lockbox, says that along with its original Flex cradle, which features a “quick-docking” locking mechanism and a magnetic charging system, GPS Lockbox has developed its Atmos cradle to handle the high temperature variances trucks can encountering operating across the U.S. Both the Flex and Atmos cradles work with the firm’s Flex tablet-mounting system.
According to the company, Atmos was the first temperature-regulation system designed for vehicle-mounted tablets. They say it is engineered, not only to prevent tablets from overcooling in cold temperatures, but it is also capable of restoring an overheated tablet eight times faster.
Support Your Support Staff
It’s important that the administrative staff knows how to properly set up driver accounts with necessary information, such as names and DOT numbers. Discuss potential ELD malfunctions that might occur and ensure your back-office team knows what to do when malfunctions are reported by drivers. You should also train staff on how to maintain supporting documents and records in the event of an FMSCA audit.
Inspectors can collect supporting documents to verify the accuracy of driver RODs and HOS rules compliance. Per the FMCSA guidelines, motor carriers must retain a maximum of eight supporting documents for every 24-hour period a driver is on duty. Motor carriers must also retain RODS and supporting documents for six months as well as a backup copy of the data on a separate device.
Insufficient training of a motor carrier’s back office is an even greater risk than insufficient training of truck drivers. This is mainly due to daily processing of unassigned drive time, editing process changes, malfunction reporting and logging changes, and generally not being able to help the drivers if the back office isn’t comfortable with the differences between AOBRD and ELD systems.
If shop technicians have not had time to be trained, there is also the risk of ELDs remaining in malfunctioning status. Mechanics will need to have troubleshooting knowledge that is above the complexity of AOBRDs, with additional malfunction codes and potential issues with ‘flashed’ or reset electronic control module parameters.
With AOBRDs, recorded events can be changed or edited by back-office staff or drivers, but with ELDs, logged events can’t be adjusted, and drivers have the final say. However, in some cases, truck drivers and managers can leave annotations or notes instead of editing logs to mark things such as technical difficulties or mistakes in logging. These are all processes that should be fleshed out in established policy and shared with the entire team.
The fact is this: The deadline has passed. We are now looking at six months out from the final, final ELD date. Might this be the last time we provide options and warnings for trucking companies who have not yet made the switch? Perhaps. Because in 2021 the ELD will be turning into old news and it is expected that any trucking company have it as part of their standard operating plan.