After a long wait and much anticipation, the FMCSA has announced that it will issue its final ruling on the electronic logging device mandate in late September 2015.
It’s time to determine, “Do I need an ELD?” And, “Even if I’m exempt, what’s all the fuss about?”
Who the ELD Mandate Applies To
Preliminary information indicates drivers will be required to use an ELD if they are required to keep Records of Duty Status. (RODS). The FMCSA estimates 3.0 million vehicles and 3.4 million drivers will fall under this ruling.
So how do I know if I need to file Record of Duty Status (RODS)?
Most drivers must follow HOS regulations if they drive a commercial motor vehicle. If you are involved in interstate commerce, you must comply with HOS regulations if:
- Your vehicle is 10,001 pounds or more
- Your vehicle has a gross vehicle weight rating or gross combination weight rating of 10,001 pounds or more
- Your vehicle is designed or used to transport 16 or more passengers (including the driver) not for compensation
- Your vehicle is designed or used to transport 9 or more passengers (including the driver) for compensation
- Your vehicle is transporting hazardous materials in a quantity requiring placards
All carriers answering “yes” to the above are required to keep a 24 hour RODS, unless you are utilizing an exemption to operate as a:
- Driver-salesperson, where your total driving time does not exceed 40 hours in any period of 7 consecutive days
- Oilfield carrier, focused on transportation and usage of oilfield equipment like the stringing and picking up of pipe used in pipelines or well-site construction
- Short-Hauler, CDL drivers that operate within a 100 air-mile radius of the normal work reporting location or Non-CDL drivers operating within a 150 air-mile radius of their home depot
Even with exemptions, time sheets that show start and end times must be kept. Whether legally required to do so or not, safety conscious carriers will utilize full RODS in order to provide uniform safety rules across the fleet while gaining insight into detailed operations – leading to more control and protection where it’s needed. Remember is you cannot adhere to the exemption rules you will be required to keep RODS for those days.
Big Fleet, Small Fleet – You Still Must Comply
Whether you are the largest fleet in the country, or a one person Owner/Operator, if you file RODS, you will need an ELD.
Larger fleets and Owner Operators who have already adopted Automatic On-Board Recording devices that meet the standards see safety, compliance, and paperwork savings today – and it’s important to note that their device is grandfathered through 4 years after the publishing of a final rule.
What you can do now
In evaluating where to require ELD devices, the FMCSA weighed a variety of criteria prior to making a decision around the mandate. They found the paperwork savings alone would account for a positive economic input, and followed its SNPRM evaluation with further studies showing the positive safety benefits of ELDs.
That being said, many carriers voice concern at adopting an ELD solution today, and instead prefer to “wait for the mandate.” Understandably, it can mean a significant cultural shift for an entire organization to implement processes that give a new level of insight into actual operations. However, the advantages of moving to electronic logs and fleet management solutions today instead of waiting are compelling. In addition to getting a jump on the process instead of waiting until you’re “up against the wall,” you can:
- Build a culture of safety compared to “just enough” compliance. E-Logs give safety managers the tools they need to understand all areas of compliance. Safety mangers and dispatchers can work together on loads that are within HOS requirements. Drivers can be alerted when low drive or on-duty time is near
- Start immediately building ROI: slash fuel costs, drastically reduce paperwork, increase driver communication, and charge for detention time
- Accurately account for all aspects of the business, including on-duty and drive time. Fleet managers can see where time may be leaking from current processes
- Roll out technology at a pace comfortable to you, not a time frame established by the government
- Added benefit of almost eliminating Form and Manner Violations which is continually the highest frequency of issue Inspection Violations for Hours of Service
These, combined with the 4 year grandfather clause for already-implemented systems, leave fleets wondering, “What am I waiting for?”
As more information about the mandate comes out over the next few months, fleets will continue to get better clarity around what is expected from them, and how they can benefit from implementation of an ELD. To keep up to date about the ELD mandate and how it affects you, visit eldfacts.com, an important new information site designed to foster industry understanding of this critical legislation.