Mandatory ELECTRONIC LOGGING DEVICES

The end of the year will be here before you know it. It’s time now to begin discovering what is expected of you to be compliant with Electronic Logging Devices.

Beginning on December 18, 2017, motor carriers required to maintain records of duty status (RODS) must select compliant Electronic Logging Devices (ELDs), and ensure they are installed and drivers and administrative staff are trained to use them (December 16, 2019 for carriers using AOBRDs). Additionally, motor carriers should know how to annotate and edit RODS, certify RODS, and collect required supporting documents.

ELD Requirements

Devices must be synchronized with the Engine Control Module (ECM) to automatically record the following:

• Engine power status
• Vehicle motion status
• Miles Driven
• Engine hours
• Date & Time
• Geographic location information
• Must have a display or printout function
• Must have a wireless connection or be able to locally transfer data via USB and Bluetooth®
• Must have volume control or mute option for any audio feature

Supporting Documents

The ELD Rule still requires drivers and carriers to retain supporting documents (in paper or digital format) to verify HOS compliance. Drivers must submit all their supporting documents to their motor carriers, and motor carriers must retain (not more than eight) supporting documents for each 24-hour period that a driver is on duty.

Document Types

Bills of lading, itineraries, schedules, or equivalent documents that show the starting and ending location for each trip;

• Dispatch records, trip records, or equivalent documents;
• Expense receipts (meals, lodging, fuel, etc.);
• Fleet management system communication records;
• Payroll records, settlement sheets, or equivalent documents showing payment to a driver.

Required Information

Each supporting document must contain the following information: Date, time and Location (including the name of the nearest city, town, or village); driver name (or a carrier-assigned ID number) that allows the carrier to link the document to the driver. The vehicle unit number can be used, if that number can be linked to the driver.

Editing and Annotating Records of Duty Status

Limited editing is allowed to correct mistakes, enter missing information, and provide notes or explanations (annotation) for ELD records. All edits, whether made by the driver, or suggested by the carrier, must be annotated.

Driver Certification of RODS

The driver must certify each RODS. A driver must certify any edits he/she makes; and should certify carrier edits if they are accurate. Certification is intended to protect drivers from unilateral changes to the RODS.
Carrier Retention of ELD Information
Carriers must retain original ELD information (on the device, or on a separate back-up system) for at least six months, along with the associated required supporting documents. Carriers must ensure ELD information is stored with appropriate security, to protect driver privacy. Carriers must also provide drivers with access to the records, on request, for a period of six months.

Displaying and Transferring Data

Starting on the compliance date, enforcement officials may request access to RODS through data transfer. An ELD must be able to either: Transmit data using wireless Web services and email, or Transfer data locally using a thumb or flash drive (USB2.0) and Bluetooth®. Installation of these units is a bit cumbersome, but not so much that you couldn’t do it yourself. Basic installation for most units consists of locating, connecting and routing the adapter cable to the ECM and the ELD module and (in some models) connecting the Bluetooth® connection. Check the FMCSA website for a list of registered ELDs.

When choosing a compliant device, you will have two basic options. 1) a unit designed only to track HOS requirements; and 2) a management system (requiring a wireless web connection) that includes tracking, monitoring and mapping options. Some devices do not include a tablet. Instead, carriers connect their own tablet or phone to an application via Bluetooth®.

The costs vary greatly between the two. For example, with both systems you will be charged to lease or purchase the connection equipment and with a management system you also pay a monthly fee for the connectivity and the additional system features. Lease/purchase charges can start around $100 and monthly fees can start as low as $15.

IMPORTANT: a smartphone or tablet alone will not meet the ELD requirements. A device must be “integrally synchronized” with the truck’s engine to comply.

Docket No. FMCSA-2010-0167