The mandate for installing and using electronic logging devices (ELDs) in commercial vehicles became a reality on December 16, 2015. Unless your company is currently using automated on-board recording devices (AOBRD), it is important to begin or finalize the process soon. This is meant to be a summary of information contained in the rule. Be sure to review the rule and seek any legal advice from counsel. This material contains suggestions, and companies should find an approach that fits their unique operations best. Read below to learn more about the Final Rule.
The Final Rule requires that most drivers required to complete paper logs must begin to use an ELD by December 18, 2017. There are a few exceptions, and we address those below.
- Drivers who are exempt from the hours-of-service (HOS) rules, such as government drivers and drivers of utility service vehicles
- Short haul drivers (100 and 150 air-mile radius drivers) using the timecard exception and not required to complete a log for more than 8 days during any 30-day period
- In-state-only (intrastate) drivers who are exempted by their state
- Drivers operating in a “driveaway-towaway” operation in which the vehicle being driven is part of the shipment being delivered
- Drivers of vehicles that were manufactured before model year 2000 since these vehicles were not required to have electronic control modules (ECMs) to which an ELD can connect
- Drivers who are using a compliant AOBRD by December 18, 2017, will not be required to use an ELD until December 16, 2019
Exceptions apply to very few operations, and it is best to be sure before claiming an exception.
While the requirement for electronic logging seems to be a long way away, it is not. The requirement will not impact the hours-of-service limits and therefore the hours a driver has available to drive, but it will make a huge difference for many carriers. Having drivers use an accurate technology-based time recording device, rather than pencil and paper, will lead to many carriers needing to make adjustments or outright changes to how they operate. It’s been said before, but it bears repeating: change takes time. The more planning and time you put into a change, the less stressful the change will be. On the other hand, the longer you delay the change, the more stressful the change will be. Since most drivers will have to use ELDs, providing a less stressful learning environment will greatly improve their learning curve and acceptance. Leading with training of operations personnel is the key to a successful transition.
Some carriers may try to implement quickly, skipping steps such as developing the “wants and needs” list, approaching several providers, checking out the different devices and systems available, vetting potential vendors, and making a final selection based on a competitive process. If there is not enough time to make the selection correctly, there is a chance that the company may end up with a system that does not match the company’s needs.
As the deadline approaches, vendors will be pressured to deliver devices. The problem is that due to the pressure, some vendors may not have the hours available to provide sufficient guidance while the customer is going through the transition. Currently, part of the training process involves having carrier personnel receive additional training to serve as super-users, mentors, and/or in-house trainers. These individuals develop a working relationship with the vendor; the relationship allows for the quick and free flow of questions and information. Unfortunately, it takes time to develop a super-user and for the super-user to develop a relationship with the vendor. There is also a risk that as customers wait, the vendors will not be able to service the flood of requests coming in due to supply and physical staffing constraints.
Another risk of delaying the transition is that the transition cannot be done smoothly. This could be due to speeding through some of the steps, skipping steps, or not having enough time to complete a step. Speeding through the transition may give the idea that you are not serious about it. If your drivers don’t see this as a serious change, what will they think? Could some come away with the opinion that this is “just a passing phase”?
To avoid poor communication and all of the other risks and problems discussed, it is important that carriers who have not begun the process of transitioning get started soon. Even small carriers, who can get through some of the steps more quickly, will require time to make the transition successful. Due to the risks and consequences involved, the last thing any carrier needs is to be hurried through the process.