ELD Changes and Considerations for Your Fleet

The FMCSA’s electronic logging device (or ELD) mandate does not affect current regulations, but rather is an attempt to standardize:

• In-cab devices
• Data being collected
• and how inspectors review and collect that data.

For more information on the ruling itself, go to the FMCSA’s website here: FMCSA ELD Rule Frequently Asked Questions

As an Omnitracs customer moving from an AOBRD for tracking your driver’s hours and duty statuses to an ELD, there are some concepts to keep in mind. Drivers must review and certify their logs and any carrier edits every 24 hours and there are no minimum duty statuses. All drive time must be accounted for, so there must be an active driver logged in any time someone moves an ELD-equipped vehicle.

Omnitracs supports multiple state and federal rules sets; and these are still available on our ELDs. You may allow drivers to flag drive time as personal conveyance and yard moves, but be sure to inform your drivers that, though they may edit their logs on the ELD, they cannot change their drive time. Additionally, neither personal conveyance nor yard may be edited to a non-driving activity. To prevent the accumulation of incorrectly assigned drive time, encourage your drivers to turn off the engine; then log out of hours of service and the ELD at end of trip, end of day, when swapping vehicles, or when swapping drivers.

Also, when you convert to ELDs, be aware that, per the FMCSA mandate, Omnitracs monitors for malfunctions and diagnostic events, including those related to GPS and the ECM, that your drivers haven’t seen before. Provide them with a list of possible alerts and troubleshooting steps to follow. If any malfunctions continue to be logged for eight consecutive days, the vehicle is out of service.

Vehicle inspections must be performed daily, and if drivers forget, they’ll see a popup prompting them to complete a vehicle and trailer inspection. After you complete the repair, drivers must acknowledge that the fix is complete or reject your fix and submit another report about the defect. Be sure to correct any defects quickly so that your equipment is safe to use.

As part of the conversion, you’ll need to:

• Ensure your firmware is upgraded to an ELD-compliant version
• Train your drivers and back office personnel
• Prepare for audits and inspections
• Enable ELD on your vehicles

Ideally, you would train your drivers in a single group so that your drivers would get the same message and start electronic logging at the same time. Though most functions are intuitive and easy to understand after a demonstration, some tasks are easier to learn with practice using a training ELD rather than trying to figure them out while in-cab, using a driver’s real logs. Companies that have the greatest success and fewest problems converting to ELD have held classroom training with a live, ELD unit so drivers can practice tasks like editing logs or entering load information without affecting their logs of record.

For ease of recordkeeping, Omnitracs suggests converting to ELDs on day one of a driver’s duty cycle. From that point, the driver should be ELD-only.

During an audit, you’ll need to provide driver’s logs and duty status for the time frame specified by the auditor. Our reports show both AOBRD and ELD data together.

If a road-side inspection occurs during you transition to ELD, some of those logs will be AOBRD and others ELD. The hours of service graph tab shows what type of device the driver is using. The driver is required to show the inspector the driver card and inform the inspector how to navigate screens to the header file and access inspector mode. Additionally, the driver must be able to send eRODS to the inspector if requested. Details of what the driver does during an inspection are covered in another video.

The last step is to switch your AOBRDs to ELDs, only after the firmware is updated, all personnel are trained, and drivers have the appropriate FMCSA mandated cab-cards with them.

About Omnitracs:

Omnitracs, LLC is a global pioneer of fleet management, routing and predictive analytics solutions for private and for-hire fleets. Omnitracs’ nearly 1,000 employees deliver software-as-a-service-based solutions to help more than 50,000 private and for-hire fleet customers manage nearly 1,500,000 mobile assets in more than 70 countries. The company pioneered the use of commercial vehicle telematics over 25 years ago and serves today as a powerhouse of innovative, intuitive technologies. Omnitracs transforms the transportation industry through technology and insight, featuring best-in-class solutions for compliance, safety and security, productivity, telematics and tracking, transportation management (TMS), planning and delivery, data and analytics, and professional services.

Efficient Fleets is proud to be an Omnitracs Authorized Dealer. We offer a complete set of services for the Omnitracs IVG including sales, service, setup, and training.

ELD Mandate Definitions

Any driver that is required to keep records of duty status is affected by the ELD mandate. This includes drivers who keep RODS for more than 8 days in any 30 day period. The short haul regulation remains the same – no RODS required. This also includes rental equipment, but there was no reference to short term rental.

Exemptions include:

• Vehicles manufactured prior to 2000
  • Answer to mechanical engines comment – RODS still needed
  • If a truck has an ECM, it may use an ELD
• Driveaway-Towaway, provided the vehicle driven is part of shipment
• If using RODS less than 8 days in 30

Affected Companies/Drivers

From the FMCSA fact sheet:

The ELD rule applies to motor carriers and drivers who are currently required to keep records of duty service (RODS) under the hours-of-service (HOS) regulations. Drivers who use the time card exception, and don’t keep paper RODs, will not be required to use ELDs. The following drivers may keep paper RODS:

• Drivers who keep RODS no more than 8 days during any 30-day period.
• Driveaway-towaway drivers (transporting a vehicle for sale, lease, or repair), provided the vehicle driven is part of the shipment or the vehicle being transported is a motor home or recreational vehicle trailer.
• Drivers of vehicles manufactured before model year 2000. However, a carrier can choose to use an ELD, even if it is not required.

According to the FMCSA exemptions page:

Drivers who use paper logs no more than 8 days during any 30-day period. Driveaway-towaway drivers (transporting a vehicle for sale, lease, or repair), provided the vehicle driven is part of the shipment or the vehicle being transported is a motor home or recreational vehicle trailer. Drivers of vehicles manufactured before model year 2000.

Differences Between AOBRDs and ELDs

Because of the differences in how AOBRDs and ELDs record and display driver data, and what trip, vehicle, and driver data are required, you manage these units differently. If your drivers are used to Omnitracs AOBRDs, they’ll see differences when RDC/XRS Mobile is updated from AOBRD to ELD operation.

Some general requirements are that ELDs must be registered with the FMCSA, accessible outside of the vehicle, and mounted to the vehicle. All duty statuses are recorded to the second. Additional driver-facing changes include:

CDL, VIN, and DOT information

ELDs must have your drivers’ CDL details, the vehicle’s VIN, and your company’s DOT number. This information displays on the header of your driver’s daily logs The VIN can be captured from the ECM or entered manually. If you need to update your driver’s CDL details, use the RDC/XRS website and select ADMIN > Drivers. Search for and select the applicable driver. From the Edit Driver – General Information tab, view and update the License # field.

To update a vehicle’s VIN, use the RDC/XRS website and select ADMIN > Vehicles. Search for and select the applicable vehicle. From the Edit Vehicle – General Information tab, view and update the VIN field.

NOTE: VIN numbers can only be updated for vehicles that have not provided a VIN number automatically through RDC/XRS Mobile.

Location Tracking

AOBRDs require a position information when a duty status is updated. The position can be recorded manually or automatically.

ELDs automatically record positions when a duty status changes, every 5 minutes while driving, when the engine is turned on or off, and at the beginning and end of personal conveyance and yard move.

Hours of Service Driver Alerts

Drivers are notified:

• As they approach their hours limits
• When a vehicle inspection is due
• When there is a diagnostic malfunction
• When there are carrier edits
• When unassigned drive time has accumulated on the ELD
• If they haven’t entered load or carrier information

Diagnostic and Malfunction Alerts

Ensure your drivers are aware of the new alerts they’ll see on ELDs and have troubleshooting steps to work around them. AOBRDs display GPS, odometer, and speedometer malfunctions to the driver, but ELDs display additional, more detailed, diagnostic and malfunction alerts. Malfunctions that are not automatically cleared must be corrected within 8 days of their first occurrence and the RDC/XRS Relay and RDC/XRS Mobile will continue to record as much required data that it can. If an ELD reports a malfunction, the driver must keep paper logs until the malfunction clears.

Default and Automatic Duty Statuses

Unlike AOBRDs, ELD drivers are no longer off duty by default when they log in. They are prompted to select a duty status upon log in and log out. Be sure your drivers are aware that ELDs default to On Duty if the vehicle is no longer moving after six minutes, so they may see a popup asking them to change their duty status if they’re stopped in traffic. If they don’t respond to the popup, they’re put in On Duty after six minutes of no movement.

Unassigned Driving Time and Editing Logs

Encourage drivers to turn off the engine; then log out of RDC/XRS Mobile at end of trip, end of day, and after swapping vehicles or drivers. This ensures that their hours are accurate and another driver’s drive time is not associated with their ID.

AOBRDs did not require that all drive time be allocated to individual drivers, but ELDs require drivers to review and either approve or reject drive time that accumulated on the ELD while no driver was logged in. The driver is notified when opening hours of service that there is unassigned drive time on the in-cab device. If the driver does not claim that drive time, your hours of service administrator must reconcile those hours and that reconciliation will display during DOT audits.

When you edit the logs of a driver using an ELD, the changes are listed as pending until the driver reviews and approves those modifications. If you reallocate drive time between drives, both drivers must accept the log modifications. These changes are recoded on the ELD and in any reports. You can edit a driver’s prior duty statuses, not the current duty status.

Yard Moves

If you allow drivers to record drive time that takes place in a private yard, without public access as yard move, you can configure ELDs to record this time, without mileage or time limit. Drivers manually select this duty status and end the duty status by: selecting another duty status, shutting off the in-cab unit, or you can configure hours of service to end yard move based on a 20 MPH (31 km/h) speed threshold.

To end this duty status, the driver must select a different duty status, shut off the engine, and log out of the ELD.

Accumulated yard move time displays on the on duty line.

Personal Conveyance

You can configure your ELDs to record personal conveyance, but be aware that:

• AOBRDs were not required to record off duty drive time, but they could be configured by the company to do so.
• ELDs may be configured by the company to record personal conveyance, but the vehicle’s position accuracy is limited to a 10-mile radius and there is no distance or time limit. Drivers are alerted when they near the company-defined personal conveyance limit, but are not automatically moved into the Drive duty status if that threshold is exceeded.

To end this duty status, the driver must select a different duty status, shut off the engine, and log out of the ELD.

Log Editing by Driver

ELDs allow all drivers to edit their logs. They must enter a reason for edit for any changes and cannot reduce or eliminate drive time.

Driver Log Editing by Administrators (Carrier Edits)

AOBRDs had no specifications about how administrators could edit driver logs, but when running ELDs, administrator changes are listed as pending until the driver reviews and approves those modifications. Administrators cannot reduce or eliminate drive time accumulated on an ELD. These changes are recoded on the ELD and in any reports. If the administrator reallocates drive time between drives, both drivers must accept the log modifications. These constraints are applicable to the driver’s current and prior duty cycles.

Additionally, keep in mind that:

• Drivers are notified of carrier changes upon vehicle association or PRE-Trip Inspection
• Edits remain pending until driver logs in and accepts them
• Edits are are not part of the driver’s logs until the driver approves them
• Drivers must enter a reason if rejecting the edits
• Your back office processes should be updated to monitor rejected log edits

Sending Logs to Inspectors

ELDs require a specific eRODS file format, and only electronic logs are required unless the in-cab device is experiencing issues; then paper logs are acceptable.

Password Protected Login

AOBRDs didn’t require a password protected login, but ELDs require a unique ID and password for each driver. Additionally, if there are two drivers logged into RDC/XRS Mobile, the co-driver must provide a password to view their logs.

Frequency of Daily-Log Certification

AOBRDs did not require that driver duty status logs be approved daily, but ELDs require (at minimum) certification every 24 hours of duty shift, including accepting or rejecting any log edits performed by the back office, hours of service administrator.

Driver Response to In-Cab Device Failure

There was no required driver response when an AOBRD failed and the driver used paper logs until the device was repaired or replaced. ELDs must be repaired within eight days and paper logs must be kept until fixed or replaced.

Roadside Inspection Requirements

Train drivers to hand over their mobile device and the Omnitracs RDC/XRS Mobile Driver Cab Card to the inspectors. Drivers must be able to direct law enforcement to the HOS Log screen when requested.

ELD Compliant Driver CAB Cards

Below are links to ELD compliant driver CAB cards for both XRS and IVG.

XRS ELD Driver CAB Card

IVG ELD Driver CAB Card