ELD Mandate Review - TN Truckingtntrucking.org/documents/TN SAFETY ELD Presentation.pdf · o Driver...

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ELD Mandate Review

Tom Cuthbertson

TTA Safety Management

Council and Maintenance

Council

Agenda

• Final ELD Mandate Timeline

• What is in ELD Mandate

• Supporting Documents

• Changes in the final rule

o Who must comply

o Enforcement transfer requirements

o Display requirements

• What is in the final rule?

o Driver control of RODs

o Security / Certification requirements

• Operational Considerations

ELD Short Glossary of Terms

• AOBRD – Automatic Onboard Recording Device

• DOT – Department of Transportation

• ELD – Electronic Logging Device

• EOBR – Electronic Onboard Recorder

• FIPS – Federal Information Processing Standards

• FMCSA – Federal Motor Carrier Safety Administration

ELD Short Glossary of Terms

• HOS – Hours of Service

• NPRM – Notice of Proposed Rulemaking

• NIST – National Institute of Standards and Technology

• OMB – Office of Management and Budget

• OST – Office of the Secretary of Transportation

• PKI – Public Key Infrastructure – Encryption Certificates

• RODS – Record of Duty Status

• SNPRM – Supplemental Notice of Proposed Rulemaking

December 16, 2015

Final published

January 16, 2016

Effective date

December 2017

Compliance date

December 2019

Last date to be able to use AOBRD

AOBRD | Automatic

Onboard

Recording Device

AOBRD can be installed from

any time before published date up to the

compliance date ..Transfer of AOBRD

after compliance date not allowed

ELD Mandate Final Timeline

Final Federal Register Dates

• Prohibition of Coercion –

o $16K Penalty - 11/30/2015

• ELD Mandate used of electronic logging devices

o Final date 12/16/2015

• Does not change Hours of Service

• Technical update

• Address Harassment

• Supporting Documents

• Security

• More formal Certification

• Information electronically transferred to enforcement

What is this ELD Regulation?


• 1 ELD Function describes an ELD as follows: “The ELD discussed in this appendix is an electronic module capable of recording the electronic records of duty status for CMV drivers using the unit in a driving environment within a CMV and meets the compliance requirements in this appendix.”

• This means that any and all components that are required for compliance in an ELD will have separate certification and registration

Definition of an ELD

• Submit employer supporting documents 13 days of either the 24-hour period to which the documents pertain or the day the document comes into the driver’s possession, whichever is later.

TYPES OF DOCUMENTS IDENTIFIED

• Each bill of lading, itinerary, schedule, or equivalent document that

indicates the origin and destination of each trip;

• Each dispatch record, trip record, or equivalent document;

• Each expense receipt related to any on-duty not driving time

Each electronic mobile communication record, reflecting

communications transmitted through a fleet management system; and

• Each payroll record, settlement sheet, or equivalent document that

indicates payment to a driver.

• 8 Documents in 24-hour period

Supporting Documents

Each Document

A. Driver or Tractor ID

B. Date of transaction

C. Location of transaction

D. Time Zone

Fewer than 8 containing elements if have A,B,C qualify

Supporting Documents – Cont.

Who is Affected? Who is Affected? • Any driver that is required to keep Records of Duty Status

(approx. 3.1 million)

o Includes drivers who keep RODS for more than 8 days in any 30 day period.

− Short haul regulation remains the same, no RODS required

o Includes rental equipment (no reference to short term rental)

Exemptions

• Vehicles manufactured prior to 2000

o Answer to mechanical engines comment – RODS still needed

o If truck has ECM, may use ELD

• Driveaway - Towaway, provided the vehicle driven is part of shipment, RV, Motor Home – Fast Act

• If using RODS less than 8 days in 30


Login/Logout

Power-up and Power-down

Yard Move

Personal Conveyance

Intermediate position

Diagnostic Event

Malfunction Event

Introduction of Events


• Vehicle VIN

• Beginning and Ending Odometer and Engine hours

• Driver CDL # and State

• Exempt status

• Data Diagnostics

• ELD Malfunctions

• Unidentified Driver Records

• Body of Log Detail to display all events and duty status

DISPLAY STILL VALID for Roadside Inspection if can be viewed without enforcement entering the vehicle

Display Options in Final Rule Increase

Additional Information

New Display Requirements

Display Options in Final Rule Increase

• Yard Moves – Not Drive, Only On-Duty

• Drive Starts at up to 5 MPH

• Only Auto On-Duty when stopped 5 minutes

• Driver Interaction – Traffic Considerations

• Proposed item of Interoperability between

providers

• Significant More Driver Control

• Create transfer file for roadside - eRODS

• ELD must be repaired within 8 days.

ELD final rule

eRODS File Transmission

Acceptable methods to transmit data

Safety official will select method

Enforcement must be capable of one from each

Telematics Transfer Method

•Web Services

•Email SMTP

Peer to Peer Transfer Method

•Bluetooth Web service local network

•USB 2.0

Or


Drivers must certify logs – 24 hour of

operation

Must certify log edits even if out of window

of the 8 days

When accepting or rejecting back office

edits - annotation

Driver Log Certification

• Allow drivers to edit their logs and create

annotations on all entries and edits – cannot reduce

drive time

• Drivers must approve all edits from Support

Systems before applied

• Require that drivers have direct access to the log

information

• Personal Conveyance – do not record all engine

information – 10 mile accuracy on GPS

• Audible muting of devices by driver

• Driver reviews unassigned vehicle moves

• Daily certification of logs and for all edits - by driver

or carrier

ELD Final – Items Specific For Drivers (address harassment)

ELD Certification Process

• ELD providers register their ELD with FMCSA

• Request a user account

• Register an ELD

• Provide required information • Device Name, Model Number, Software Version, ELD Identifier,

Image, User Manual, Company, Contact Company (Phone),

Contact Company (Email), Company Website

• Self-certify that the ELD meets the technical spec

• Process to update when modifications made


• FMCSA will provide

• Authentication key(s)

• Authentication file(s)

• Registration number

• Used in ELD log file for verification

• Currently available for certification


• Shortcomings of the Process

• Anyone can claim to be certified

• Anyone can register an ELD

• If FMCSA finds that an ELD listed on its website does

not comply with the technical specifications, FMCSA

may initiate removal of an ELD model or version from

its list by providing written notice to the ELD

• By then it may be too late for the carrier that may

have spent tens of thousands of dollars

• 454 page test document to pass

Telematics Transfer Method

• Web Services

• Email SMTP

Peer to Peer Transfer Method

• Bluetooth

• USB 2.0

• Web Service and email

• FIPS publication 197

• NIST SP 800-32

• Bluetooth

• Discoverable

• Generate random code

• USB thumb drive

• AES – 256 Security

Transfer Security

Unassigned Driving Time

• Unassigned Driving – Presented to Driver

• What are operational causes?

• Driver forgets to login

• Mechanic road test

• Relocating tractor to another yard not by

driver

• Correction after the fact

• Upon login, a driver is prompted to accept or

decline unassigned driving time

• Any declined time must be reconciled by

carrier by annotating the record

Unassigned Driving Time

• ELD states each driver needs a driver ID

• Prevention – EXEMPT DRIVER

• Create login for each use of vehicle

• Mechanics that road test have CDL

• Relocation of vehicles

• Make sure drivers log in

• Devices can provide warning upon wheel move

EXEMPT DRIVER CAN BE USED FOR SHORT HAUL

• Drive – From any other duty status to Drive when motion is

detected and the speed reaches a maximum of 5 MPH • There is NO TIME / NOR DISTANCE consideration

• On-Duty – From Drive after 5 minutes of no detected motion

and after 1 minute of driver being prompted

• Yard Move – this an event that the driver puts themselves in as

a duty status

• In RODS it is to be recorded as “on duty” time and NOT

DRIVE

Auto Duty Status & Yard Move

• Shortcomings of the event • There are no limits around it

• There are no defined thresholds for it

• There are no automatic duty status changes allowed

• Possible Solutions • FMCSA only offers log editing as an alternative

• Vendors could implement warnings around it

Yard Move


Discussion on AOBRD grandfather

Discussion on Web Services –

certification

Recent FMCSA Verbal

Communications


Join the Conversation Today!

• What about gliders ? – VIN number

• Where can I use yard moves?

• Are there specific mounting requirements for the ELD

device?

• What happens when a driver is in a break and is forced to

move the vehicle?

• ELD and Short Haul?

• How should we handle rentals?

• What restriction on fleet management systems?

• Shipper makes leave out of hours?

Frequently Asked Questions


QUESTIONS?

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