How many truck drivers are currently running with a grandfathered automatic on-board recording device (AOBRD) is an open question. Estimates have ranged from about 30 percent to 75 percent. J.J. Keller estimates that about 60 percent of motor carriers are operating with an AOBRD device while other manufacturers report various percentages. Clem Driscoll, founder and principal of consulting firm C.J. Driscoll & Associates, told FreightWaves he’s heard various numbers, but 50-50 (percent) would be a good starting point. Whatever the actual industry-wide number is, as of December 16, 2019, any driver still running an AOBRD will be in violation of the electronic logging device (ELD) law.
“If you are at 40 percent or 50 percent of devices that are AOBRDs that need to transition to ELDs, that’s a large number,” Driscoll said. “It’s not going to be painless.”
Drivers and carriers can start taking steps now to ease any potential pain. It starts by identifying whether you have an AOBRD installed and whether you need to replace it with an ELD (some AOBRD devices can be switched to ELD mode), what functions it should offer; how to use an ELD; and what paperwork must be retained.
Experts like J.J. Keller suggest checking with the provider if you are unsure whether you have an ELD or AOBRD and ask how simple or complex the switchover will be. They also suggest not waiting until the deadline approaches to deploy an ELD. The number of drivers who waited until the last minute before the earlier deadlines created industry-wide logjams on customer support lines and delays in receiving some devices.
“Do I think it will be a seamless transition? The answer is no,” Driscoll said. “Maybe the most significant thing is going to be training the drivers on the differences and law enforcement.”
J.J. Keller concurred, even though 100% of its installed base can switch from AOBRD mode to ELD with an over-the-air update. Keller said customers continue to underestimate the amount of driver training and education needed.
The education campaigns have already started, encouraging those that must switch to do so early. J.J. Keller has published “2019 Hours of Service Blueprint: Your Strategy for Meeting the Final ELog Deadline.” The guide addresses questions on topics such as what is involved in switching and whether the device currently in the truck is an older AOBRD or a newer model.
The company is also scheduling sessions with its AOBRD users to assist with driver training.
As companies look at which devices to install, they need to keep in mind several things, including the provider’s reputation, the provider’s experience with ELDs and capacity to handle customer service, and whether the solution fits the goals of the fleet. Some devices record the minimum data required by law, while others can pull additional data and information, opening up other potential operational benefits. Understand what you are trying to achieve with the device before you buy one.
The driver training process starts with an understanding of what an ELD actually reports. An ELD records the following data elements at certain intervals: date; time; location information; engine hours; vehicle miles; and identification information for the driver, authenticated user, vehicle, and motor carrier.
Drivers must retain certain paperwork inside the vehicle at all time. This includes a user’s manual; data transfer instruction sheet; an instruction sheet covering reporting requirements and recordkeeping procedures during ELD malfunctions; and an eight-day supply of blank driver’s records of duty status (RODS) graph-grids, to be used in the case of an ELD malfunction.
When it comes to the actual training, carriers do not have to go this alone. Most providers will offer support and resources to assist in the training process (last-minute adopters may find delays in this process, though) and FMCSA has a handy FAQ section on its website answering common questions.
Drivers should be trained on how to log in and out of the device, and importantly how to use edits and annotations. An edit is a change to the ELD record, but it does not overwrite the original record. An annotation is a note related to an ELD record and can be used to explain things such as personal conveyance or an unassigned yard move.
Drivers also must know how to transfer data to roadside inspectors. The ELD is required to transmit information either through a local transfer (USB or Bluetooth) or via a telematics system.
Training should be given to anyone that will interact with the ELD in some way – drivers, dispatchers, supervisors and safety managers, for instance. Explain how the technology works, what happens if the device malfunctions, and what information drivers must provide to law enforcement during a roadside inspection.
FMCSA said drivers should also be trained to:
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Respond to unassigned driving hours in their ELD records
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Record of duty status changes
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Certify their records to indicate that they are complete and accurate
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Access RODS data from their ELD
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Review and understand their ELD’s printout/display information
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Identify and correct or report data diagnostic issues
Drivers must retain eight supporting documents and submit those documents to their carrier within 13 days of receiving them. Documents must come from these five categories:
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Bills of lading, itineraries, schedules, or equivalent documents that indicate the origin and destination of each trip;
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Dispatch records, trip records, or equivalent documents;
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Expense receipts related to any on-duty not-driving time;
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Electronic mobile communication records, reflecting communications transmitted through a fleet management system; and
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Payroll records, settlement sheets, or equivalent documents that indicate what and how a driver was paid. If a driver keeps paper
Payroll records and electronic mobile communication records can be stored electronically. The documents must contain the driver’s name or carrier-assigned identification number, either on the document or on another document enabling the carrier to link the document to the driver; date; location (including name of nearest city, town, or village); and time.
Training is also a great time to note some of the benefits an ELD can provide for drivers which may improve buy-in. These include potentially fewer driver check calls, less time spent filling out paperwork, streamlined roadside inspections, and verifiable digital proof of their driving hours.
Carriers are required to maintain RODS data and backup data for six months, with the backup data on a device separate from the original device.
The process of converting from an AOBRD to an ELD doesn’t need to be a painful one, but it does require planning and proper training so drivers understand how to use the devices. It is a process, though, that should start sooner rather than later.
