The Go-To ELD Implementation Guide for Carriers
Beginning December 18, 2017, most U.S. motor carriers will be required to comply with Electronic Logging Device (ELD) regulations. While the Commercial Vehicle Safety Alliance won’t begin placing trucks out of service for violating the regulation until after April 1, 2018, compliance with the regulation is still important for the safety of the motoring public. Fines or citations can be issued to violators between Dec. 18, 2017, and April 1, 2018. According to a Morgan Stanley survey conducted in August, approximately 30% of carriers are not yet fully compliant, and 15% don’t expect to be fully compliant by the deadline. To help carriers understand the ELD regulation, we developed the following checklist based on the Federal Motor Carrier Safety Administration (FMCSA) guidelines.
Understand ELD use and its exemptions
Any carrier currently maintaining hours of service (HOS) or records of duty status (RODS) must implement ELDs by Dec. 18, 2017. If an Automatic On-Board Recording Device is installed before that deadline, carriers may use it instead of an ELD until the full compliance date. Beginning Dec. 16, 2019, all carriers must use ELDs. If certain drivers are exempt, proper documentation should be kept in their truck.
Evaluate and select the right ELD
The FMCSA compiled a list of registered ELDs; however, those ELDs are self-certified by the manufacturer – not the FMCSA. Before selecting, research an ELD by reading ratings on an ELD and its manufacturer. Sample ELD requirements include the ability to:
- Record location with an accuracy of a one-mile radius
- Retain data for the current 24-hour period and the previous 7 consecutive days
- Obtain a copy of ELD records on demand (print or electronic file)
For more help choosing a device, read the FMCSA’s tips.
Develop training procedures for managers, drivers, and other ELD users
The road to implementation and compliance will likely be full of bumps. Create and test accounts for drivers, administrators, and other users. Then, conduct training on an initial/orientation, refresher, and as-needed basis. For a list of suggested topics, visit the FMCSA’s website.
Ensure drivers have required user documentation in vehicles
Proper documentation in the vehicle will be mandatory beginning Dec. 18, 2017. If drivers are already using ELDs, documentation should be present in their vehicle. Mandatory items are:
- ELD user manual
- Instruction sheet for transferring HOS records to safety officials
- Instruction sheet on reporting ELD malfunctions and recordkeeping procedures during ELD malfunctions
- Supply of paper tracking forms (grid graphs) to last 8 or more days, in case of ELD malfunction
Retain required supporting documents and backup data on separate systems
Carriers must maintain up to eight supporting documents for every 24-hour period of on-duty time. The 5 types of documents are:
- Bills of lading, itineraries, schedules, or similar documents that show the start and finish location for each trip
- Dispatch records, trip records, or similar documents
- Expense receipts for meals, lodging, fuel, etc.
- Fleet management system communication records
- Payroll records, settlement sheets, or similar documents that verify driver payment
- Toll receipts if the driver is using paper RODS that don’t count toward the document limit
Beginning Dec. 18, 2017, carriers must:
- Retain ELD data and backup data for 6 months
- Ensure secure storage of all data and backups to protect driver privacy
Understand harassment and the penalties for it
The FMCSA defines harassment as “an action by a carrier toward one of its drivers in which the carrier knew, or should have known, the action would result in a violation of HOS on the driver’s part.” Regarding the new the ELD rules, the FMCSA listed the following harassment example: It is harassment if a carrier uses ELD data to pressure a driver to take action that results in an HOS violation or to drive when ill or fatigued. If carriers or their drivers are overwhelmed with ELD compliance, they can rest easy knowing resources are available. Take it one step at a time by following this checklist to better prepare for the mandate. Visit the FMCSA FAQ page for more resources on choosing, implementing, and maintaining ELDs.