Time is running out before the final implementation of the ELD mandate. December 16th is the start of the regulation’s Phase 3 and begins full compliance with the ELD regulation. Until then, the FMCSA is encouraging carriers and drivers to fully train on ELD operations, and the subsequent changes the ELDs bring.
What Types of Changes
The ELD mandate has been in effect since December 2017, but carriers and drivers have been given a grace period to transition over from traditional devices like Automatic Onboard Recording Devices (AOBRDs) to the new ELD devices. Many carriers have been able to grandfather in the traditional devices but going forward, carriers will be expected to use the electronic logging software mandated by the FMCSA. With that change comes additional challenges carriers. “There’s a lot of planning to do, and it takes time,” Lisa Gonnerman, Vice President of Safety and Security for Transport America told attendees at this year’s American Trucking Associations’ Management Conference & Exhibition. “It seems like an easy transition, but there are key changes that bring out a lot of questions.”
Some common driver questions involve the data tracking process, (e.g. Yard moves or personal conveyance when the driver is off-duty.) while others may focus on exemptions and other legal processes. Many drivers today need to know about dealing with their ELD technical issues and common solutions for malfunctions. The FMCSA also suggests that carriers address harassment and coercion concerns with their drivers.
Not only do drivers require training, many operations and support staff need questions answered too. One issue carriers face is editing data logs – when it is appropriate and how it is done. Then it is important to file these updates correctly with the DOT.
Each operation is unique, so it is important to take time before the mandate goes into effect to train drivers and answer their questions.
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What Should Be Trained
Each company should train their drivers on specific questions, as well as a few general ideas. The FMCSA published a list of helpful training topics for carriers to meet with their drivers about. Here are a few of their ideas.
Compliance Requirements and Processes
These include FMCSA approved hardware and software as well as direct questions like which systems are grandfathered in the new mandate.
Supporting Document Requirements and Processes
Drivers who have exemptions need to keep a copy with them at all times in case law enforcement requires it. Other documents, like ELD data, are to be kept on file for six months.
ELD Operation
This is how to physically use the ELD. Many ELD hardware devices are the same as AOBRDs but have new software.
Proper Editing of Records
This is especially important for drivers whose data may be lost or for operation staff for proper filing.
ELD Data Retention
Current ELD standards call for duty status records (RODS) to be kept securely for six months.
Understanding and Preventing Harassment and Coercion
This can come from within a carrier’s own office or from external stakeholders like shippers or 3PLs. Harassment and coercion are illegal, and it is important that drivers are trained to recognize them. Carriers should also have a reporting policy available.
ELD Troubleshooting/Malfunctions
This involves procedures for fixing issues with the ELD and operating procedures without one. E.g. drivers are required to have paper tracking forms for eight days on hand.
Training Resources
The FMCSA has published helpful training materials to aid companies with the transition to ELDs. Their website has instructional videos and FAQ pages to help with common questions as well as other useful material. Many private companies promote training materials as well.
The ELD mandate brings many significant changes and disruptions to current transportation processes. That is why it is important to train carriers, drivers, and support teams on the many facets of the mandate itself as well as the many questions that these changes drive. It is important to do it soon, as FMCSA Administrator, Ray Martinez said, “The deadline is approaching quickly … I ask you to please do that as soon as possible, and don’t wait until the last minute.”
