ELD in 2017: Who Must Comply?

Most drivers must follow the HOS Regulations if they drive a commercial motor vehicle, or CMV.

In general, a CMV is a vehicle that is used as part of a business and is involved in interstate commerce and fits any of these descriptions:

• Weighs 10,001 pounds or more
• Has a gross vehicle weight rating or gross combination weight rating of 10,001 pounds or more
• Is designed or used to transport 16 or more passengers (including the driver) not for compensation
• Is designed or used to transport 9 or more passengers (including the driver) for compensation
• Is transporting hazardous materials in a quantity requiring placards
• (Source: https://www.fmcsa.dot.gov/regulations/hours-of-service)

ELD – ELogs Mandate December 2015 Changes

• When do I HAVE to have an ELD system installed in my truck or my drivers’ trucks?
  • Every driver that is required to do paper logs today (see exceptions in the FMCSA rules) will be required to use an ELD system on or before December 18, 2017
• Can I still use an AOBRD system to be compliant?
  • You may only buy an AOBRD system for ELogs for warranty replacement of an existing AOBRD. AOBRD may only be used for ELogs until December 19, 2019
• When will fully compliant ELD systems be available?
  • Compliant ELD systems are currently available. Click herefor more information.
• What are the major changes in the ELD system versus the AOBRD rulings from a few years ago?
  • • Some notable additions are as follows:
      • The new regulations tighten up some of the suspect requirements from the last rules.  There is now a requirement for offline “drivers” or users that will record what happens when no driver is logged into the system.  There are also requirements that capture more engine data and therefore make manipulation of the data more difficult.
      • The regulations are more clear as to how an officer should receive data from the ELD system.  Email or specific wireless connections will now be required.
      • Drivers must now have direct access to their own, historic, log files.

  Pre-ELD Mandate Posted by FMCSA December 11, 2015

  • • What are Electronic Logs and Hours of Service?
      • The Federal Motor Carrier Safety Administration has mandated Hours of Service logging (ELogs) for truck drivers to be made electronic as of 2017 (the official mandate to be announced 10/30/2015).  Under this mandate, rule 395.15 becomes a requirement for ALL truckers.
    • What is FMCSA Rule 395?
      • The full FMCSA rule 395 includes a number of regulations not specific to the 395.15 specification.  These include carrier requirements and other rules such as data retention requirements.
    • How does an EOBR system fulfill FMCSA 395?
      • The EOBR requirement is rule 395.15 as stated above.  The rule adds the mandate that logging be performed electronically in order to eliminate the possibility of driver tampering or “adjusting” the driver’s log book.  The EOBR must be tightly coupled with the vehicle and track the actual vehicle mileage.  By tracking actual vehicle mileage, falsification of logs is near impossible.
    • When is the FMCSA 395.15 EOBR Mandate in Effect?
      • The FMCSA is set to announce the final mandate on October 30, 2015.  The nation’s drivers will then have two years to fully comply.  Don’t wait until the last month to get yours!  That could spell trouble with supply and installation issues.
    • What is an EOBR?
      • An Electronic On Board Recorder is a device that gathers data both from the truck and an attached driver user interface.  The recorder will collect driver status each time the driver comes to a stop or starts or whenever the driver specifically changes the status.
    • Does the EOBR Replace the Daily Driver Logbook?
      • It sure does!  Instead of commercial truck drivers logging their daily activity in a paper log book, commercial drivers will now simply change their work/driving status on the EOBR.
    • How does fleet tracking work?
      • See the diagram to the right
    • Do I need a separate cellular plan?
      • Some companies require you to provide your own cellular connection for your GPS tracking or EOBR data.  As such, some companies also require you to bring your own tablet or mobile phone.  In the end, it is your preference when you are shopping for a fleet tracking or EOBR system.  It is certainly easier to choose a company that includes the cellular service plan in your fleet tracking or hours of service plan.
    • Can I use my EOBR system for navigation?
      • That depends… The majority of EOBR systems include navigation.  However, some do not.  If truck navigation is a requirement of your system, just be sure you verify that this is included.  Even some of the more notable names like Rand McNally, have a plan that does NOT include GPS navigation with its EOBR setup.
    • What does an EOBR system cost?
      • This is a very difficult question to answer. Some system include hardware with a monthly fee.  Some systems charge for hardware and have a lesser service plan.  Then, some try to accomplish the whole thing with no service plan at all.
      • When selecting the right option, you need to verify that coverage can take place when the vehicle is out of cellular coverage.  Some systems that allow you to use a mobile app require a constant cellular connection to avoid electronic logbook data loss.
      • Keep total cost in mind.  Generally, the systems that allow you to just start paying for your system monthly without the upfront hardware cost are more expensive over the life of the contract.
    • Should I expect a multi-year contract for my eLog system?
      • Many of the vendors require a contract.  Some are as short as pre-purchasing 6 months of service, but most are 3 years in duration and are very difficult to escape.
      • Some vendors choose to allow you to be customers on a month-to-month basis.  Rhino Fleet Tracking is one of these.
    • Is there a difference between an EOBR and AOBRD?
      • Technically?  Yes
      • Practically?  No
    • What hardware is required for an EOBR system?
      • Generally, you need a tablet or other interface in the truck whereby the driver can log duty status and that an officer can review.
      • This device must communicate with the JBUS to ensure proper tracking of vehicle mileage.
      • Finally, most systems include a “black box” GPS tracking device to send basic and EOBR-related back to the software vendor’s servers and then to the company’s user interface.
    • Is fleet tracking included in all EOBR systems?
      • Definitely not.  You will need to be specific when doing your research or speaking with sales representatives.  Even some of the most well known names do not include EOBR in the standard system.  So, all of the great things you usually get from a fleet tracking system might be ignored despite paying about the same for the system.
    • Is GPS tracking included in every EOBR system?
      • The same answer applies as for fleet tracking.  Most do, but some don’t.
    • Do all EOBR or HOS systems track fuel tax or IFTA as well?
      • Most reputable EOBR systems provide IFTA logging along with the EOBR information.
      • Almost none take the IFTA data and fully prepare the forms for submission – this is primarily because each tax jurisdiction is widely different.
    • What is the difference between an EOBR and a fleet tracking system?
      • Fleet tracking is typically GPS tracking of a fleet of vehicles.  EOBR encompasses the rules for driver status and logbook recording electronically.  There are no specific regulations on fleet tracking and no mandates either.  A company will choose to use fleet tracking to improve fleet efficiencies and save on fuel and labor costs.  But, it is not a requirement.
    • How is driver identification verified?
      • Driver logins are verified on the EOBR with login and password
      • Driver identification can also be verified through key fobs
    • How do EOBR systems manage co-drivers?
      • In the case of co-drivers, both drivers log into the EOBR and maintain status jointly.  The system tracks them both
    • Which Garmin Navigation Devices are Compatible with Dispatching and HOS?
      • Click ELD Devices with Garmin Compatibilityfor a list