Safety and Compliance Industry UpdateHours of Service & ELDs
Elise Chianelli- Sr Product Mgr Safety & Compliance
Regulatory and Industry Update- HOS
Regulatory Update
Current HOS Studies• Split Sleeper Berth Pilot – 2016• 34 Hour Restart - 2015
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SSB: the agency had planned to award a contract for the study by the end of 2014, but data collection likely won’t start until January 2016 The agency hopes to have 200 driver participants. “[200] would allow us to look at the different ways they split their sleep and determine what may be the best way,” The goal, is to determine “whether added flexibility can result in reduced driver fatigue and improved alertness.” 4/3/15: The Federal Motor Carrier Safety Administration has granted a sleeper berth hours-of-service exemption to McKee Foods Transportation. The one-year exemption will allow the carrier’s team drivers engaged in delivery and backhaul operations to take the equivalent of 10 consecutive hours off duty by splitting sleeper berth time into two periods totaling 10 hours, provided neither of the two periods is less than 3 hours.
34 Hour Restart Suspension
In effect on 12/16/14 at 12:01AM Impacts on:
• Drivers• Enforcement• Technology
Suspended until 9/30/2015 or submission of the final report
Electronic Logging Devices (ELDs)
ELDs Eliminate Top Driver Violations
Rank Violation Code Violation Description # of Inspections # of Violations% of Total Violations
2 395.8F1 Drivers Record Of Duty Status Not Current 17,544 17,658 9.24% 21 0.12% 5
3 395.3A3IIDriving beyond 8 hour limit since the end of the last off duty or sleeper period of at least 30 minutes
11,843 16,197 8.47% 89 0.55% 7
4 392.2SLLS2State/Local Laws - Speeding 6-10 Miles Per Hour Over The Speed Limit
13,303 13,304 6.96% 0 0% 4
5 395.3A2PROPDriving beyond 14 hour duty period (Property carrying vehicle)
7,860 9,333 4.88% 3,815 40.88% 7
6 392.16 Failing To Use Seat Belt While Operating Cmv 8,427 8,466 4.43% 1 0.01% 7
7 392.2C Failure To Obey Traffic Control Device 7,967 7,999 4.19% 3 0.04% 5
8 395.8E False Report Of Drivers Record Of Duty Status 6,707 7,540 3.95% 5,637 74.76% 7
9 391.41AFOperating a property-carrying vehicle without possessing a valid medical certificate.
6,766 6,797 3.56% 127 1.87% 1
10 391.41A Driver Not In Possession Of Medical Certificate 5,902 5,919 3.10% 327 5.52% 1
111,728 128,289 67% 10,057
45%
Top 10 Driver Violations: United States Vehicles as of March 2015
Top 10 Totals:
eDriver Logs can eliminate Data Source: FMCSA Motor Carrier Management Information System (MCMIS) data snapshot as of 3/27/2015 , including current year-to-date information for 2015.
Electronic Logging Device Proposal Supplemental Notice of Proposed Rulemaking
To OST: 5/14/2015 (office of the secretary) To OMB: 6/17/2015 (The Office of Mgmt & Budget) OMB Clearance: 9/21/2015 Pub Date: 9/30/2015 The Office of the Secretary (OST): Oversees the formulation of national transportation policy and promotes intermodal transportation. Other responsibilities range from negotiation and implementation of international transportation agreements, assuring the fitness of US airlines, enforcing airline consumer protection regulations, issuance of regulations to prevent alcohol and illegal drug misuse in transportation systems and preparing transportation legislation. The Office of Management and Budget (OMB): Assists the President in overseeing the preparation of the Federal budget and in supervising its administration in Federal agencies. The OMB also oversees and coordinates the Administration's procurement, financial management, information, and regulatory policies.
ELD Mandate- Timing ELD Mandated for all drivers required to complete RODS
All drivers required to adopt ELD within 2 years of final rule
Existing AOBRD Grandfathered• Adopt ELD within 4 years of final rule
Short Haul Drivers are generally Exempt (100/150 air-mile drivers)• May only use paper logs up to 8 days in any 30 day period• Any Short Haul Driver that uses a paper log for more than 8 days
in a 30 day period must install an ELD
ELD Display Requirements Same as today, plus:
• Driver’s First & Last Name
• ELD Username• Total Engine Hours• Miles per Driving period• ELD Malfunction Status• Data Diagnostic Status
Indicator for Authenticated Driver
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As well as being able to report out the data, the system must be able to display certain information for the driver and officers. The display must include (review list) Driver must notify carrier within 24 hours of system failure
ELD Technical Requirements
Must capture data elements• At startup and shutdown• At each change of duty status• Once per hour when vehicle is operating• At start and end of “personal use” or “yard time”
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The “required” data that must be captured includes…(review list) Frequency in which you have to capture slide 20
ELD Technical Requirements Data elements include:
• Date and time• Location
- 1 mile while on duty- 10 miles during personal use
Engine, Speed & Distance must be captured by vehicle
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To make sure the records are accurate, the vehicle must capture the required data (review) This will be a system that will either be on the vehicle requiring maintenance or it will be something the customer will have to “plug into” the truck’s J-bus/ECM. Either way, there will be issues for equipment providers. Both (having device pre-mounted or allowing customers to “plug their own in”) will create issues, elaborate
ELD Technical Requirements
No consideration for On Duty edits or Payroll Integrations
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Mandate says driver cannot add on duty time any way other than through the device (NO DRIVER PORTAL, NO PAYROLL SYSTEM-TIME CLOCK)
ELD Account Creation
All Drivers and Support Personnel must have unique user name and password associated with their account
Driver account must include driver’s license informationto provide unique ID
Driver must not have Administrative rights
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The overall system must include unique accounts and logins for each user. Driver’s accounts must include DL information to discourage the creation of “ghost drivers.” All users in the system must have a unique ID and password, so any changes, edits, comments, or notes in the system can be tracked back to who made them.
ELD Driver Interaction- Corrections
Back office support edits must all be approved by driver All annotations, comments, and changes must be retained, along with the
original Driver direct access to 6 months logs
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Driver must certify the record for the day when submitting, including selecting “I Agree” to a specific certification statement. If the records needs changed due to an error, the driver must re-certify. Carrier cannot initiate and place changes into the system without the driver re-certifying the record. The driver must be able to access and get all records (complete with comments, annotates, edits) for the last six months.
Unassigned Driver Account ELD must include “unassigned driver” account All driving time must be assigned or accounted for Issues for Leasing & Mechanic Road Tests
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One item that is in the proposal that might make working with carrier customers interesting is the system must have an unassigned driver account…all unassigned miles must either be assigned out of the account or explained. Could create a problem for carriers that use a leasing company that moves units around for them or mechanic road tests with equipment
ELD Driver Interaction- Certification
Driver must “certify” log within 24 hours • Cannot submit until last activity is complete
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Driver must certify the record for the day when submitting, including selecting “I Agree” to a specific certification statement. If the records needs changed due to an error, the driver must re-certify. Carrier cannot initiate and place changes into the system without the driver re-certifying the record. The driver must be able to access and get all records (complete with comments, annotates, edits) for the last six months.
ELD Driver Interaction- Fixed Mounted
Portable ELDs must be fixed mounted during operation
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Drivers will be required to interact with the systems, including (review list) Mounting requirement: plug’n’play or fixed mounted displays will be necessary for leased or rental vehicles (open debate)
ELD Driver Interaction- Updates
Driver must have ability to add/update• Annotations • CMV number • Trailer numbers • Shipment Info
• Output Comment, as requested by enforcement
ELD Driver Interaction- Safe Mode
Driver entries to be made when vehicle is stopped
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2 or more buttons becomes distracted driving
ELD Driver Interaction- Login Alert
ELD prompts Driver to Login if vehicle moves with no driver
ELD Driver Interaction- Mute
System must have “mute” to be used when driver is in the sleeper
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Device must mute automatically or give function to driver to mute manually
ELD Driver Interaction- PreWarning Prompts
Driver does NOT have to be prompted when approaching hours limit
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Mandate says not required
Driver Interaction: Location Information
Driver must add Location if no position fix at duty change
Driver Interaction: Automatic Duty Status Change Driving time automatically calculated Device requires alert if vehicle stops moving
for 5 minutes • Defaults to On Duty if no driver entry within 1 min• Other automatic duty status settings are prohibited
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Auto Duty Status Change
Roadside Inspection Process Must be capable of producing Graph Grid at Roadside One step process for Data Transfer
Authorized Official selects method of transfer
ELD Data Transfer
Standardized data output format• System can use any type of data, but output must be
standard• May provide a “value-add” option for vehicle
providers
Carrier provide data to Auditors and Drivers upon request
Carrier to maintain a “backup copy”
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Here again, to make all this work the devices will need to send out data in a standard format.
ELD Roadside Data Transfer
One Primary Method: • Web Services• Bluetooth• Email• Print
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The device must be able to transfer data to officers using a standard data format. The means of the transfer (communications method) would be one primary and two secondary (review). The officer would tell the driver which one of the device options he needs the driver to use. The options for the systems include: Printing and QR codes Wireless web, with USB 2.0 and QR code for a back up Wireless web, with USB 2.0 and TransferJet for back up Bluetooth, with USB 2.0 and QR code for a back up Bluetooth, with USB 2.0 and TransferJet for back up Email, with USB 2.0 and QR code for a back up Email, with USB 2.0 and TransferJet for back up
ELD Roadside Data Transfer (cont)
Two Backup Methods• USB (all devices must support)• Scannable QR Code or Transjet Transfer
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Example #1: LTL Fleet 100 records per day average 35 QR codes to be scanned by DOT at time/location of event. Example #2: Long Haul Driver: Let’s say the driver is long haul and transitions from on-duty to driving and back 4 times per day and enters no additional information regarding ship-to or bill of lading info 6 QR Codes with 4000 character resolution.
Required Data Elements:• Driver Name• Date• Time• Location
TOP 5 ELD Mandate Misconceptions 5. “If I have a couple of trucks in my fleet equipped
with an OBC, I meet the Grandfather requirements for an existing AOBRD and don’t have to comply for 4 years”
4. “If I purchase hardware today, it will be obsolete with the new requirements of the proposed ELD rulemaking”
3. “Suppliers will be ready to ship ELD’s on the date the final rule is published”
2. “I have less than 50 trucks in my fleet and therefore am exempt from the mandate”
1. “Driver must be able to produce a printed copy of his log, even if he using and ELD”
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#5: If I have a couple trucks in my fleet equipped with an OBC, I meet the Grandfather requirements for an existing AOBRD user and don’t have to comply for 4 years FALSE: As the proposal is currently written, a driver must be actively logging hours of service via a 395.15 certified AOBRD, in order to be eligible for the grandfather clause. Those fleets with equipment installed and not using eLogs should consider activating eDriver Logs prior to the publication of final rule to ensure eligibility with the 4 year grandfather clause. #4: If I purchase hardware today, it will be obsolete with the new requirements of the proposed ELD Rulemaking FALSE: Many suppliers, including PeopleNet have reviewed the mandate to ensure that their devices being shipped today will comply with a simple Software Update. These updates can be done over the air without the need to touch each and every truck. There may be some solutions out there today, that will not be in compliance. #3: Suppliers will be ready to ship ELDs on the date in which the final rule is published Neither True nor False, however, the supplier industry has agreed that it could take 12-24 months to make all necessary updates to comply with the new requirements. The proposed rule has not accounted for any supplier implementation time; therefore if it takes a Supplier 12 months to make updates; carriers will only have 12 months to purchase, implement and train. Our company has estimated needing approx. 12 months to comply. Don’t procrastinate… you wouldn’t want to be left in the dust without equipment once mandated. #2: I have less than 50 trucks in my fleet. I am exempt from the mandate FALSE: the only exception that was included in the proposed rulemaking was that for those drivers that qualify for the 100/150 Air-Mile Radius exemptions. There is one caveat, in the event that the exempt 100/150 air mile radius driver is required to log via a paper log 8 times in a rolling 30 days, the driver will be required to install and log via an ELD. As a side note, if the driver exceeds the radius or hours, they would be required to convert to US Federal Regs. #1: Driver must produce a printed copy of his log, even if he is using an ELD FALSE: According to the proposed ELD Mandate, a printed copy of the log is an optional transfer method. Unless there are changes made to the final rule, most suppliers will opt to support USB, Email, Web Transfer and QR Codes. Again, printing is not a mandatory requirement of the ELD Mandate.
ELD Mandate Reference Materials
Review the rule at http://www.fmcsa.dot.gov/ Review comments at
