By Dave Osiecki, President of Scopelitis Transportation Consulting & ELD Consultant to PeopleNet Earlier this week, we posted a blog about how AOBRD fleets should prepare for more stringent enforcement. This blog is part two of that series, discussing how fleets with ELDs can prepare for this increased level of enforcement: April 1 is fast approaching and, when it arrives, it will bring the next phase of ELD implementation—more stringent enforcement of the mandate. But what does that mean, and what can your drivers expect? Some of the answers to these questions can be found in the Commercial Vehicle Safety Alliance’s (CVSA) recently issued “Hand-Held and Electronic Logging Devices” Inspection Bulletin. This is where CVSA’s ELD Inspection Bulletin, and experience during the January through March ‘soft enforcement’ period, helps. During an inspection, one of the first questions a driver should expect is whether the device being used is an ELD, or an Automatic On-board Recording Device (AOBRD). Of course, the rules for these technologies are different, and a driver’s answer to that question will dictate the inspector’s follow-up questions and requests. On this note, it’s critical that drivers know which technology they are using (ELD or AOBRD), and be ready to communicate it with certainty. If an ELD is being used, the inspector is likely to ask the driver some or all of the following questions (not necessarily in this order):
- Can you show me (or hand me) the on-board ELD information packet? This packet is required to contain an ELD user’s manual, an instruction sheet on the data transfer mechanisms the ELD supports, and an instruction sheet describing ELD malfunction reporting requirements. This packet can be either on paper, or an electronic file containing this information.
- Can you show me an 8-day supply of blank paper logs? These are required in the event of an ELD malfunction.
- Can you show me, on the ELD display screen, electronic log for the current day AND for the last seven days? This is the backup inspector review/inspection option in the event a requested electronic data transfer fails.
- Can you show me that the ELD can be uncradled from its mount, and potentially handed out of the window for my review?
- Do you know how to initiate an electronic transfer of your electronic record?
- When I give you a code, can you initiate an electronic data transfer from the ELD to my computer? An electronic data transfer is required, and the driver must know how to initiate and complete the transfer process.
If an electronic data transfer is requested, the code provided by the inspector will allow the file to be sent from the ELD (or, in some cases, from an encrypted USB storage device), through an FMCSA computer server, to the inspector’s laptop or tablet computer. Drivers should expect the data transfer process to take just a few minutes. And, drivers should also expect the inspector to spend a few additional minutes, likely in a car or in a different area away from the truck, reviewing the electronic file he or she receives to determine if it contains any potential hours-of-service violations. If no violations are discovered, the inspector will communicate this to the driver. If everything is in order, the electronic log data transfer process, along with the inspector’s review of it, should take less than 15 minutes. If a potential or actual violation is found, all bets are off and the inspection will take significantly longer. For the hour-of-service and ELD portion of a roadside inspection to go smoothly, it’s important for a driver to know:
- whether the device is an ELD or an AOBRD;
- how to use the device including how to toggle between screens to show the current and prior days’ electronic records;
- where the on-board information packet is (including where it is if it’s an electronic file), and what it contains;
- how to initiate and complete an electronic data transfer to an inspector; and,
- how to remove the ELD from its mount to hand it to an inspector, if requested.
Inspections can be high-stress events for drivers, especially if they don’t experience them very often. Driver training, and preparation on what to expect, can lower the stress and facilitate the inspection for all involved. Read the full version of the CVSA’s ELD Inspection Bulletin here. Have questions about April 1 or anything else related to the ELD mandate? Visit PeopleNet’s ELD Resource Page to get your questions and answered and stay up-to-date on everything ELD.