Tom Bray - Industry Consultant - J. J. Keller & Associates, Inc.
December 14 , 2018
A common practice with automatic onboard recording device (AOBRD) systems is the use of “ghost driver” accounts, also known as “generic” or “dummy” accounts. While these types of generic accounts are not allowed in ELD systems, fleets using AOBRDs would use them to prevent unassigned driving time from building up in the system as they provide “buckets” into which certain unassigned driving time can be placed. Common ghost accounts include:
When a driver uses one of these accounts, he or she will typically either:
Ghost driver accounts are possible because the AOBRD rules at §395.15 do not prohibit them. They are allowed, but that they must be used appropriately and monitored by the carrier. During an audit, the investigator will look at the movements within such accounts and verify that the carrier is using and managing them appropriately.
Some drivers or supervisors that know about the ghost driver accounts may use them to “hide” driving and on-duty time. A driver might be tempted to log in to the ghost driver account if short on available hours. In some fleets, supervisors actually have set up ghost driver accounts solely for this purpose.
In contrast, the ELD regulations clearly state that all accounts must be assigned to an individual and all driver accounts must have a driver’s license number associated with them, meaning that ghost driver accounts are not allowed in an ELD system (see §395.22(c) and (d)).
The only exception is the “unidentified driver” account. Any driving time that comes into this account must be either assigned to a specific driver, or a comment must be attached to the driving time explaining why it could not be assigned to a specific driver.
Fortunately, ELD systems allow for another option that can help eliminate the need for ghost accounts. “Exempt driver” accounts can be set up for exempt drivers — those who are not subject to the hours-of-service or logging regulations. With these accounts, the driving time is captured and assigned to the correct driver, but a regular log is not generated. This way, the driver can log in whenever moving a vehicle, eliminating the need for a ghost driver account or having to deal with unassigned driving time
Take steps to eliminate the “ghosts” in your logging system. If you are using ELDs, compare your driver roster to the list of drivers in the ELD system, remembering to include drivers who left the company within the last six months. If you find a driver in the ELD list who is not on your driver roster, investigate and find out why. It could be a supervisor who occasionally drives, or an employee who is in the ELD system as an exempt driver due to moving vehicles around in the yard, or, it could be a ghost driver account. The key will be to investigate and find out what is going on, and if it is a ghost driver account, it must be shut down.
If you are using still using AOBRDs, you will need to address removing “ghost” accounts, updating driver logins, if necessary, along with other mandate required items to meet the December 16th, 2019. To help with the AOBRD to ELD transition, download our new 2019 HOS Blueprint. At nearly 50 pages, this expert content was created to help you understand the regulatory and technical changes between AOBRDs and ELDs and how to prepare your organization. It also includes specific checklists and guidance on getting you ready for the deadline.
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