Tom Bray - J. J. Keller Industry Consultant
April 06 , 2018
April 1st marked the start of full enforcement of the ELD rule which includes assigning CSA points and issuing out-of-service citations. The Commercial Vehicle Safety Alliance (CVSA) supported a ‘soft enforcement’ period to allow the motor carrier industry, shippers and enforcement officers time to adjust to the new rule. In related news, CVSA announced that its International Roadcheck event will be held on June 5 – 7, 2018 with a special focus this year on hours-of-service compliance.
Now, more than ever, carriers are seeing that simply installing an ELD does not make them compliant. The hours of service limits have not changed. What has changed, and what is causing the most concern, is that ELDs require drivers to follow the limits to the letter, because they provide highly accurate recordkeeping. This detailed hours of service information is easily available to companies, officers, auditors, and investigators.
Late adopters may still be suffering the ill effects of the adjustment period; but, there are opportunities to make operations more effective and efficient on electronic logs.
The most important changes must come from the drivers. First, drivers need to understand the importance of logging in and out at the correct time. Logging in at the wrong time can create a violation that is not truly a violation. Forgetting to log in or logging out early can create unassigned driving time that will need to be dealt with either by the driver or the back office.
Drivers should also be making non-driving related duty changes when they occur, rather than relying on the device making automatic changes. The automatic non-driving change happens once the vehicle has stopped for five minutes or more. When a driver goes off-duty, he or she should immediately make the change on the device to avoid needlessly using up available hours.
Some drivers may need to adjust old or create new habits. One new habit, that should be old habit, is entering a comment whenever the driver goes over hours. Comments are necessary when there is a reasonable explanation for going over hours or using an exception that allowed for extra hours. Editing logs is not quite as easy with electronic logs but it’s a skill that drivers need to have. Editing to correct errors and omissions is fine, but editing to create more hours available is not. Inspectors and roadside officers will always investigate log edits.
More important than ever, managers must know how many hours a driver has available. The first step in this process is making sure that all the driver’s hours are visible. One common challenge companies have is mixed data sources – one day the driver is using time records, the next day, the driver is using a paper log, and then the next day, the driver is using an AOBRD/ELD … or any combination of these records. In that situation, the manager is going to need to know where to look to assemble all the hours, or the company is going to have to use a program or service that can combine all the records for a complete view of hours available.
As well as knowing how many hours a driver has available, managers also need to understand how long, as in how much time, an assignment will take. The duration to complete an assignment can no longer be judged solely on mileage.
Managers must also understand what to do should a driver be assigned a run he or she cannot complete, a driver runs out of service an hour from a customer or home, or the driver has been told the vehicle cannot stay where it is, and the driver has not hours available. It is imperative that managers embrace the new work process and be prepared to handle delays and make schedule adjustments as needed.
In conclusion, it is important to remember, these systems have a lot of data … that data can either help you or hurt you. If you are not dealing with the data – both your problems and your opportunities, you could be putting your company at risk. Simply plugging in an ELD device does not make you compliant. It is essential for drivers and managers to adjust habits and processes to ensure your ELD data shows you are operating in compliance.
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