ELD Transition Guidance From Fleets That Know

Fleets who have made the transition to electronic logging devices (ELDs) are saying the switch can’t be done in a day. This makes sense since the AOBRD rules consist of about 1,300 words, compared to over 26,000 to regulate ELDs. That’s a 20-fold increase.

December 16, 2019, is the mandate deadline by which anyone using a grandfathered automatic on-board recording device (AOBRD) will need to start using an ELD. FMCSA says there will be no additional grace period, given that motor carriers were given four years to prepare.

Based in part on conversations with small- and mid-sized carriers that switched to ELDs earlier this year, the following are some “best practices” for making the transition.

The most recurring message from carriers that have already converted to ELDs is this: Don’t underestimate how long a smooth transition will take.

“I had my drivers view the training video twice – and it still wasn’t enough,” said one fleet manager.

By design, ELDs are much more complex than AOBRDs and typically require more button pushing and decisions from drivers. Carriers told us that it’s important to make sure that drivers, along with their dispatchers and supervisors, are aware of the major differences — which may appear as soon as a driver logs in.

“Confusion” and “anger” were words we heard repeatedly when asking carriers about dealing with unassigned miles. If unassigned miles aren’t dealt with quickly — or prevented in the first place — they can rapidly overwhelm drivers and administrators alike.

The fact that all unassigned miles must be assigned or explained — combined with ELDs recording nearly every mile driven — means carriers should have an ELD account for as many of their drivers as possible, so they can log in before driving. Dispatchers and supervisors across the country have lost sleep over (a) the need to assign or explain every instance of unassigned driving time, and (b) arguments with drivers about which unassigned miles belong to them.

Another major change that drivers need to understand is that ELDs are required to switch to “driving” status when the vehicle reaches no more than five miles per hour. With an AOBRD, carriers had flexibility to set their own threshold based on time or distance. That flexibility goes away with ELDs.

One way carriers have reduced the impact of the five-miles-per-hour trigger is by using the “yard moves” and “personal use” settings with their ELDs. Carriers experienced in the transition to ELDs say drivers must understand when the special driving categories may be used.

• Yard moves should be used when driving in a restricted area that is not open to public travel. Yard moves are recorded as “on duty/not driving.”
• Personal use is for use of an ELD-equipped vehicle in an off-duty status, otherwise known as personal conveyance. The FMCSA has issued strict guidelines for personal conveyance, found in their official interpretations for 49 CFR §395.8, under Question 26.

With ELDs, drivers have more control over the contents of their logs, which also means more work for them. Supervisors will no longer be able to make edits without drivers’ approval. They can “suggest” fixes and edits, but drivers get to decide whether to approve or reject them.

Carriers who already transitioned noted that drivers and supervisors need to know how to edit ELD records and which edits are possible. ELDs allow much less editing than AOBRDs, making it harder for drivers to falsify their logs to gain more driving time. Drivers and fleets need to remember that all edits will be available for review during a roadside inspection.

How to transfer data directly to officers during a roadside inspection is another key bit of knowledge drivers need to have. When it comes to transfer methods, ELDs come in two flavors: long-distance (web transfer and email) or local (USB and Bluetooth). Drivers need to know which method their device uses, and what to do when an officer requests their logs.

If you want to see what an officer will see when they download your logs, try uploading one of your ELD files to the eRODS system at https://eld.fmcsa.dot.gov/eRODS

Preparing your drivers means training on the above (and other) topics — both before and after the transition — and you may need to do a lot of it depending on your chosen ELD system. Training builds confidence and reduces errors.

Keep in mind that drivers are not the only ones impacted. Other individuals who deal with ELDs or logs will need training as well.

“We lost time because my office people didn’t really understand the number of changes,” said the operations manager of one transportation company, speaking about their ELD transition.

Some key actions to take:

• Meet with drivers and back-office administrators to discuss the coming changes and how they will impact your operation.
• Obtain and review all training and educational materials your ELD vendor offers or recommends.
• Test all aspects of the system and make sure administrators know how to pull all the data they need to see.
• Prepare for malfunctions because they will occur. Training ensures fewer surprises and gets drivers up and running quicker after something breaks down.

If you don’t already have a timeline, start today and plan your transition working backwards from the December 16th deadline, allowing plenty of time for installation (if required) and training. The transition won't be easy, but making sure everyone is trained will go a long way towards easing the pain.

Waiting till the last minute to transition to ELD devices may find you settling for a less-than-ideal system. Asking your vendor to update existing ELog devices to ELDs at the eleventh hour will likely cause chaos and panic within your fleet and staff.  When it comes to Hours of Service, both scenarios should be avoided.