December 18th, the day the ELD (Electronic Logging Device) Mandate goes into effect, is right around the corner. The Federal Motor Carrier Safety Administration (FMCSA) issued technical specifications and certification standards for ELD manufacturers, but there’s no official vetting of manufacturers for carriers nor guidance on how to make the best choice of a compliance solution. Since the mandate will impact an estimated 1.8 to 2 million vehicles, there is great interest on the part of opportunistic and inexperienced entrepreneurs as well as for the more established industry providers. But the ELD Mandate also creates opportunities for carriers, whether they’re moving from paper records or already utilizing e-log technology in their fleets, as the more established providers offer more than just compliance for their ELD solutions, but applications that also reduce paperwork, improve safety, and increase the bottom line.
There’s an ELD solution for every fleet size, ranging from BYOD (Bring Your Own Device) apps managed from a tablet or smartphone to fully-integrated telematic solutions providing information that can be used for fuel management, vehicle inspections, dispatching, back office support, shippers and even payroll.
On the low-cost end are companies that claim to make a vehicle compliant for ‘free’, or as low as a flat $200 investment in hardware with no additional costs. However, a closer look at their websites reveals little about details of the solution, the companies, and who runs them. More importantly, try finding ELD support information that goes beyond a FAQ page, or contact information other than a generic email address. This inexpensive option to comply may work for some carriers -- maybe not. But the risks of non-compliance areis high and the experience of these providers is low. The great value of these solutions evaporates as a driver loses 10 hours on an Out of Service because the no- or low- cost solution didn’t deliver. At the opposite end are integrated telematics that can deliver more information than a company currently needs.
To help carriers make more informed decisions regarding their choice of ELD, two of TMW’s strategic partners provided their thoughts on this critical situation. Tom Cuthbertson, VP, Regulatory Compliance, Omnitracs and Eric Witty, VP, Product Management, PeopleNet share information on how to prioritize and what additional features can be added to maximize your return on investment.
Cuthbertson and Witty agreed on the importance of doing due diligence beforehand. Witty states, “Small and medium companies really need to adopt a buyer beware attitude. There are so many names providing ELD it’s hard to sift through them, and determining a device’s capability and selecting the right one is difficult. Talk to a reputable vendor when you’re doing research. The newer companies getting into the market could be fine, but there’s an opportunity to create a long-term relationship that can benefit your fleet. The FMCSA website might not be the best place to do your research.”
Witty also pointed out the value of choosing a vendor who can deliver more: “You have to buy ELD - that decision’s been made for you - but if you’re investing in technology for the first time, or you have existing technology that needs to be ELD-capable, as long as you’re investing, are there other business problems you can solve? Choose a vendor who can help you get more.”
Omnitracs’ Cuthbertson says, “Make sure the device is compliant to FMCSA regulations. The [ELD] supplier has to provide a number of documents required to support and register their product: driver cards for driver training, a user manual, photographs of the product, release numbers for software products, documentation for malfunctions and to illustrate how the device was tested to meet compliance.” He noted due diligence is important here because this information is provided from the supplier, not the FMCSA.
Cuthbertson also indicated that carriers should take extra precautions when considering buying an ELD from a supplier without a track record in the industry, because of the significant amount of technical specifications in the regulations. These include confirming the supplier is using the specified security measures, including providing the correct enforcement of E-rods to ensure proper transfer of information to enforcement; that the ELD ensures drivers can control edits and make annotations; and that access to logs and interactions between drivers and the back-office function correctly.
While the time to install an ELD on a vehicle ranges from only 15 to 45 minutes, Cuthbertson and Witty also agreed carriers shouldn’t wait for the last minute to make a decision.
Witty observed some of phases of the decision- making process and installation are the same no matter the carrier’s size, but scale is a factor: “A three-truck fleet vs. a 15,000 truck fleet will obviously have different implementation schedules. A small-size fleet will probably need a couple of months to do their research, decide on a budget, do some training and make sure they have a successful rollout. In some cases, this could be done inside of a month for small fleets -- maybe even a couple of weeks if you’re really small.”
“As you move beyond that - getting the equipment, doing the installations, training people -- is a significant process, even if you’re just doing ELD, and it scales depending on the carrier’s size. If they have no technology at all they should be planning now. If they already have some technology it will vary by product and vendor. Low-end, self-serve models that are phone-based could be running in days,” Witty added.
Cuthbertson agreed, “Don’t wait for the last 90 days if you don’t have a device for your vehicle. When to make that decision depends on the size of your fleet. If you’ve always used paper this is going to impact more than just the drivers. All drivers will require some training, and some will pick up how the ELD works quickly, even in under an hour, while some others will need more time and repetition in understanding how it works. Allow two weeks to 30 days to get everyone onboard. Create a plan, one that includes dispatch, drivers and covers enforcement.”
Understanding how key components of ELDs function can alleviate problems for carriers, especially how the product handles unassigned vehicle moves. Look for one that includes secure access for drivers and passwords for administrators -- drivers aren’t the only ones getting behind the wheel and carriers won’t want to waste a lot of time on reconciliation or having exempt drivers impact the vehicle’s available time. Take the time to set up categories of exempt drivers accurately (road test mechanics, fuel dock, positioners, etc.) and bear in mind the differences in rules between short- and long-haul drivers.
Cuthbertson emphasized how important it is to “remember an exempt driver is also used to identify short-haul drivers eligible for the 8 and 30 exemption - if you don’t break short haul more than eight times in a 30-day period, you don’t need to keep a record of duty status. But if a short-haul driver breaks the short-haul rules more than 8 times in a 30-day cycle, they’ll be required to have an ELD.”
With that in mind he added, “Carriers have to look at how they move vehicles around because there are specifications on capturing unassigned vehicle moves, and depending on your operation, you need to be able to identify and understand how drivers would be exempt under the regulations - for example CDL mechanics do road tests, and during one they can drive around for 15 or 20 miles. If they don’t log in as an exempt driver, then all those unassigned vehicle moves have to be presented to the next driver who logs in to the vehicle for reconciliation or rejection. If there are five unassigned vehicle moves presented to a driver when he or she logs in, two may legitimately be theirs -- they may have forgotten to log in so they accept them -- the other three have to be sent back to the carrier for reconciliation.”
Another basic that should be considered is how edits and annotations could increase clerical workload, at least for a while, so carriers should look for a system that can be streamlined.
Additionally, Vehicle Inspection Reports (VIRs) are also required in the U.S. if a driver has defects (in Canada, they are required either way) and can be done electronically. Paper can still be used, but that paper needs to be managed for 90 days. A system incorporating VIRs into an ELD will be a big benefit for the driver, whether the fleet is large or small.
Beyond the basic considerations for complying with the mandate, Witty and Cuthbertson also agreed this is the right moment to consider adding features that provide impactful benefits like fuel management, maintenance tracking, and data to be used by back offices and shippers. There aren’t any one-size-fits-all solutions, so here is where talking with people with longtime industry experience pays off.
At Omnitracs, Cuthbertson said, “When I counsel people I ask them ‘what’s your worst problem? Are you getting 5.2 miles per gallon instead of seven? Then you might want a system to help you with fuel management,” which would also factor in the age of the fleet and the terrain in which the fleet operates.
Witty said, at PeopleNet, they view ELD as a component, not the end goal. He advised, “Ask questions internally about what your fleet needs, talk to other carriers, trade groups, and ask questions to vendors about what they provide and what kind of support they offer. The vendor should be able to answer your questions, including identifying the difference between what’s optional and what’s mandatory. We’re not telling people to invest in something they’re not interested in, but rather here is an opportunity to look at your business and decide if there is additional value you can get from a system - not every carrier will need it, but for those that can benefit, now is the time to see what an integrated system can provide. Look at the ROI opportunities on what that extra $50 or $100 investment can net you.”
When looking at the right ELD choice for your fleet, consider how electronics can also manage functions like fuel management, electronic vehicle inspection, driver behavior management, idling, and speeding. Integration with a TMS would be another plus, enabling transmission of hours of service information to be used by dispatch. Electronically tying all this data together using a telematics solution can provide your fleet with a streamlined system that even extends to dispatch and payroll.