Whether you are ready or not, ELD mandates goes into effect in December 2017. There are many carriers who has been putting this off and I know many carriers are looking into it. This article isn’t about how to choose or how ELD mandate will change the industry, but it is about what people don’t realize before committing to implement. When we were looking into this back in 2014, no sales people at ELD providers mentioned about this.
The relay is attached to the ECM port in a truck where this device simply records all truck related data and transmits to an ELD device (fixed or portable) and transmits to the server where we can access it. Therefore, instead of manually filling out the paper Log, it does it automatically once it is properly used. When not properly used, it creates so much manual work to fix the issue to be in compliant. So, here are some of the items you need to think about when implementing.
- Training safety administrator and drivers – This is a hard and long process, ELD provider does a good job for on-boarding but this just isn’t enough with your employees. Training needs to happen at the orientation, recurrent training, and counselling, otherwise, expect to get calls from every driver whenever they can’t figure out what to do or doesn’t know what happening. Be prepare to answer and know any technical issues drivers will throw at you.
- Installation – There are two main types, a hard mount in the truck or portable tablet based system. They both require a hook up to an ECM port. Many of our drivers are on the road and we don’t always get to see them, so, think about how you will get to install this in every fleet that you have, this will cost time and money.
- Uninstall – You will now need to recover the unit when drivers quit by uninstalling from his truck. A few options: contract a shop to install and uninstall when needed, or you can have them come to you to get this done but this isn’t always easy when they already quit.
- Unassigned miles – This is the biggest headache when drivers do not follow the correct procedure on how to use it. Remember whenever truck is in idle, it records the data, therefore, when it is not logged in properly with set of procedures including log-in in, pre-trip, post-trip, log-off, and anything in between, the system does not know exactly how to handle the data in terms of off-duty and on-duty. This will need to manually corrected by talking to drivers and get their permission to do so. Mandates will address this where drivers can now fix it on the go.
- Personal Conveyance – Personal use and personal conveyance of a commercial motor vehicle (CMV) is one of the gray area regarding hours of service. This is because there is no regulation, and only one interpretation, pertaining to it. What is allowed is often a matter of enforcement. Question 26 of the interpretations for 49 CFR Section 395.8 discusses its use. Some guidance, When a driver is relieved from work and all responsibility for performing work, time spent traveling from a driver’s home to his/her terminal (normal work reporting location), or from a driver’s terminal to his/her home, may be considered off-duty time. Understand this fully and how to administer this on ELD and train drivers on what is qualified and not qualified as personal conveyance.
- Relay, tablet, unit failures. When this happens, drivers must start to use the paper-log until the ELD starts to work again. A lot of times, drivers need to be reminded of this. Also, office must be able to provide the previous 7 days worth of logs when the driver is stopped on the road.
- Intermittent data coverage. You have many different data services to choose from, AT&T, Verizon, Sprint, and etc. Well, we found out that some locations are very spotty and can’t get real-time data when we need it, but don’t worry, relay will save the data and transmit when the cellular connections are made. But be mindful of this, we changed carrier 3 times for our purposes.
- ECM and Relay. No matter how many time you train the drivers, it takes a long time for drivers to really understand how it works. Some drivers thought that by not logging in or logging in after they started to drive will save them that much time (old paper way, surely this is not proper), well, that is certainly not the case. Remember, relay records everything and we will now need to correct the HOS and re-train the driver.
- Login issues – This happens time to time, when drivers can’t log in, it is hard to properly record HOS for that driver and expect a call from him or need to monitor and reach out to drivers. Otherwise, you will receive a violation when stopped.
- Inventory – this is something no one thinks about when implementing. We have reviewed at least 5 providers before committing but every provider will require a long term contract for every unit you purchase or lease. Well, here is an example. You sign 5 year contract for 500 units for your fleet, we all know, you will have turn-over in driver, so, let say, you now only have 400 drivers, you are on a hook to pay monthly fees for that 100 units not knowing when you will have 500 drivers again for the remainder of the contract. Therefore, more you lease, the bar continues to go up but never comes down. Every trucking company will have this issue and think about the unnecessary cost you will have to bare. If do not have a properly written procedure to button down your inventory control, it will quickly get out of hand.
I hope this helps you to think about a few things when you are getting ready to implement. Please note that it is a long process to implement even after carefully choosing the ELD provider.