ELD Enforcement – What You Need to Know

As I am sure most everyone knows, the ELD (electronic logging device) requirement goes into effect today, December 18th, 2017 and motor carrier enforcement (DOT) will begin a soft enforcement phase. The FMCSA has provided various forms of training to the state agencies, however, the level of preparedness of enforcement officers will vary from state to state. To successfully get through a DOT inspection, here are some things that drivers need to know and understand.

  1. Know if you are subject to the rule: Most Total drivers are required to use an ELD or AOBRD (automatic on-board recording device). Local drivers (100 air-mile exempt drivers) who typically are on a time card and don’t use paper logs no more than 8 days during any 30-day period are typically exempt. Check with your safety manager if you are not sure.
  2. Understand when you must use an ELD: Total’s trucks do not have ELDs, however, they are equipped with an AOBRD. Because Total voluntarily installed some form of logging/recording device prior to the December 18th deadline, Total is “grandfathered” until December 16th, 2019 to replace the AOBRD with an ELD. If asked by an enforcement officer which system you have, the answer will be “an AOBRD that is grandfathered”.
  3. Understand the difference between an ELD and an AOBRD: While an ELD and an AOBRD appear to be the same, there are some technical differences. The major differences are mostly about the information that an AOBRD and ELD record. For instance, ELDs record date and time, engine hours, vehicle miles, location, information on the driver, motor carrier, and vehicle, including malfunctions, engine on and off, logging in and out, etc. AOBRDs record less information. Another major difference is that ELDs restrict the amount and types of entries that can be edited.
  4. Know how to operate your system: You must know how to do the following:
    • Log in
    • Accept/Reject any unassigned driving hours the ELD records
    • Record duty status changes
    • Edit records
    • Add notes to records to explain any edits or additions
    • Certify records – to indicate that they are complete and accurate
    • Access RODS (records of duty status) data from the ELD
    • Review and understand the ELD printout/display information
    • Transfer ELD data by email or Blue Tooth to inspectors or law enforcement
    • Identify and correct or report data diagnostic issues
    • Report ELD malfunctions
  5. Know where your ELD user instructions/manual and supplies are located: Mandatory items can be found in your permit book:
    • ELD User’s Manual or instruction card (DOT Enforcement Card)
    • Instruction sheet for transferring HOS records to safety officials
    • Instruction sheet on reporting ELD malfunctions & recordkeeping procedures during ELD malfunctions
    • A supply of paper tracking forms (paper log sheets) for at least 8 days, in case of ELD malfunction
  6. Be patient and helpful: With all the different ELD and AOBRD systems available, officers aren’t necessarily going to know how navigate Total’s system. Frankly, it’s not their job to know how to navigate the system, it’s yours. Because this is all relatively new to many enforcement officers there is going to be a lot of questions. Be prepared to answer them, waiting until you are in the middle of a DOT inspection to start trying to figure things out is probably not going to end well for you. Most importantly, remember, attitude begets attitude. If you act knowledgeable, helpful and professional you will be treated as such. If you give the officer attitude, you can expect to receive the same.
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