Still Not On An ELD? 3 Steps To Compliance – If You Start Now

In less than four months, nearly all motor carriers will be required to run an electronic logging device (ELD) to monitor driving hours. There are a few exceptions, such as those drivers not required to keep a Record of Duty Status (RODS) more than eight days in a 30-day period, or those operating a vehicle manufactured before model year 2000, but those are truly exceptions, not the rule.

For those not required to meet either of the first two deadlines for ELD compliance – December 17, 2017 and April 1, 2018 – your time is up. As of December 16, 2019, you must be using an ELD. Many carriers that are not currently compliant are running Automatic Onboard Recording Devices (AOBRD), which were grandfathered in until the December 16 date.  

J.J. Keller estimates that about half of those required to convert have done so, leaving thousands of fleets and drivers non-compliant. 

"We recognized the challenge fleets would have in migrating to ELDs, and have been aggressive in efforts to help prepare for the final mandate" said Paul Schwartz, vice president of technology solutions at J. J. Keller & Associates, Inc. "We expect to have over 90% of our customers converted to ELDs by the end of August."

Making the switch from an AOBRD to an ELD might seem easy, but it is not always.

"We had initially wanted to [transition] January 1, [2018], but it took us five months to get to where we were comfortable to pull the switch," said Chip Warterfield, driver fleet safety manager for Upstaging, a theatrical logistics carrier. Upstaging finally converted all its drivers from AOBRDs to ELDs on June 3, he told FreightWaves. "There was plenty of work that needed to be done behind the scenes. Anyone that has any computer networking background would understand the pain of just changing servers."

In Upstaging's case, it had installed AOBRDs on its fleet of 200 trucks in mid-2017, so the transition was seemingly a "flip of the switch." It was far from that.

Warterfield, who said the ELD transition was "his baby," shared some of what he learned during the process as the deadline approaches.

While Upstaging is a larger fleet with its trucks and drivers spread throughout the country, its experience isn't necessarily unusual. The time-frame for a smaller fleet might be shorter, but the pain points remain similar. Starting now, though, can ease those pain points.

"Start now," Warterfield said. "Be ready for unexpected workflow. [One thing] that is going to occur is you are going to receive phone calls from drivers asking you to edit their logs when you are no longer able to do so."

The conversion process can be broken down into three basic steps.

1. Verify

Do you have a compliant device? The first step to compliance is to find out what type of device you are currently running, and if it is an AOBRD, can it be converted to ELD compliance? Warterfield said Upstaging's fleet had J.J. Keller AOBRDs that could be transitioned with a software and firmware update, but not all devices are capable of that.

If you are unsure if your device is compliant or can be transitioned, J.J. Keller has created a verification hotline at 855-215-3691 that anyone can call.

2. Prepare and Train

"We started using AOBRDs in mid-2017," Warterfield said. "We witnessed some of the difficulties in getting the drivers up to speed [even though] our initial management training was very simple because the AOBRDs were very forgiving."

Once Upstaging started the transition to ELDs, which are less forgiving, Warterfield realized basic levels of training would not be enough. He generated a PowerPoint presentation, and the company trained drivers in groups of 15 to 20 at a time via video conference. There were plenty of questions, especially around personal conveyance, yard moves and the steps necessary for compliance.

"The driver has to remain focused on his duty status or else the system is going to [penalize them]," Warterfield said. "They have to be very aware of their duty status at all times. One of the key differences between an AOBRD and an ELD is that the AOBRD was taking three data points, but the ELD is taking seven data points and that includes the ignition switch."

Understanding these data points is important because a misstep could trigger a violation. For instance, if a mechanic drives a truck for an hour and then the driver gets into the cab and doesn't check the ELD and reject that hour, it will be charged against the driver's available drive time, cutting into productivity and potentially compensation.

Warterfield said the ELD also will highlight deficiencies in your operation. Upstaging runs its trucks in both the U.S. and Canada, which operates under slightly different hours of service rules. In Canada, Warterfield said that switching the ELD from off-duty to sleeper (as opposed to going from on-duty to sleeper) would cause it to trigger a violation of rest rules.

"Until the ELD, we didn't know some of the nuances in the Canadian rules and that we were violating the hours-of-service rules," he said.

Warterfield noted that training the drivers was only part of the equation; back-office staff needed to be trained as well, including on the day-to-day task of resolving unassigned driving time.

"Without question, that was as big a portion of the task as anything," he said. "We have a four-member safety department that needed to understand the devices and Keller was very kind to give us the [needed support]."

In fact, supplier support is one of the big reasons that Warterfield says fleets should start the transition now if they have not done so already.

"You don't want to be sitting there looking like Homer Simpson at the nuclear plant," he joked. "You want to know what is going to happen. Our phone calls with Keller were extensive… but without those calls, we would still be hacking around out there and pushing buttons incorrectly. It's important to know how to navigate the edits and other assigned events."

3. Implement

Once training is complete, it's time to make the switch. Experts advise doing so quickly so drivers and staff can put their training into effect while it is fresh. If it requires a software update, as was the case with Upstaging, coordinate that with your provider so training can be scheduled accordingly. If it is installation of new hardware, there may be extra time involved, especially for fleets with trucks in multiple locations.

Some areas to watch for in the implementation process:

• As ELDs receive software updates or new devices are installed, ensure the Engine Control Module (ECM) and ELD data interface match and maintain a connection
• Verify that required ELD in-vehicle information is readily accessible in each truck and remove AOBRD documentation and procedural information.
• Upgrade to ELD software or install devices no more than one week after driver training takes place.
• Implement a problem identification and reporting process to quickly resolve issues and communicate progress. Schedule town hall meetings with drivers in-person and via conference calls at least weekly.

Upstaging needed five full months for training and implementation to make the switch from AOBRDs to ELDs, and ran into several speed bumps along the way. With only about four months left, time is quickly running out.

"The idea that switching is easy is ill-conceived," Warterfield summed up.

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