Especially during this transitional period when ELDs and their older sibling, automatic onboard recording devices (AOBRDs), are still in use through December 2019, some common errors have cropped up around ELD use that are costing truck drivers and fleets valuable time. It can also lead to often unnecessary citations that'll have to be chased down and resolved.
According to Joe DeLorenzo, director of the Office of Compliance & Enforcement at the Federal Motor Carrier Safety Administration, some of these are pretty obvious little things that lead to disproportionate problems. So the good news is, it may not take a lot for drivers and their fleets to have a much better day.
1. Driver unsure/ not confident if device is an ELD or AOBRD.
With fleets often spread out in regional or national operations not only with many—sometimes hundreds or more—drivers and high rates of turnover, small wonder it can be tough to keep drivers up to speed on the HOS logging device they're using.
"Especially as you're making the conversion to ELDs, be sure your drivers are looped in to this and know if they're operating with an AOBRD or an ELD," DeLorenzo said. "There's a lot going on with roadside inspections, and it's going to be that enforcement officer's job to figure out your driver's Hours of Service.
"The first question is going to be, 'Do you have an AOBRD or an ELD?'" he noted. "When the answer is, 'Um, I'm not sure,' that inspection is going to take a long time."
ELDs and AOBRDs communicate differently. Drivers need to know confidently what kind of device they've got in that cab and have appropriate instruction sheets ready.
"If not, they're going to be standing there at the roadside answering a whole bunch of questions," DeLorenzo said. "It seems really simple, but if you can give your drivers some kind of 'cheat sheet' or whatever to remind them so they know what device they have, it will make that process go a lot smoother."
2. It's complicated: previous days of logs/ records of duty status unavailable.
At the roadside or an inspection facility, enforcement officers will not only be looking at a driver's records of duty status for that particular day but the previous days as well to determine Hours of Service compliance.
Great—so what if a driver is changing trucks or there was a problem with whatever e-logs recording device the driver is using?
"It could be because a driver has multiple employers with incompatible devices; it could be because there was a malfunction for a couple of days that week and the driver went to paper," DeLorenzo said. "There are any number of reasons why you're going to run into this situation where there is not a fully complete set of the previous seven days of hours of service data on the ELD or AOBRD."
The answer for this is "whatever works best for you," he suggested.
"You can keep paper logs and make sure the driver can present the full seven days—'Here's my two days, yesterday and the day before, from when my ELD was malfunctioning, and here's the five before that from my ELD'—that's fine," DeLorenzo explained.
If an ELD has malfunctioned, a driver's hours can also be edited in later. "Think of this in the simplest terms," he said. "How do you establish Hours of Service compliance on the roadside?
"The same way you did before: make sure you've got your previous seven days [of driver logs], and make sure those previous seven days can be passed along to an enforcement officer."
DeLorenzo noted that there's no requirement for a driver to have some kind of documentation or note from the company if there was a problem/malfunction with the ELD, but it wouldn't hurt.
3. Data transfer to enforcement officer misunderstood/ a puzzle.
Just like a truck driver should know what type of e-logging device is in use, understanding how to transfer data from it to an enforcement officer is just as important. Because, again, AOBRDs and ELDs are different.
AOBRDs can email files more directly—and usually quickly—to an officer. There are more options required for ELDs, and they don't work the same way.
ELDs have options of using web services, email, a direct USB plug-in, a printout, or displaying information directly on a screen that can be handed to an enforcement officer. And not all are equal.
"The officer is going to ask for a web services transfer" with an ELD, DeLorenzo noted. "That is by far our preferred method of transferring [Hours of Service] data."
There's a good reason for that: it's the quickest and most convenient method for the officer. Using email with an ELD "takes a little detour," according to DeLorenzo: "If you use email [with an ELD], sometimes the officer will be like, 'Hey, I haven't gotten your data file—your ELD must not be working.'
"But it's only because it's taking so much longer to get there."
The solution here, again, is for drivers to be comfortable knowing how to transfer info to the officer with the device they're using. FMCSA, meanwhile, is trying to make sure officers are aware of the options for different device types.
"What we're telling the law enforcement officers is that if for some reason things aren't working, the driver can't figure it out or whatever, that's why we've got the backup options," DeLorenzo said. "We're really training the law enforcement officers to focus on Hours of Service compliance."
4. Driver forgot to log in/ unassigned miles showing.
Your driver got in and started off without signing in to the ELD or AOBRD, or someone else didn't log off properly. Whoops!
"One of the biggest problems that companies are having is with drivers forgetting to log in," DeLorenzo said. "So the most aggravation I hear is, 'We've got unassigned miles because the driver forgot to log out, the wrong driver logged in,' whatever."
His recommendation for fleets is to manage that unassigned drive time as best as possible and don't let it pile up. "Staying on top of that to the extent that you can is helpful," he advised.
"With an ELD, you have the added complication now of accumulating unassigned miles that now you need to address," he pointed out. "If you can figure out how to do that, it will help. Unassigned miles that show up on the roadside will cause problems, and there's going to be questions that are asked."
5. Tip to make life easier: Use the ELD's edit and annotations feature.
"All I can tell you about that is, it's there for a reason," DeLorenzo said. "Encourage your drivers to use those edit and annotation features whenever something unusual happens."
Drivers were used to making such notes on paper logs, he added, but that's fallen off somewhat now that they're using ELDs. Any edits and annotations made on an ELD will show up when an officer goes to review the data files.
"So to the extent there are unassigned miles, or the driver is operating under personal conveyance, something strange happened, or whatever the case may be, if there's an annotation in there, it just makes life a lot easier and it's a lot easier to explain to everyone," said DeLorenzo.
"Especially as you make the transition to ELDs, that's a good place to spend a little time" with driver training, he stressed. And that can be important beyond just helping drivers get through their daily routines.
"It makes it much easier to explain things at the roadside and also much easier if there's an investigation or an audit sometime down the road," DeLorenzo noted.