ELD Rule: Three Paths to Compliance
Three small fleets share their methods to choose and implement electronic logging device systems, integrate electronic compliance into their business processes, instruct drivers, and manage enforcement under the new rules.
Hi-Lite Airfield Services LLC, an airport pavement markings, runway rubber removal, and airfield maintenance contractor, had a specific compliance need from its ELD system — to understand trucks’ runway work for the purposes of calculating hours of service. (Photo courtesy of HiLite)
Years in the making, the electronic logging device (ELD) regulation — which requires the transition from paper to electronic logs to comply with hours-of-service (HOS) and records of duty status regulations — is finally in practice. For many small fleets, especially those for which fleet duties comprise only a portion of their job functions, the path to compliance has been an ongoing challenge.
Driver acceptance was one issue for Hi-Lite Airfield Services LLC, a nationwide airfield maintenance contractor. “In this day and age, people don’t like change,” says Desirae Woodside, DOT clerk for Hi-Lite who oversees the company’s 55 trucks.
Woodside adds that the change was especially challenging for several older drivers, some who still used flip phones. Some of those drivers mentioned that they might let their commercial driver’s licenses (CDLs) expire and choose a different profession because of the change. So what is the status of those Hi-Lite drivers today?
“Well, we didn’t have anyone turn in their CDL,” Woodside says, adding that one elderly holdout now appreciates being able to go home sooner due to reduced paperwork.
The company’s ELD vendor, Gorilla Safety, held training sessions and worked closely with the drivers to get them comfortable with the system. Woodside says that made a big difference with the drivers.
Geotechnology, Inc. has also been working collaboratively with its ELD vendor to meet the challenges of compliance.
Jim Howe is vice president, exploration, for the St. Louis-based engineering and environmental services company. Howe oversees about 45 vehicles that use the Geotab Drive ELD system, along with 95 other vehicles that are exempt from ELD mandates. The company had used an automatic onboard recording (AOBR) device system since 2013, but Geotechnology phased it out in favor of Geotab Drive soon after the ELD rule came into play.
Geotechnology’s transition from paper logs to AOBR was unrelated to the ELD mandate, but when company officials learned around 2015 that the ELD mandate was imminent, they decided to transition to Geotab Drive.
Through its relationship with Enterprise Fleet Management, the business had already implemented Geotab’s telematics system in a portion of its fleet — and was receiving other benefits from telematics, such as analyzing engine malfunctions and evaluating driving habits. “Safety and how vehicles are behaving in public view, those are huge things in our market,” Howe says.
“Six months before the ELD mandate, I became a very popular guy,” says Steve Tungate of Toshiba, regarding the flood of contact from ELD providers. While he had made contact with FleetUp early on, Tungate did a side-by-side analysis of other ELD solutions as they came to him. (Photo courtesy of Tungate/Toshiba)
Technology products company Toshiba had a similar experience working with its ELD provider, FleetUp, to comply with the ELD mandate. Steve Tungate, Toshiba vice president and general manager of service, supply chain and innovation, chose the system to “comply with DOT (regulations) and our policies, and for the cost benefit of the solution itself.”
He explained that the company drivers are computer technicians who “also put on a driver hat.” He wanted an ELD product that “was easy to install, easy to use, and easy to monitor.”
A look at these three companies provides a sample of how small fleets have gone about choosing and implementing ELD products, instructing drivers, and dealing with enforcement and other issues in integrating compliance into their business processes.
Woodside of Hi-Lite Airfield Services worked with an internal committee formed for the purpose of choosing an ELD system. The committee talked to about 15 ELD suppliers and narrowed it down to three after about a month and a half before deciding on Gorilla Safety. One concern was longtime viability of the ELD suppliers. “Some of these small companies can go broke,” she says.
In choosing an ELD vendor, the committee wanted a reasonable price, a company that would treat Hi-Lite as well as it treated its bigger customers, and one that worked well with Hi-Lite’s duties of moving vehicles around airports. Committee members looked for “portability, customer service, and price,” she says.
Hi-Lite’s business necessitated a particularly tricky HOS need to be fulfilled by its vendor — to not only capture highway miles, but also operation of trucks when they’re striping runways. Gorilla Safety worked with Hi-Lite, Woodside says, to identify those striping applications as “yard moves” that don’t count toward driving time.
Howe of Geotechnology says his company chose Geotab Drive partly because of its low entry cost, incentives on the hardware, and his company’s existing relationship with Enterprise Fleet Management. “It made for a comfortable situation,” Howe says. “I had an ally in this negotiation if I didn’t get something I was expecting.”
For Howe, ongoing system support and updates are essential. Geotechnology’s business is able to take advantage of a specific HOS exemption for water well drilling, and Howe is working with Geotab to build that functionality into the Geotab system. “I want (a system) that’s going to change as the technology and the regulations change,” he says.
Geotab Drive also handles fuel tax reporting. “That can be a very onerous task for our drivers and our supervisors and accounting people,” he says. “We like the electronic solution to minimize that.”
In addition to compliance, Toshiba chose FleetUp to take advantage of its fleet management services platform and because the company developed a good working relationship with one of FleetUp’s regional sales managers.
“Six months before the ELD mandate, I became a very popular guy,” says Tungate, regarding the flood of contact from ELD providers. While he had made contact with FleetUp early on, Tungate did a side-by-side analysis of other solutions as they came to him.
Another deciding factor was that other providers couldn’t commit to getting the devices into the Toshiba fleet in a reasonable time to meet the deadline, Tungate says.
For Geotechnology, system implementation and training have been smooth. With familiarity of the previous AOBR system, drivers were familiar with the language, Howe says, and found the new system easier to use and understand. Training for the four offices took less than two weeks, compared to six months for the old system.
“There’s always supervision and follow-up and coaching guys who may not be getting it the way they need to, but we were up and running pretty quickly this time,” Howe says.
Geotechnology drivers access the Geotab Drive system through a 7-inch tablet inside their vehicles. The driver can log in, log out, and do pre-trip and post-trip inspections using their smart phones if they wish, but the company relies on the tablet to serve as the vehicle’s record of operation. The user interface is intuitive, providing easy interaction for drivers, Howe says.
Woodside is still getting used to the change in auditing electronic logbooks compared to paper, where she would lay out the books in front of her. “I had my routine, and my routine doesn’t work anymore,” she says. “But it will get easier.”
One of Geotechnology's 22 exploration rigs is ready to be mobilized. Having previously used an AOBR system, Geotechnology drivers were trained in less than two weeks, compared to six months for the old system. (Photo courtesy of Geotechnology)
Further, if the drivers send in a digitally signed log book and then realize they have made a mistake, FMCSA rules require that only an administrator can correct the change.
Toshiba held several webinars and conference calls with drivers and managers leading up to the December deadline for the new rule. FleetUp sent instructions to those employees and set them up with the system.
During implementation, Toshiba’s focus was to ensure that the tool was user friendly. Some Toshiba drivers started with applications on cell phones and then migrated to mounted tablets, while others kept the cell phone app, Tungate says.
Tungate expected driver pushback against complying with the rule, but he did not see much. Some managers and drivers thought the system would have too much of a “big brother” feel to it, but they actually appreciated it, he says. In fact, in some Toshiba markets, teams are now sharing best practices with each other.
Toshiba is also using the ELD system as a method to track and manage its vehicle inspection checks, monitor driver behavior, and identify areas in which it can improve fuel economy or use assets more efficiently.
“From a corporate perspective, we like it because we get to see everything,” Tungate says. “We get to see assets that are not utilized potentially as much as they should be, and we get to see assets that are being well-used to help us in our overall fleet management processes.”
After installation of the system, Tungate sees his role as being an auditor of compliance, from a driver perspective and also of the FleetUp system. “We’re simply providing (drivers) the tools to help them complete their duties,” he says.
The mandate created a sense of urgency for Toshiba to review various fleet processes, Tungate says, and to look into the wider benefits of a telematics system. “We agreed if we’re going to go this route, we might as well get everything we want.”
As of early February, only two Geotechnology drivers had gone through full Department of Transportation (DOT) inspections, and both passed. One new driver was warned for not meeting the requirement to have seven blank paper logs with him. The driver drove down the road and picked up the new forms.
With so many available compliance solutions and a few methods to comply, fleet operators are finding that inspectors are going through their own learning curve. Woodside says that while drivers are putting the system to practice on the road, they need to be patient with enforcement officers as well. “It’s going to take all of us working together,” she says.
Shannon McLeroy, COO of Gorilla Safety, has conducted ELD seminars for DOT officers and has also accompanied clients during inspections. The education can be granular: Some officers asked drivers to print out loss forms, not knowing that the FMCSA accepts emailed forms. “The biggest key has been education on both sides,” he says.
During this learning process, the FMCSA has given fleets a reprieve until April 1, 2018. Until that point, violators would not be put out of service, nor would violations affect their CSA scores.
Switching from paper to electronic logs was the hardest part of the transition, McLeroy says, but a needed one.
The ELD rule was implemented to mitigate the gray areas that allowed drivers to work more hours than they should, drive with less-than-adequate rest, and cause accidents. McLeroy predicts early data on the new rule will show a reduction in accidents and fatalities as a result of eliminating the gray areas.
With electronic logs, “There are no gray areas anymore,” he says. “It’s all black and white.”