What does your calendar say for Dec. 18, other than “finish (or start) Christmas shopping?” For commercial fleets engaged in interstate commerce, it should be marked as the day to throw out the paper logbooks.
On that date, fleets that fall under the Federal Motor Carrier Safety Administration’s (FMCSA) Hours of Service (HOS) requirements must be in compliance with the Electronic Logging Device (ELD) rule. Not having an ELD system in place on that date could cost you much more than the fallout from Christmas shopping procrastination.
(While fines for non-compliance can be given from that date forward, fleets have a reprieve on being placed out of service until April 1, 2018. Fleets presently using an automatic onboard recording device [AOBRD] have until Dec. 16, 2019 to comply.)
Many fleets, particularly smaller ones, still have their heads buried in the sand. “There are a significant number of fleets that have not made a decision from a provider standpoint,” says Scott Sutarik of Geotab.
If you’re in that category, and you’re thinking you still have 11 weeks to figure this out, you really don’t — for a few reasons.
First and foremost, choosing a system is not as easy as walking into an auto parts store. “There is a significant lead time to search and procure these components,” Sutarik says. “For those who wait until the last moment, will manufacturers be able to keep up with demand?”
The FMCSA does provide a list of registered ELD providers. For those just beginning the process, a look at this long list makes clear that the vetting process will take longer than anticipated. It’s important to note that the providers on this list have self-certified; they’re not FMCSA approved.
“Who you go with is not an easy decision,” says Samuel Mayfield, a retired state trooper, DOT inspector, and FMCSA-certified instructor at FleetUp, a provider of ELD and HOS compliance solutions. “All of [the providers] will say they’re compliant and they’re self-certifying, yet there has been no testing [to date] to demonstrate that they’re actually compliant.”
Mayfield says he is aware of companies offering ELD solutions that are not in compliance with the specifications listed in the ELD mandates. For fleets that signed on with one of those companies, this presents a Catch-22 — fleets using non-compliant devices will likely first find out only when the government begins investigating reports after the mandate kicks in.
One good piece of advice: Pay attention to the version of the software, which is listed on the FMCSA’s supplier page, according to Jennifer Gordon, product sales consultant for Merchants Fleet Management. “It’s always good to go to a solution that has gone through many versions versus one that came out when the mandate was announced,” she says.
The vetting process becomes more complicated when understanding the complexity of the different solutions. Should you go with a stand-alone system, or make the leap to a full-blown telematics system that handles other functions? Is a proprietary device, a tablet, or a smartphone solution right for your fleet characteristics? Is BYOD — “bring your own device” — right for you?
Don’t underestimate the time to get up and running on your new system. “You’ll need to schedule training through the ELD provider, not only for your drivers but your back-office personnel as well,” says Les Smart, a fleet consultant. “You’ll also need to go through several dry runs with your drivers before you’ll be fully confident in your process.”
Smart and Mayfield’s advice: Get help to understand these systems, now. “It will be very difficult for a fleet to understand compliance without the help of someone who is knowledgeable about the regulations and has tested these systems,” Mayfield says.
In general, be wary of dirt-cheap ELD solutions — saving a few bucks in the beginning isn’t worth the long-term time and effort. “You get what you pay for,” Mayfield says. “The cheapest solution is not the most effective in the long run.”
Ultimately, luck will run out for the non-compliant. A surprise inspection will not only lead to fines and potential downtime, but it will also have long-term consequences. Mayfield explains that ELD compliance will cause an overall improvement in CSA scores. If you’re not in compliance, “you’ll be magnified and highlighted as a problem,” he says.