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Three steps to ELD implementation on the eve of out-of-service enforcement

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Jason Morgan is the editor of Fleet Equipment. He has more than 14 years of B2B journalism experience covering the likes of trucking and construction equipment, real estate, movies and craft beer industries.

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The Dec. 18, 2017, effective date for the electronic logging device (ELD) mandate has come and gone, but fleets are beginning to realize that it didn’t mark the end of the ELD saga—it was the beginning of a new ELD era. The next mile marker on the road toward the mandatory use deadline is April 1, 2018—the date when enforcement officials can start putting trucks that aren’t ELD compliant out of service.

“It is important to understand that this compliance date is very black and white,” said Scott Sutarik, Geotab’s associate vice president of commercial vehicle solutions. “If fleets do not have a solution—either an automatic onboard recording device [AOBRD] or ELD—the officer can pull you off the road. Ensuring that you are equipped with the correct solution will also be critical for fleets that want to keep their CSA scores in check and to avoid fines which can be very costly to the fleets and the drivers.”

The ELD experts that Fleet Equipment spoke with estimate that there are still a considerable number of trucks on the road that are not currently compliant—anywhere from 8% to 20%, representing between 250,000 and 500,000 trucks.

Don’t have an ELD solution picked out yet? Here are three things to consider when looking for an ELD.

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“We don’t have hard data that gives exact numbers, but it is likely that there are a significant number of smaller fleets that are still using paper logs and are not in compliance with the mandate,” said Eric Witty, vice president of product for PeopleNet. “We saw an influx of inquiries from some of these fleets during Q4 of 2017 and just now has that begun to wane, nearly two months after the mandate went into effect.

“Whether it was procrastination or speculation that the mandate would never actually happen, December 18 has passed and the mandate is indeed in effect,” he said. “This means that paper-based fleets that waited until the very last minute are likely scrambling for compliance.”

While procrastination and speculation are on you, if you don’t have an ELD solution, or maybe you have a solution in place but are having problems getting it off the ground, Fleet Equipment is here to help. Let’s get started.

Implementation step one: Know how your ELD works

Sure, it seems like a no-brainer, but knowing how your ELD works and crafting a plan to implement it across your fleet is the first stride in working toward step two: teaching others how your ELD works.

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“There is a perception that once you have made a purchasing decision, install a unit in your vehicle or an application on your smart device, you are ready to go,” said Ken Creager, senior vice president of sales and marketing for EROAD Inc. “Clearly that is just the beginning, and to truly understand and gain value from the technology, there is a fundamental transformation in business process, training and optimization that must occur.”

The first thing to know is that you’re not alone. ELD technology isn’t just new to you—it’s new to the industry and to law enforcement too.

“There are still many small to midsize fleets dealing with the ELD learning curve and trying how they have to work in parallel with law enforcement. Some operators are not very clear on what to expect during a roadside inspection and what they will need to do when it happens,” said James McCarthy, business development manager for ELD with Continental Commercial Vehicles and Aftermarket. “We have reached out to both fleets and law enforcement on ELD compliance. In the process of conducting information courses on the subject, we readily see the lack of understanding in the market and the overall confusion about the requirements, which can vary from state to state, and the tools that will be needed to meet the April 1 deadline.”

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One of the biggest points of confusion today is the role of AORBDs.

“Many of our fleets that are grandfathered in with AOBRD are receiving fines from officers who don’t fully understand that these fleets are still compliant,” said Erin Cave, vice president of mobile products for Verizon Telematics. “Also, the nuance around adding new or incremental vehicles to an AOBRD fleet has made it difficult for fleets to manage two different systems.”

A quick refresher about the mandate difference between AOBRD and ELD: AOBRD was the ELD’s predecessor in terms of technology, and the FMCSA approved their compliance until Dec. 16, 2019, only on the condition that it was installed prior to the effective date of the mandate. Many fleets currently operating a full-featured AOBRD should start to consider how they plan to transition their drivers to ELD solutions.

So, how has this two-pronged compliance approach impacted compliance today? According to PeopleNet’s Witty, grandfathering in AOBRDs leading up to the full use mandate in 2019 has created challenges during roadside inspections, in part due to the huge number of ELD providers, which means that law enforcement officials are faced with navigating dozens of different types of displays—some are AOBRDs and others are ELDs, which can add to the confusion.

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“The transition is also more complex for fleets that have deeply integrated AOBRDs,” he said, “meaning that they use the HOS data for other parts of their business such as dispatch or maintenance. The data that is deeply embedded in these other systems means that their transition from AOBRDs to ELDs can be more challenging than a fleet that was previously paper-based or one that does not have any data integrations currently.”

“AOBRD solutions require the officer to manually go through a driver’s logs, a highly time-consuming process,” Geotab’s Sutarik said. “ELDs are required to be able to transmit a data file containing the driver’s RODs and other information to the FMCSA’s eRODS server for analysis. Officers will then use this software to help identify hours of service violations and analyze the data.”

“We see a turbulent marketplace as we roll toward the end of the year,” Continental’s McCarthy said. “Fleets who have been grandfathered with an AOBRD will have to abandon their devices when the law comes into effect. They will need to start searching for and make a decision on the best ELD for their needs. This will initiate yet another learning curve and adjustment in how they manage their compliance activities.”

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If you’re breathing into a paper bag right now, it’s okay: Just tell yourself that you’re not alone. Your ELD provider of choice should be able to help you with any questions, technology issues or even lend an open ear to hear your concerns.

“The most important thing is to learn and understand how your ELD works and make sure the company that supplied it to you is a good partner and can support you during your learning curve and compliance efforts,” McCarthy said. “The keys to success in the mandate area are simple: Have an approved ELD device in the vehicle; know how to use it; and make sure you have the ‘in-cab card’ in the vehicle and ready to show the inspector.”

Implementation step two: Teach others within your fleet how your ELDs work

How you interact with your drivers differs from other fleet operations, but ensuring that the men and women behind the wheel of your trucks understand your ELD solution should be a constant. Start with brushing up on the hours-of-service (HOS) basics.

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“What some fleets don’t realize is that the mandate does not change any of the hours-of-service rules. It only impacts how the HOS data is collected,” PeopleNet’s Witty said.

“In our experience, the general knowledge of HOS in the market is not only very weak but also complicated by the exacting standards of technology,” Continental’s McCarthy agreed. “Drivers accustomed to planning their activities manually are now trying to structure their day following the rigid requirements of a 14-hour clock and using criteria dictated by an automated device. This raises a lot of questions, creates information gaps and adds to the confusion. The biggest issues are time management and what you need to do at a roadside inspection stop.”

Communication during roadside inspections is key.

“If using AOBRDs, drivers need to be trained and equipped with proper documentation so that inspectors will not attempt to cite them for failing to produce electronic data file transfers,” GPS Insight’s Gaither explained. “ELD admins need to fully understand and train their drivers to understand the differences unique to ELDs. These include the device’s absolute requirement to identify a driver for even very short movements.

“Drivers need to certify their previous days logs daily and report unidentified driver movements that do not belong to them—more than simply rejecting them,” he continued. “Drivers also will need to understand how to use the vendor’s software to edit their own logs for accuracy and compliance as the rules now make a driver primarily responsible for these instead of the office. Compliance administrators need to be tasked to manage logs daily and work with drivers on log corrections immediately, as these can add up quickly.”

Implementation step three: Think beyond ELD functionality

If you’ve made it this far, congrats! You’ve taken the first step toward not only getting back to business as usual, but also making that business more profitable. Robust telematics platforms that incorporate ELD compliance can also help you improve your fuel efficiency, boost driver safety and raise the quality of service your fleet provides.

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“Fleets can leverage telematics data for a vast array of applications beyond fuel economy,” Geotab’s Sutarik recommended, noting that 81% of Geotab customers utilize device plans that also offer actionable insight and tools surrounding increased productivity, fleet optimization, improved driver safety and fuel efficiency.
“Other telematics data that fleets can benefit from include remote diagnostics, IFTA fuel tax reporting and helping to improve driver behavior by accessing data surrounding speed, harsh braking and idling time,” he said.

“The view of many of our customers is that if you are going to take the time to implement technology, it makes sense to use it to your advantage and realize all of the benefits available through a fleet management system [FMS],” PeopleNet’s Witty said. “While these might be new benefits to previously paper-based fleets, our technology allows our platform to go well beyond these. PeopleNet’s Video Intelligence, real-time fault code monitoring, predictive analytics—these are just a few examples of a more robust FMS.”

While your drivers are coming to terms with the fact that ELDs will make their jobs a little more confusing and difficult in the short-term, remind them that, long-term, driver safety is one of the ELD advantages.

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“Driver safety metrics are widely available to monitor how drivers are operating these trucks in order to help coach them on safer behaviors,” GPS Insight’s Gaither noted, reporting that the majority of GPS Insight customers also employ other functionality to benefit outside of compliance, including navigation, messaging, dispatching and important fleet KPIs to improve efficiencies and simplify fleet management. “Driver safety metrics will likely reduce the number of accidents across a fleet, reducing costs significantly, and will also reduce the number of citations given for infractions like speeding and many others.”

EROAD’s Creager noted that a user-friendly ELD can also improve a driver’s productivity.

“Driver retention is a major issue in today’s market and keeping drivers happy and on the road is key to your ultimate success. If they are happy and driving, your fleet costs go down,” he said. Creager pointed to telematics modules and features that enhance operations such as the ability to automate International Fuel Tax Agreement (IFTA) reports to maximize operational savings.

Continental’s McCarthy noted that many fleets they work with are also forward looking and anticipating emerging technologies and opportunities.

“In addition to our expertise in electronic log technology and ELDs, Continental is also a major commercial tire manufacturer, as well as a global supplier of systems and components for truck manufacturers,” McCarthy noted. “We see an opportunity and an advantage to incorporate some of our technologies into an aftermarket platform to better improve and diagnose both driver and vehicle performance and efficiency.”

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“The possibilities are endless,” Navistar’s Dondlinger agreed. “It’s not only measuring how driver behavior is affecting vehicle efficiency—things like measurement of the cost of harsh braking, harsh cornering or rapid acceleration. Trailer monitoring is another great example: If you’re communicating the unused capacity of your trailer to a load board, they can offer you an added load to pick up on your route, meaning extra revenue in the driver’s pocket.”

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