9-22-17 Handout Intro Pages€¦ · days after the ELD Rule is published (February 16, 2016) Compliance date is 2 years after ELD Rule is published (December 18, 2017) AOBRDs must

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S E M I N A R

Thank you for attending our seminar:

Presented by:

Kevin Stewart, President & CEO, Pennsylvania Motor Truck Association (PMTA) &

Blake Risker, Account Executive, J.J. Keller & Associates, Inc.

Electronic Logging Devices:

All You Need to Know

September 22, 2017

Table of Contents


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The information contained in this handout is proprietary property of Fundamental Labor Strategies®, Inc.

Do not distribute or reproduce without the express written permission of Fundamental Labor Strategies®, Inc. © 2006-2017 Fundamental Labor Strategies®, Inc.

FUNDAMENTAL LABOR STRATEGIES®, INC. About FLS……………………………………………………………………………………..……………3

What We Do and Why Quick Facts Our Credentials Benefits of Partnering with FLS Contact Information

TODAY’S SEMINAR Event Details…………………………………………………………………….………………………….4

Agenda What You Will Learn

About the Speakers……….…………………………………….……………...………….……………..5 & 6

Background Information Contact Information

Social Media Information.....………………………………………………………………………………...7 PowerPoint Slides...………..………………………………………………………………………………...8

“Electronic Logging Devices: All You Need to Know”

About FLS


WHAT WE DO AND WHY

Driver employers universally face challenges in four basic areas (see pie chart, right). We provide products that address and solve these fundamental driver employer issues including:

Commercial Truck Driver Leasing DOT Compliance Products Risk Management Products Market Research

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Founded in 1991, privately owned Serving markets from Boston, MA to Richmond, VA Core attributes: Pioneering, Straightforward, Experienced Proprietary research data is the foundation for all that we do Close ties to the transportation and professional driver industries and their advocates

OUR CREDENTIALS

Over 25 years of experience in all aspects of driver employment and management Strength in managing the four basic driver employer challenges:

We plan for, manage, and cover driver absences We partner with some of the best people and institutions in these areas We maintain a strong DOT compliance and safety first philosophy We improve and add value to your customer relations We manage risk through careful loss prevention and control

Data driven: the utilization of critical data extracted from over 45,000 driver and motor carrier interviews in our business decisions and recommendations to clients

BENEFITS OF PARTNERING WITH FLS

Your level of customer service is increased Your costs are transferred, reduced, and predictable You can focus more on your core business Your operational control increases Your risk is managed

CONTACT INFORMATION

Telephone: (215) 862-7280 or (877) 357-7776 Email: [email protected] Website: www.FundamentalLabor.com

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Relations

Our mission is to establish and maintain mutually beneficial, open, direct, and long-term relationships with our em-ployees, customers, and suppliers.

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Risk

Management

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“

AGENDA 08:30 am - 09:00 am Guest Arrival and Continental Breakfast

09:00 am - 10:30 am Speaker Part I; Kevin Stewart

10:30 am - 10:45 am Mid-Morning Break

10:45 am - 12:00 pm Speaker Part II; Blake Risker

12:00 pm - 01:00 pm Buffet Lunch

WHAT YOU WILL LEARN Today’s seminar will feature an overview of the FMCSA’s mandate regarding Electronic Logging Devices including: Compliance dates

Applicability

Exemptions

Display and Transmission of Data

Approved Devices

Performance Requirements

Requirements During Roadside Inspections

Violations

Solutions & Examples


Event Details

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BACKGROUND INFORMATION

Mr. Kevin Stewart became the President and CEO of the Pennsylvania Motor Truck Association in July of 2016 and has served as the Association’s Director of Safety since 2013.

Prior to joining the staff at PMTA, Mr. Stewart had a distinguished 33 year career in the Commonwealth of Pennsylvania’s Commercial Vehicle Safety Program. Starting as a roadside enforcement officer, Stewart progressed through the ranks to become a regional manager and he oversaw the operation of 10 of the Commonwealth’s 28 Commercial Vehicle Enforcement Teams and the division’s administrative staff.

About the Speakers

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Kevin Stewart President & CEO

Email: [email protected]


BACKGROUND INFORMATION

Mr. Blake Risker is the Account Executive for J.J. Keller & Associates, Inc. and has been with the company since 2013. He has extensive experience in Electronic On-board Recorder (EOBR) and other transportation-related products. Blake focuses on connecting clients with effective solutions that reduce costs and ensure regulatory compliance.

About the Speakers

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Blake Risker Account Executive

Email: [email protected]


Social Media

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Kevin N. Stewart, President & CEO1

Electronic Logging Device

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Major Components of ELD Rule

• Requirements for the mandatory use of ELDs by most drivers currently required to prepare Record of Duty Status (RODS)

• Minimum performance and design standards (Technical Specifications) for ELDs

• Requirements for Hours of Service (HOS) supporting documents

• Measures to prevent harassment through the use of ELDs

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Who is required to use an ELD?

• Interstate CMV drivers currently required to keep RODS Subject to requirements in 49 CFR 395.

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Interstate Commercial Motor Vehicle

• Commercial motor vehicle means any self‐propelled or towed motor vehicle used on a highway in interstate commerce to transport passengers or property when the vehicle;– Has a gross vehicle weight rating or gross combination weight rating, or gross vehicle weight or gross combination weight, of 10,001 pounds or more, whichever is greater;

– Is designed or used to transport more than 8 passengers (including the driver) for compensation;

– Is designed or used to transport more than 15 passengers, including the driver, and is not used to transport passengers for compensation;

– Transports hazardous materials in a quantity requiring placarding.

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Phase 1 Awareness and Transition

Registration and voluntary use of ELDs begins 60 days after the ELD Rule is published (February 16, 2016)

Compliance date is 2 years after ELD Rule is published (December 18, 2017)

AOBRDs must be upgraded or replaced with ELDs within 4 years of the publication of the Final Rule (December 16, 2019) I.e., AOBRDs compliant with § 395.15 that were installed before the compliance date could be used (grandfathered) for 2 years after the compliance date

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AOBRD Definition

• Automatic on‐board recording device means an electric, electronic, electromechanical, or mechanical device capable of recording driver's duty status information accurately and automatically as required by §395.15. The device must be integrally synchronized with specific operations of the commercial motor vehicle in which it is installed. At a minimum, the device must record engine use, road speed, miles driven, the date, and time of day.

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Information Requirements

• AOBRD must produce on demand– The driver’s hours of service chart, electronic display or printout.

– Time and sequence of duty status changes– Driver’s start time for each day– Information must be provided for current day and 7 previous consecutive days.

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Electronic Display Requirements

• Driver's total hours of driving today.• The total hours on duty today.• Total miles driving today.• Total hours on duty for the 7 consecutive day period, including today.

• Total hours on duty for the prior 8 consecutive day period, including the present day.

• The sequential changes in duty status and the times the changes occurred for each driver using the device.

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On‐board Information

• An instruction sheet describing in detail how data may be stored and retrieved from an automatic on‐board recording system.

• A supply of blank driver's records of duty status graph‐grids sufficient to record the driver's duty status and other related information for the duration of the current trip.– Drivers are required to note any failure of automatic on‐board recording devices, and to reconstruct the driver's record of duty status for the current day, and the past 7 days, less any days for which the drivers have records, and to continue to prepare a handwritten record of all subsequent duty status until the device is again operational.

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Device with Logging Software and Applications

• Not Integrally Synchronized

• Manually input driving duty status

• Not an AOBRD

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Interpretation

• Question 28: May a driver use a computer, tablet, or smartphone (that is not an Automatic On‐Board Recording Device) to create, electronically sign, and store the record of duty status (RODS)?

• Guidance: Yes. A driver may make manual duty‐status entries to a computer, tablet, or smartphone program that is used to generate the graph grid and entries for the record of duty status (RODS) or log book, provided the electronically‐generated display (if any) and output includes the minimum information required by §395.8 and is formatted in accordance with that section. The driver must sign the RODS (manually or electronically) at the end of each 24‐hour period to certify that all required entries are true and correct.

– If electronic signatures are not used:– The driver must print and manually sign the RODS daily.– The driver must have in his or her possession the printed and signed RODS for the prior seven

consecutive days (if required on those days).– The driver should be given an opportunity to print and manually sign the current day’s RODS at the

time of the inspection.• If RODS have been electronically signed:

– At the time of an inspection of records by an enforcement official, the driver may display the current and prior seven days RODS to the official on the device’s screen.

– If the enforcement official requests printed copies of the RODS, the driver must be given an opportunity to print the current and prior seven days RODS (if required on those days) at the time of inspection. 13

ELD Definition 395.2

• Electronic logging device (ELD) means a device or technology that automatically records a driver’s driving time and facilitates the accurate recording of the driver’s hours of service, and that meets the requirements of subpart B of this part.

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Exemptions

• 100 air‐mile radius drivers may continue to use timecards, as allowed by §395.1(e)(1)

• 150 air‐mile radius non‐CDL freight drivers may continue to use timecards, as allowed by §395.1(e)(2)

• Using paper RODS for not more than 8 days during any 30‐day period

• In a driveaway‐towaway operation in which the vehicle being driven is part of the shipment being delivered.

• Driving vehicles manufactured before model year 2000

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Short Haul Operations100 air‐mile radius driver. (395.1(e)(1))

• A driver is exempt from the requirements of Section 395.8 if:

• The driver operates within a 100 air‐mile radius of the normal work reporting location;

• The driver returns to the work reporting location and is released from work within 12 consecutive hours;

• The driver has at least 10 consecutive hours off duty separating each 12 hours on duty;

• The driver does not exceed 11 hours maximum driving time following 10 consecutive hours off duty; or

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Hours of Service ExemptionsShort‐haul operations 100 air‐mile radius driver.

• The motor carrier that employs the driver maintains and retains for a period of 6 months accurate and true time records showing:

• The time the driver reports for duty each day;

• The total number of hours the driver is on duty each day;

• The time the driver is released from duty each day; and

• The total time for the preceding 7 days.

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Short Haul Operations

Operators of property‐carrying commercial motor vehicles not requiring a commercial driver's license. 395.1(e)(2)• A driver is exempt from the requirements of §395.3(a)(2) and

§395.8 if:• The driver operates a property‐carrying commercial motor

vehicle for which a commercial driver's license is not required. • The driver operates within a 150 air‐mile radius of the location

where the driver reports to and is released from work, i.e., the normal work reporting location;

• The driver returns to the normal work reporting location at the end of each duty tour;

• The driver does not drive:(A) After the 14th hour after coming on duty on 5 days of any period of 7 consecutive days; and(B) After the 16th hour after coming on duty on 2 days of any period of 7 consecutive days; 19

Hours of Service ExemptionsOperators of property‐carrying commercial motor vehicles not requiring a commercial driver's license.

• The motor carrier that employs the driver maintains and retains for a period of 6 months accurate and true time records showing:

• The time the driver reports for duty each day;

• The total number of hours the driver is on duty each day;

• The time the driver is released from duty each day; and

• The total time for the preceding 7 days.

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ELD Rule

• Certification: Manufacturers are required to test and certify to FMCSA that their devices meet the new standards. FMCSA will create a public (i.e. Internet) registry of compliant devices and conduct tests to verify manufacturers’ claims.

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Registered ELD’shttps://3pdp.fmcsa.dot.gov/ELD/ELDList.aspx

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Removal of Registered ELDs

• Written notice to ELD provider• Response from provider required in 30 days• Failure to respond will result in the removal of the ELD form registration list

• Provider has 60 days to correct ELD non‐compliance

• If correction(s) aren’t made within 60 days, the ELD will be removed

• The provider may then request an Administrative Review

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ELD Information – Daily Header

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ELD Information – Daily Header

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Graph Grid• The printout and display must show a graph‐grid consistent with § 395.8(g) showing each change of duty status.

• The graph‐grid must overlay periods of driver’s indications of personal use and yard moves using a different style line (such as dashed or dotted line) or shading.

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Automatically Recorded Data

• Data automatically recorded when a driver indicates a duty status change or when a commercial motor vehicle is in motion and there has not been a duty status change or another intermediate recording in the previous 1 hour.– (1) Date;– (2) Time;– (3) CMV geographic location information;– (4) Engine hours;– (5) Vehicle miles;– (6) Driver or authenticated user identification data;– (7) Vehicle identification data; and– (8) Motor carrier identification data. 29

ELD Detail Log Data

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Geolocations

• CMV Geographic Location Information – Show a nearby city, town, or village, or the compass direction and distance from the nearest city, town, or village

– During on‐duty driving periods, the location accuracy is approximately within a 1‐mile radius

– When a CMV is used for personal use, the position reporting accuracy is approximately within a 10‐mile radius

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ELD Requirements• Driver’s ELD Volume Control• (a) If a driver selects the sleeper‐berth state for the driver’s record of duty status, and no co‐driver has logged into the ELD as on‐duty driving, and if the ELD outputs audible signals, the ELD must either:– (1) Allow the driver to mute the ELD’s volume or turn off the ELD’s audible output, or

– (2) Automatically mute the ELD’s volume or turn off the ELD’s audible output.

• (b) For purposes of this section, if an ELD operates in combination with another device or other hardware or software technology that is not separate from the ELD, the volume controls required herein apply to the combined device or technology.

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Roadside Inspections

• The ELD must be able to generate a compliant report either as a printout or on a display.

• An ELD must be designed so that its display may be reasonably viewed by an authorized safety official without entering the commercial motor vehicle. For example, the display may be untethered from its mount or connected in a manner that would allow it to be passed outside of the vehicle for a reasonable distance.

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Roadside Inspections

• The printout and display must show a graph‐grid consistent with § 395.8(g) showing each change of duty status.– On the printout, the graph‐grid for each day’s RODS must be at least 6 inches by 1.5 inches in size.

– The graph‐grid must overlay periods of driver’s indications of authorized personal use of CMV and yard moves using a different style line (such as dashed or dotted line) or shading. The appropriate abbreviation must also be indicated on the graph‐grid.

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Data Transfer During Roadside SafetyInspections

• During a roadside safety inspection, an ELD must produce ELD records for the current 24‐hour period and the previous 7 consecutive days in electronic format.

• To meet roadside electronic data transfer requirements, an ELD must do at least one of the following:– (1) Option 1—Telematics transfer methods. Transfer the electronic data

using both:• (i) Wireless Web services, and• (ii) Email, or

– (2) Option 2—Local transfer methods. Transfer the electronic data using both:

• (i) USB2 • (ii) Bluetooth

• An authorized safety official will specify which transfer mechanism the official will use within the certified transfer mechanisms of an ELD.

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eRods

• All electronic data will be analyzed by Electronic Records of Duty Status (eRODS)

• Potential hours of service violations identified• Falsification and tampering alerts• Safety officials will continue exercise investigative techniques

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ELD Malfunctions 395.34

• (a)Recordkeeping during ELD malfunctions. In case of an ELD malfunction, a driver must do the following:– (1) Note the malfunction of the ELD and provide written notice of the malfunction to the motor carrier within 24 hours;

– (2) Reconstruct the record of duty status for the current 24‐hour period and the previous 7 consecutive days, and record the records of duty status on graph‐grid paper logs that comply with § 395.8, unless the driver already possesses the records or the records are retrievable from the ELD; and

– (3) Continue to manually prepare a record of duty status in accordance with § 395.8 until the ELD is serviced and brought back into compliance with this subpart.

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ELD Malfunctions 395.34• (b) Inspections during malfunctions. When a driver is inspected for

hours of service compliance during an ELD malfunction, the driver must provide the authorized safety official the driver’s records of duty status manually kept as specified under paragraphs (a)(2) and (3) of this section.

• (c) Driver requirements during ELD data diagnostic events. If an ELD indicates that there is a data inconsistency that generates a data diagnostic event, the driver must follow the motor carrier’s and ELD provider’s recommendations in resolving the data inconsistency.

• (d) Motor carrier requirements for repair, replacement, or service. – (1) If a motor carrier receives or discovers information concerning the

malfunction of an ELD, the motor carrier must take actions to correct the malfunction of the ELD within 8 days of discovery of the condition or a driver’s notification to the motor carrier, whichever occurs first.

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ELD In‐Vehicle Information• A motor carrier must ensure that its drivers possess onboard a commercial motor vehicle an ELD information packet containing the following items:– (1) A user’s manual for the driver describing how to operate the ELD;

– (2) An instruction sheet for the driver describing the data transfer mechanisms supported by the ELD and step‐by‐step instructions for the driver to produce and transfer the driver’s hours‐of‐service records to an authorized safety official;

– (3) An instruction sheet for the driver describing ELD malfunction reporting requirements and recordkeeping procedures during ELD malfunctions; and

– (4) A supply of blank driver’s records of duty status graph‐grids sufficient to record the driver’s duty status and other related information for a minimum of 8 days.

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Special driving categories; otherdriving statuses.

• A motor carrier may configure an ELD to authorize a driver to indicate that the driver is operating a commercial motor vehicle under any of the following special driving categories:– (i) Authorized personal use; and– (ii) Yard moves.

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Off Duty – Personal Conveyance

• Question 26: If a driver is permitted to use a Commercial Motor Vehicle (CMV) for personal reasons, how must the driving time be recorded?

• Guidance:When a driver is relieved from work and all responsibility for performing work, time spent traveling from a driver’s home to his/her terminal (normal work reporting location), or from a driver’s terminal to his/her home, may be considered off‐duty time. Similarly, time spent traveling short distances from a driver’s en route lodgings (such as en route terminals or motels) to restaurants in the vicinity of such lodgings may be considered off‐duty time. The type of conveyance used from the terminal to the driver’s home, from the driver’s home to the terminal, or to restaurants in the vicinity of en route lodgings would not alter the situation unless the vehicle is laden. A driver may not operate a laden CMV as a personal conveyance. The driver who uses a motor carrier’s Commercial Motor Vehicle (CMV) for transportation home, and is subsequently called by the employing carrier and is then dispatched from home, would be on‐duty from the time the driver leaves home.

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Special driving categories; otherdriving statuses.

• Drivers exempt from ELD use. A motor carrier may configure an ELD to designate a driver as exempt from ELD use.

• A driver operating a commercial motor vehicle under any exception under § 390.3(f) of this subchapter or § 395.1 who is not covered under paragraph (a) or (b) of this section must annotate the driver’s ELD record to explain the applicable exemption.– Agriculture Exemption– Utility Service Vehicle exemption

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Edits• An ELD must not allow automatically recorded driving time to

be shortened or the ELD username associated with an ELD record to be edited or reassigned, except under the following circumstances:

– (1) Assignment of Unidentified Driver records. ELD events recorded under the ‘‘Unidentified Driver’’ profile may be edited and assigned to the driver associated with the record; and

– (2) Correction of errors with team drivers. In the case of team drivers, the driver account associated with the driving time records may be edited and reassigned between the team drivers if there was a mistake resulting in a mismatch between the actual driver and the driver recorded by the ELD and if both team drivers were respectively indicated in each other’s records as a co‐driver. The ELD must require each co‐driver to confirm the change for the corrective action to take effect.

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Edits

• If a driver edits or annotates an ELD record or enters missing information, the act must not overwrite the original record.

• Driver or support personnel edits must be accompanied by an annotation. The ELD must prompt the driver to annotate edits.

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Edits• On review of a driver’s submitted records, the motor carrier may request edits to a driver’s records of duty status to ensure accuracy. A driver must confirm or reject any proposed change, implement the appropriate edits on the driver’s record of duty status, and recertify and resubmit the records in order for any motor carrier‐proposed changes to take effect.

• A motor carrier may not request edits to the driver’s electronic records before the records have been submitted by the driver.

• Edits requested by any system or by any person other than the driver must require the driver’s electronic confirmation or rejection.

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Supporting Documents

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Supporting Document Definition

• “A document, in any medium, generated or received by a motor carrier in the normal course of business as described in 395.11 that can be used, as produced or with additional identifying information, by the motor carrier and enforcement officials to verify the accuracy of a driver’s record of duty status.” [§395.2]

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Supporting Documents Data Elements

• Driver name (or carrier‐assigned ID) – Can be vehicle unit number if that number can be linked to the driver

• Date • Location (including the name of nearest city, town or village)

• Time

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Supporting Documents: Categories

• Bills of lading, itineraries, schedules, or equivalent with the origin and destination of each trip

• Dispatch records, trip records, or equivalent • Expense receipts related to on‐duty (not driving) periods

• Electronic mobile communication records • Payroll records, settlement sheets, or equivalent

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Supporting Documents: General

• Must be retained for 6 months • Must be submitted within 13 days • Driver must make supporting documents in his/her possession available to authorized Federal, State, or local official upon request

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Supporting Documents: General

• Link to driver’s record of duty status. A motor carrier must retain supporting documents in such a manner that they may be effectively matched to the corresponding driver’s record of duty status.

• Prohibition of destruction. No motor carrier or driver may obscure, deface, destroy, mutilate, or alter existing information contained in a supporting document.

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FAQ

• Can drivers operate commercial motor vehicles (CMVs) equipped with electronic logging devices (ELDs), if they are not required to use them due to an exception?

• Yes. A motor carrier can configure an ELD to show an exception for a driver who is exempt from using an ELD. The carrier can also use the ELD notes (annotation) capability to record the driver’s exempt status.

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FAQ

• How many electronic logging device (ELD) accounts can be established by a motor carrier for one of its ELD drivers?

• A motor carrier can establish only one account for each driver required to use an ELD. The carrier must also establish unique user identification and passwords.

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FAQ

• Can a driver’s electronic logging device (ELD) user single account be authorized for administrative functions, in addition to its driver‐related functions?

• No, administrative functions (creating, management, and approving accounts) cannot be performed from a driver account. For example, a driver who is also a company owner must have a single account as a driver, and a separate account for administrative functions.

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FAQ

• What must a driver do with unassigned driving time when he or she logs into the electronic logging device (ELD)?

• A driver must review any unassigned drive time when logging into the ELD. If the driving time is the driver’s, it must be added to his/her record. If the unassigned records do not belong to the driver, the driver must make a note (annotation) in the records to indicate this.

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FAQ

• Can an ELD record be set to record minimum duty status durations, such as 15 minutes?

• No, there is no minimum amount of time for ELD duty status recording. An ELD is more accurate, and records the actual time for each duty status entered.

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FAQ

• When will an electronic logging device (ELD) automatically start to record a driving mode or status?

• An ELD will switch to driving mode once the vehicle starts moving at a set speed threshold of no more than 5 miles per hour.

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FAQ

• When will an electronic logging device (ELD) automatically change the duty status from driving to the default duty status of on‐duty not driving?

• When the vehicle has not been in motion for five consecutive minutes, the ELD will prompt the driver to confirm driving status or enter the proper status. If the driver doesn’t respond within one minute, the ELD will switch to on‐duty not driving status.

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FAQ

• How does a driver use an electronic logging device (ELD) to designate special driving categories?

• ELDs allow drivers to indicate periods of authorized personal use (personal conveyance) or yard moves. A driver can use a note (annotation) for other special driving categories such as bad weather (adverse drive conditions) or oilfield operations.

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FAQ• What is the difference between an “edit” and an

“annotation”?• An edit is a change to an ELD record to add missing

information or correct a mistake. An annotation is a note to explain information in the record, or provide the reason for an update or edit. All edits must have notes (annotation), whether made by a driver or carrier.

• For example, an edit showing time being switched from “off‐duty” to “on‐duty not driving” could be annotated by the carrier to note, “Driver logged training time incorrectly as off‐duty.” This edit and annotation would then be sent to the driver for recertification.

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FAQ

• Would a motor carrier be non‐compliant with the ELD rule if the data cannot be sent electronically to an authorized safety official at roadside?

• No, if electronic transfer is unavailable or not working, the driver can comply by showing the ELD display or a printout of the RODS.

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Kevin Stewart – [email protected]‐761‐7122 x 107

Copyright © 2017J. J. Keller & Associates, Inc.All rights reserved.


Today’s Topics & Agenda

• Personalizing Your HOS Program

• Personalizing Your ELD Solution

• Implementation Best Practices

• KellerMobile™ – The Driver Experience

• Managing ELD Data & Your Fleet

• Moving Forward

• Q & A

2


J. J. Keller®

Electronic Hours of Service Portfolio

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ELD Policies & Procedures

The Audience to whom the policy applies.

The Behavior, or action, that you want or require.

The Conditions under which the policy applies.

The Discipline that will be taken if the policy is not complied with (the “teeth”).

The Exceptions that might apply.

Policies VS Procedures4


Personalizing Your ELD Solution

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Personalizing Your ELD Solution

• Driver-friendly app

• Back office ease of use

• Compliance support

• Vendor support and customer care

• Is the solution scalable for your future

• Technology flexibility

• Contractual considerations

• Regulatory changes

• Product Development commitment to ongoing improvement

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Getting a Handle on Current Assets

Knowing your fleet makes you prepared to work with vendors and ensure they have the features you need.

• Which of your units need ELDs?

• What classes of vehicles do you have, class 1 – 8?

• What type of vehicles do you have?

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Implementation Best Practices

• Considerations Change causes pain

Impact to your current operations

Shippers

• Rollout How to

Who to select

• Timeline

Begin with the end in mind

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Implementation Best Practice

Understanding the impact to your current routes:

Paper Log vs ELog

• Do the math.

• Paper log “flexibility”.

• Don’t be surprised. Be prepared.

• Remember, change causes pain.

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Copyright © 2017J. J. Keller & Associates, Inc.®

All rights reserved.

Implementation Best Practice

Customer Communication Guidance: Mutual Benefits

• Explaining the ELD mandate

• Explaining HOS rules

• Predict impact to delivery schedules

• Driver detention & excessive delays

• Your HOS policy

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• Senior management support –You can’t do this alone.

• Project sponsor & leadership team

• Driver champion

• Addressing non-driver personnel impacts

• Training

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• Expect mistakes

• Don’t underestimate the amount of training and coaching needed

• Train until they can't get it wrong

• Retrain

• Celebrate successes


“Be patient.”Dan YouhessOperations ManagerNiagara Scenic ToursHamburg, NY 12


Implementation Needs Assessment

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Implementation Best Practice - Timeline

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Managing ELD Data & Your Fleet

• Data management

• Audit risk

• Litigation

• Reducing the risk

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• Data is overwhelming

• No plan to manage data Dedicated person or team

Audit process

• What are you going to do with the data? Translating to actionable steps

Driver coaching

Common Challenges of Data Management

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Audit Risk with ELDs

• Discoverable Data is easy to see

• "Automatic” auditing System flags drivers operating over hours

• Edits Excessive or pattern

• Driver Roster & Ghost Accounts No driver assigned to vehicle

Safety/Maintenance people must have login

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ELDs & Litigation

• Proving the carrier is responsible for the crash If the driver had been following the hours-of-service

regulations, the crash would not have happened.

The driver was fatigued to the point that he/she was not making sound decisions at the time of the crash, and that lack of sound decision making either led to, or contributed to, the crash.

Indefensible

• “Duty to Act” & Punitive damages

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Reducing the Risk

• Policies & procedures

• Correctly using electronic logs

• Auditing processes

• Act on the data

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Moving Forward

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Questions?