Upload
vantruc
View
221
Download
0
Embed Size (px)
Citation preview
© 2016 Omnitracs, LLC. All rights reserved. 1
ELD Mandate Review
Tom Cuthbertson
TTA Safety Management
Council and Maintenance
Council
Agenda
• Final ELD Mandate Timeline
• What is in ELD Mandate
• Supporting Documents
• Changes in the final rule
o Who must comply
o Enforcement transfer requirements
o Display requirements
• What is in the final rule?
o Driver control of RODs
o Security / Certification requirements
• Operational Considerations
ELD Short Glossary of Terms
• AOBRD – Automatic Onboard Recording Device
• DOT – Department of Transportation
• ELD – Electronic Logging Device
• EOBR – Electronic Onboard Recorder
• FIPS – Federal Information Processing Standards
• FMCSA – Federal Motor Carrier Safety Administration
ELD Short Glossary of Terms
• HOS – Hours of Service
• NPRM – Notice of Proposed Rulemaking
• NIST – National Institute of Standards and Technology
• OMB – Office of Management and Budget
• OST – Office of the Secretary of Transportation
• PKI – Public Key Infrastructure – Encryption Certificates
• RODS – Record of Duty Status
• SNPRM – Supplemental Notice of Proposed Rulemaking
December 16, 2015
Final published
January 16, 2016
Effective date
December 2017
Compliance date
December 2019
Last date to be able to use AOBRD
AOBRD | Automatic
Onboard
Recording Device
AOBRD can be installed from
any time before published date up to the
compliance date ..Transfer of AOBRD
after compliance date not allowed
ELD Mandate Final Timeline
Final Federal Register Dates
• Prohibition of Coercion –
o $16K Penalty - 11/30/2015
• ELD Mandate used of electronic logging devices
o Final date 12/16/2015
• Does not change Hours of Service
• Technical update
• Address Harassment
• Supporting Documents
• Security
• More formal Certification
• Information electronically transferred to enforcement
What is this ELD Regulation?
© 2016 Omnitracs, LLC. All rights reserved. 8
• 1 ELD Function describes an ELD as follows: “The ELD discussed in this appendix is an electronic module capable of recording the electronic records of duty status for CMV drivers using the unit in a driving environment within a CMV and meets the compliance requirements in this appendix.”
• This means that any and all components that are required for compliance in an ELD will have separate certification and registration
Definition of an ELD
• Submit employer supporting documents 13 days of either the 24-hour period to which the documents pertain or the day the document comes into the driver’s possession, whichever is later.
TYPES OF DOCUMENTS IDENTIFIED
• Each bill of lading, itinerary, schedule, or equivalent document that
indicates the origin and destination of each trip;
• Each dispatch record, trip record, or equivalent document;
• Each expense receipt related to any on-duty not driving time
Each electronic mobile communication record, reflecting
communications transmitted through a fleet management system; and
• Each payroll record, settlement sheet, or equivalent document that
indicates payment to a driver.
• 8 Documents in 24-hour period
Supporting Documents
Each Document
A. Driver or Tractor ID
B. Date of transaction
C. Location of transaction
D. Time Zone
Fewer than 8 containing elements if have A,B,C qualify
Supporting Documents – Cont.
Who is Affected? Who is Affected? • Any driver that is required to keep Records of Duty Status
(approx. 3.1 million)
o Includes drivers who keep RODS for more than 8 days in any 30 day period.
− Short haul regulation remains the same, no RODS required
o Includes rental equipment (no reference to short term rental)
Exemptions
• Vehicles manufactured prior to 2000
o Answer to mechanical engines comment – RODS still needed
o If truck has ECM, may use ELD
• Driveaway - Towaway, provided the vehicle driven is part of shipment, RV, Motor Home – Fast Act
• If using RODS less than 8 days in 30
© 2016 Omnitracs, LLC. All rights reserved. 12
Login/Logout
Power-up and Power-down
Yard Move
Personal Conveyance
Intermediate position
Diagnostic Event
Malfunction Event
Introduction of Events
© 2016 Omnitracs, LLC. All rights reserved. 13
• Vehicle VIN
• Beginning and Ending Odometer and Engine hours
• Driver CDL # and State
• Exempt status
• Data Diagnostics
• ELD Malfunctions
• Unidentified Driver Records
• Body of Log Detail to display all events and duty status
DISPLAY STILL VALID for Roadside Inspection if can be viewed without enforcement entering the vehicle
Display Options in Final Rule Increase
Additional Information
• Yard Moves – Not Drive, Only On-Duty
• Drive Starts at up to 5 MPH
• Only Auto On-Duty when stopped 5 minutes
• Driver Interaction – Traffic Considerations
• Proposed item of Interoperability between
providers
• Significant More Driver Control
• Create transfer file for roadside - eRODS
• ELD must be repaired within 8 days.
ELD final rule
eRODS File Transmission
Acceptable methods to transmit data
Safety official will select method
Enforcement must be capable of one from each
Telematics Transfer Method
•Web Services
•Email SMTP
Peer to Peer Transfer Method
•Bluetooth Web service local network
•USB 2.0
Or
© 2016 Omnitracs, LLC. All rights reserved. 17
Drivers must certify logs – 24 hour of
operation
Must certify log edits even if out of window
of the 8 days
When accepting or rejecting back office
edits - annotation
Driver Log Certification
• Allow drivers to edit their logs and create
annotations on all entries and edits – cannot reduce
drive time
• Drivers must approve all edits from Support
Systems before applied
• Require that drivers have direct access to the log
information
• Personal Conveyance – do not record all engine
information – 10 mile accuracy on GPS
• Audible muting of devices by driver
• Driver reviews unassigned vehicle moves
• Daily certification of logs and for all edits - by driver
or carrier
ELD Final – Items Specific For Drivers (address harassment)
ELD Certification Process
• ELD providers register their ELD with FMCSA
• Request a user account
• Register an ELD
• Provide required information • Device Name, Model Number, Software Version, ELD Identifier,
Image, User Manual, Company, Contact Company (Phone),
Contact Company (Email), Company Website
• Self-certify that the ELD meets the technical spec
• Process to update when modifications made
ELD Certification Process
• FMCSA will provide
• Authentication key(s)
• Authentication file(s)
• Registration number
• Used in ELD log file for verification
• Currently available for certification
ELD Certification Process
• Shortcomings of the Process
• Anyone can claim to be certified
• Anyone can register an ELD
• If FMCSA finds that an ELD listed on its website does
not comply with the technical specifications, FMCSA
may initiate removal of an ELD model or version from
its list by providing written notice to the ELD
• By then it may be too late for the carrier that may
have spent tens of thousands of dollars
• 454 page test document to pass
Telematics Transfer Method
• Web Services
• Email SMTP
Peer to Peer Transfer Method
• Bluetooth
• USB 2.0
• Web Service and email
• FIPS publication 197
• NIST SP 800-32
• Bluetooth
• Discoverable
• Generate random code
• USB thumb drive
• AES – 256 Security
Transfer Security
Unassigned Driving Time
• Unassigned Driving – Presented to Driver
• What are operational causes?
• Driver forgets to login
• Mechanic road test
• Relocating tractor to another yard not by
driver
• Correction after the fact
• Upon login, a driver is prompted to accept or
decline unassigned driving time
• Any declined time must be reconciled by
carrier by annotating the record
Unassigned Driving Time
• ELD states each driver needs a driver ID
• Prevention – EXEMPT DRIVER
• Create login for each use of vehicle
• Mechanics that road test have CDL
• Relocation of vehicles
• Make sure drivers log in
• Devices can provide warning upon wheel move
EXEMPT DRIVER CAN BE USED FOR SHORT HAUL
• Drive – From any other duty status to Drive when motion is
detected and the speed reaches a maximum of 5 MPH • There is NO TIME / NOR DISTANCE consideration
• On-Duty – From Drive after 5 minutes of no detected motion
and after 1 minute of driver being prompted
• Yard Move – this an event that the driver puts themselves in as
a duty status
• In RODS it is to be recorded as “on duty” time and NOT
DRIVE
Auto Duty Status & Yard Move
• Shortcomings of the event • There are no limits around it
• There are no defined thresholds for it
• There are no automatic duty status changes allowed
• Possible Solutions • FMCSA only offers log editing as an alternative
• Vendors could implement warnings around it
Yard Move
© 2016 Omnitracs, LLC. All rights reserved. 27
Discussion on AOBRD grandfather
Discussion on Web Services –
certification
Recent FMCSA Verbal
Communications
• What about gliders ? – VIN number
• Where can I use yard moves?
• Are there specific mounting requirements for the ELD
device?
• What happens when a driver is in a break and is forced to
move the vehicle?
• ELD and Short Haul?
• How should we handle rentals?
• What restriction on fleet management systems?
• Shipper makes leave out of hours?
Frequently Asked Questions