One of the more heavily attended sessions during Trimble’s in.sight user conference held in Houston, Texas, Sept. 16-18 was an update and Q&A session on the upcoming electronic logging device mandate featuring Joe DeLorenzo, chief enforcement officer, Federal Motor Carrier Safety Administration.
Before taking questions about specifics of the mandate (of which there were many), DeLorenzo reviewed some of the FMCSA’s findings of ELD use so far.
Without a doubt, hours-of-service compliance improves with ELD use, he said. The percentage of driver inspections with at least one HOS violation fell from 1.3% in December 2017 to 0.69% in April 2018 down to 0.57% in June 2019. He said they are seeing 35,000 successful transfers of ELD data monthly – an 80% success rate.
On the other hand, the agency has not seen a corresponding reduction in violations for false logs since ELDs came on the scene. “There a lot of drivers that are misapplying the rule," he said.
He advised fleet managers to make sure that whatever manual entries they or their drivers are making, they are doing them correctly.
What kind of errors are inspectors seeing? He said they are seeing “really simple stuff.” The most commonly cited ELD violations during roadside inspections are:
- Failing to maintain paperwork such as ELD instruction manuals, data transfer instructions, or blank paper logs.
- The device is unable to transfer log data when requested by the inspecting officer.
- Portable ELD is not mounted properly.
“Make sure the drivers know how to transfer data,” he said. "And that he has all supporting documentation that’s required."
He added that drivers need to give the inspecting officer some insight into what devices they are using. “Keep going over the basics with drivers,” he advised.
He said that using web services to transfer log data was preferable to an email transfer.
For motor carriers, the most commonly cited ELD violations included:
- The motor carrier failed to ensure driver’s ELD record was accurate.
- The motor carrier failed to electronically produce ELD records upon request.
- The motor carrier failed to review records of unassigned driving and/or annotate the record explaining why the time is unassigned.
As for edits and annotations to the ELD record, DeLorenzo noted that drivers can make such edits, but they cannot shorten the drive time and the ELD data must be re-certified after it has been edited and the original records must be maintained.
Carriers can request edits after ELD records have been submitted, but annotations are required to explain the edits. He reminded fleet managers that unassigned miles must be addressed prior to operating a commercial motor vehicle the next day. He also advised carriers to be certain that data entered manually is correct.
Questions from those in attendance were varied and covered such topics as how to deal with unassigned drivers such as mechanics moving a vehicle, or how to handle a situation where an inspecting officer asks for data but the vehicle in out of cellular range. DeLorenzo also talked about dealing with unassigned drivers such as mechanics, which could be classified as a yard move.