Mandatory Use of Electronic Logging Devices

Companies operating commercial vehicle fleets have until Dec. 16, 2019 to switch from an Automatic On-Boarding Recording Device (AOBRD) to a Federal Motor Carrier Safety Administration (FMCSA) registered Electronic Logging Device (ELD).

An AOBRD is hardware that presents data through a display or printout. An ELD can transmit data immediately through a wireless service and email or by use of a USB and Bluetooth. Some carriers and drivers/operators think they are using an ELD when in reality they are using an AOBRD. To be compliant, check with your provider.

ELDs must:

• Automatically capture latitude/longitude coordinates with accuracy
• Record the vehicle location at least once every five miles of driving and at the change of duty status
• Automatically record driving status once the vehicle reaches 5mph unless the driver/operator selects a special driving category of Yard Move or Personal Conveyance (if allowed by carrier)
• Allow the driver/operator the ability to review, edit, and annotate the driver's/operator’s ELD record
• Allow all edits by the driver/operator or carrier to have an annotation explaining the reason
• Allow carriers to suggest edits on submitted logs, but the driver/operator must accept or reject the proposed edits and recertify
• Record unidentified driving trips when the vehicle is driven without a driver/operator logged in
• Prompt the driver/operator to approve or reject unidentified driving trips at login
• Allow the carrier, who is also responsible, to assign any unidentified trips or annotate why the time is unassigned
• Be able to transfer the ELD data electronically (web-based services and email) or by local (USB and Bluetooth) methods

Bottom line

Waiting too long to make the switch from AOBRD to ELD will not only increase your risk of being out of compliance but will also force drivers/operators and fleet managers to adjust to new rules and technology in a very short period of time. For more resources related to ELDs, read the FMCSA's Fast Facts sheet.

For additional guidance on ELDs, North Risk Partners clients should contact our partners at Integrated Loss Control by calling our Value-Added Services Hotline and selecting option 2.

Value-Added Services Hotline: (888) 667-4135

If you have any other questions, please contact your North Risk Partners advisor. Don’t have an advisor? No problem. We’ll help you find one.

This regulatory update is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.