OTA Dispatch Issue 1, 2019

29 www.ortrucking.org Issue 1 | 2019 AOBRD Requirement ELD Requirement Key Consideration When Making the Transition UNIDENTIFIED DRIVING TRIPS Not required Must record unidentified driving trips when the vehicle is driven without a driver logged in Driver must be prompted to approve or reject unidentified driving trips at login Carrier is also responsible for assigning the unidentified driving trips or annotate why the time is unassigned Have you worked with your drivers to ensure that they are logging in and out correctly? Have you designated dedicated personnel to oversee unidentified driving trips as part of reviewing the driver’s logs? LOCATION RECORDS Required at each change of duty status Can be automatic or manually recorded Must automatically capture latitude/longitude coordinates with accuracy (two decimal places) unless driver operates under personal conveyance when the precision is reduced (one decimal place) The location must be retrieved at every change in duty status and during driving status, least once every 60 minutes (intermediate recording) The ELD must display the geo-location info indicating approximate distance and direction to the name of a nearby city, town, village of a state that has a population greater than 5,000 Are your drivers being forced to manually record location, much as they did with paper logs? For a driver, when using a compliant ELD, they can rest assured that the records are up to date and ensure that their privacy is safeguarded when using Personal Conveyance. MALFUNCTIONS AND DATA DIAGNOSTICS Not addressed ELD mandate specifically outlines the scenarios that must be monitored, detected and recorded The carrier is responsible for ensuring malfunctions are resolved within eight days of discovery Has the vendor provided an Information Sheet that outlines what the cause and resolution for each malfunction or data diagnostics are? What procedure do you have in place to fix, resolve or replace the malfunctioning device within 8 days? Does your vendor offer technical support specifically for malfunctions? CERTIFICATION AND REGISTRATION Self-certified by vendor Self-certified by vendor and registered on FMCSA’s registry Can you find the device name and model number on the FMCSA’s registry? Are you using the ELD software version? Have the ELD supplier gone a step further in certification and been verified by a trust-worthy unbiased third-party? following the deadline. It is crucial that you give your organization enough runway to do the necessary research on your options for ELD compliance and establish plans for making the transition. What should you think about when you’re planning for your fleet’s transition? There are fundamental differences between a legacy AOBRD and an ELD. Which means you’ll need to think beyond just a device upgrade. Your transition plan should include preparations for administrative changes, possibly deploying new devices (or altering existing hardware), and implementing operational procedures, including adjustments to your company’s policies or practices. We’ve outlined key factors that you may need to consider depending on the AOBRD hardware, system, provider and how you manage your operations. Planning for your transition to ELDs  If you haven’t yet, now is the time to decide on the transition path for your operations from AOBRD to ELD. It’s important to understand what you are using and what you need to watch out for, so no surprises or hidden risks surface after the December 2019 full-compliance date arrives. Otherwise, your operations can be left exposed to non-compliance.