Complying With the ELD Mandate: What’s Next?
With the December deadline now past for the Federal Motor Carrier Safety Administration’s Electronic Logging Devices (ELD) mandate and the “soft” enforcement period having elapsed on April 1, it is all the more pressing that companies that needed to comply with the ELD mandate are up and running with their devices.
Now comes the fun part. Admittedly, the words “compliance” and “fun” are not often used together in the same sentence. But if you think about the intent of the rule—streamlining and modernizing a cumbersome paper process—you can start to see the silver lining hidden in this regulation, said Rick Walters, Sr., general manager of Lytx C
“For some companies, the ELD mandate is their first foray into digital data,” said Walters, whose department processes 8.5 million electronic and paper logs a month. “That can be an opportunity for them to really dive into the data and find ways to drive additional business efficiencies.”
These four tips are designed to take you from basic CSA compliance to full ELD mastery, helping you gain all the operational improvements that going digital can provide.
1. Create a Unified ELD Tracking Dashboard to Tame the Data Onslaught
Many companies in recent weeks are finding out ELD systems don’t come trouble-free right out of the gate. “As they start working with their ELD systems, they’re finding out where the kinks are,” said Gary L. Johnson, Lytx director of risk and compliance management. “That’s because no two fleets are exactly the same. So they’re having to constantly adjust these systems.”
Fleets that have a mix of technology systems in their cabs are having an especially difficult time. “Let’s say I have two ELD systems, one in my original fleet and another installed on another set of vehicles from a company I acquired,” Walters explained. “I have a driver who alternates between both sets of vehicles on any given week. To get visibility into a driver’s total hours of service, I would need to log into two different systems. If I have 10 drivers, it might be manageable. But if I have 100 or more drivers, it becomes a big deal.”
Another issue is the avalanche of email or text alerts of real-time violations jamming supervisors’ inboxes. “It can be overwhelming to put your arms around your true compliance level, risk and trends because you’re constantly putting out fires and not actually looking at the trends,” Walters said. In addition, safety managers are now required to assign unassigned drive time and work with drivers to fix previous days’ electronic log data.
The solution? Find a way to gather the disparate streams of data to give you a unified view, Walters advised.
“You need something that can ingest all that data, aggregate them into a single dashboard, and present you with the relevant data pulled together with driver ranking, location ranking, and trend analysis,” he said. “And, just as importantly, it needs to present the data to you in a way that is actionable. Look for a data aggregation solution that doesn’t just pepper you with alerts, but organizes the information into categories that help you do your work faster, whether that’s zeroing in on hours-of-service violations or quickly telling you where your CSA violations are happening most often.”
2. Keep an Out: Maintain a Way to Handle Paper Backups
This may sound silly or redundant, especially since the intent of the mandate is to reduce paper. But for better or worse, paper logs will continue to play a role in the ELD world. “There will be times when the ELD system goes down and the driver needs to rely on paper logs during that downtime,” Johnson said.
Jason Gaul, a Lytx senior client account manager who has helped transportation companies navigate hours of service issues for more than 14 years, pointed to several other examples of when paper logs might come into play. Companies that need to rent vehicles, either to handle seasonal peaks or as temporary replacement vehicles, for example, would need an alternative way to track driver hours on those vehicles. Also, some supporting documents, such as receipts, may only be available in paper form.
“Even though the ELD mandate is designed to transition the industry into digital records, the reality is that every carrier still needs to process paper at some level,” Walters said.
Take, for example, the Short Haul exemption rule, which exempts drivers from the mandate if the driver doesn’t work more than 12 hours, stays within a 100 air mile radius, and returns back to work reporting location.
“If you have drivers who occasionally need to exceed the 100-mile radius, you can keep tabs on them with a driver auditing system that can flag you when someone is getting close to the limit,” Gaul said. “That way, you can dispatch them on routes that don’t exceed the limit for that day.”
3. Be Prepared for DoT Audits and Accuracy
One of the biggest sources of paper is backup documentation, which is especially important in the event of an audit. That means you need a way to organize those documents, either in physical or digital format, so they can be produced during an audit.
“Supporting documents become far more important in a world where we have ELD requirements,” Walters said. “It really puts teeth behind hours of service rules.” That’s because electronic logs are easier and faster for inspectors or regulators to audit than paper logs, so any inconsistencies will be easier to spot.
For example, drivers who report a 30-minute break at exactly the same time they are shown to be refueling might be “double-dipping,” Walters said. That’s because drivers aren’t supposed to be performing work-related tasks, including refueling, on their breaks. Electronic logs will more readily expose those instances.
“Unfortunately, there’s a tendency for some managers to think that having an electronic logging system installed means it will automatically take care of their compliance requirements and audits will be a completely hands-off process,” Walters cautioned. “While they do help audits go more efficiently, ELDs don’t offer the ability to match supporting documents. In fact, electronic logs can make it easier for an auditor to identify discrepancies, making the need for supporting documents during audits more vital.”
Although that may sound like bad news, you can actually turn this to your advantage. And that leads us to the topic of our next tip.
4. Use Electronic Log Data to Get Ahead of Issues
Data from electronic logs can help uncover issues once hidden in piles of paper logs. For example, the visibility afforded by data gives you an opportunity to head off CSA score violations before they happen, Walters said.
It can also set you on a path to finding new ways to improve your operations, Johnson said.
“The key is to keep your assets moving,” Johnson said. “ELDs will surface and capture those delaying events more quickly so you can identify patterns and manage around them. You then can take proactive measures to combat costly operational interruptions.”
Another example is speeding violations, which hurt your CSA scores.
“With a digital dashboard, such as one provided by Lytx, you can aggregate your data by vehicle and driver, combine data from your ELD, and identify patterns that help you single out the source of your speeding,” Johnson said.
“Is it a particular driver who needs to be coached?” he continued. “Does speeding tend to happen toward the end of the day as drivers rush to fulfill their deliveries? Does it happen only on certain routes? When you identify patterns, you can start to make adjustments. You can use your ELD systems to help you be proactive rather than just watch those violations add up.”
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