ELD Compliance – After the Deadline
Well, it’s almost here. In a week, on December 18, 2017, we’ll reach the first deadline for the ELD Mandate and the start of complete electronic recording for all fleets throughout the U.S. As we approach this second phase, the Phased-In Compliance Phase, self-certified and FMCSA-registered ELDs or automatic onboard recording device (AOBRD) systems are required for your fleet vehicles. There are a few exceptions to this deadline, but most fleets are required to comply. As this deadline, discussed for so long, now takes effect, here’s what you should know about ELD compliance after the deadline.
1. Am I exempt?
Even if you believe your fleet is exempt, take another look at the FMCSA exemptions. Most drivers who have to keep records of duty status (RODS) are required to log their hours through an ELD or an AOBRD installed before today, so avoid fines and citations by confirming your exemption.
2. Are my ELDs registered with the FMCSA?
To comply, the specific model of your electronic recording devices must be registered by your vendor with the FMCSA. You can easily check for registration through the FMCSA’s list of registered devices.
3. Do my ELDs meet specifications?
Just installing your ELDs isn’t enough, your drivers actually have to use them for specific purposes. Make sure your devices meet specification requirements, by checking this function list.
4. Are my drivers logging hours through my ELDs or manually?
The purpose of the ELD Mandate is to eliminate paper logging and introduce wide-spread electronic logging. Moving forward, your drivers should be signing in and out to log their Hours of Service through your devices. As we move into this ELD-exclusive stage, train your employees to rely on your devices and avoid non-compliant recording.
5. Are my drivers complying with supporting document requirements?
According to the ELD Mandate, “Motor carriers must retain up to eight supporting documents for every 24-hour period that a driver is on duty” and drivers must submit these documents to their motor carrier within 13 days of receiving them. These documents can include:
- Bills of lading, itineraries, schedules, or equivalent documents that show the starting and ending location for each trip
- Dispatch records, trip records, or equivalent documents
- Expense receipts related to “on-duty/not driving” periods (meals, lodging, fuel, etc.)
- Fleet management system communication records
- Payroll records, settlement sheets, or equivalent documents showing payment to a driver
- Toll receipts, which do not count toward the eight-document cap
The long, two-year period between announcing and implementing the ELD Mandate means that leniency is unlikely. As the second phase begins, do your best to remain compliant with FMCSA requirements and avoid any issues or consequences.