E-log proposed mandate comment period nearing end

| June 24, 2014

Follow this link to submit a comment with one click. 

Following the Federal Motor Carrier Safety Administration’s extension of the public comment period on its proposed electronic logging device (ELD) mandate, comments close finally on June 26. To submit a comment, use Docket Number FMCSA-2010-0167 at regulations.gov or by email at oira_submissions@omb.eop.gov, using the subject line Attention: Desk Officer for FMCSA, DOT. See below for fax and postal mail options. 

With the deadline two days away, the CCJ Symposium was well under way in La Jolla, Calif. A session devoted to issues surrounding the ELD mandate saw fleet reps from Con-way, Swift and John Christner Trucking speak of their respective fleets’ e-log implementations and associated challenges. Overdrive Equipment Editor Jack Roberts covered the panel, in which all speakers emphasized difficulties in implementation and generally positive experiences following.

While owner-operators wouldn’t experience the same length of time for implementation as such large fleets, small fleets have reported a similar dynamic, with some difficulty settling on a system on the market currently that fit their company’s needs well.

In Overdrive‘s 2014 ELD Survey, conducted this Spring, among owner-operators and small fleets who noted an intent to comply with the mandate, should it become final, familiarity with the current device market was low, as the following chart indicates. 

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Furthermore, only 12 percent of readers indicated they were using e-logs for hours of service compliance today — implementation for non-ELD-equipped trucks, should the mandate become final, will be no small matter. 

Among recent commenters, reader Geoff Chausse was among those already running under ELDs (for two years now, he said), and he summed up advantages and disadvantages in commentary under the story at this link.

Among the advantages: “I no longer can be tempted to run two days straight. I don’t have to draw lines, figure recaps or figure out where I am.”

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The disadvantages Chausse named, however, were numerous and, considered on the whole, may represent a safety negative for trucking nationwide, particularly given time pressures of the 14-hour clock in the hours of service rules, he wrote. “I have no choice but to drive in traffic, adverse weather conditions and/or fatigued because I can’t take a nap or avoid adverse conditions because it is tick, tick, ticking away.”

ELDs also have exacerbated already extant parking shortages, he added. “We all pretty much pick up at the same times, therefore we all run out of hours at about the same times. Slow loading or unloading times affect my overall productivity and paycheck more so then they did before.”

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In short, Chausse concluded, “they are expensive and restrictive, and should be left as a choice.”

Those who haven’t commented on the proposed rule as yet can use the links above for online submission. Comments can also be faxed to 202-395-6566, or mailed to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street NW., Washington, DC 20503, ATTN: Desk Officer, FMCSA, DOT. 

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