One of the less publicized but highly critical aspects of the electronic logging device mandate involves a new platform that will transfer ELD data from roadside to a central federal system.
The electronic record of duty status data platform is supposed to be working by Dec. 18. If nothing changes at the highest levels of government relative to the mandate, on that date, inspectors from state Departments of Transportation and police departments will be required to begin enforcing the ELD mandate’s requirement for most drivers to use an ELD. They’re also supposed to interpret whether an ELD indicates a potential hours of service violation, which in many cases will not be as simple as it sounds.
One thing has been made clear, however, by the Federal Motor Carrier Safety Administration: Come Dec. 18, running without an ELD will be a violation if you’re not exempt. According to new out-of-service criteria in place from the Commercial Vehicle Safety Alliance, such a violation will net you eight hours out of service at roadside.
FMCSA spokesman Duane DeBruyne didn’t directly answer a question about whether he suspected most states would have their inspectors up to speed on access points to a planned central federal system for ELD data transfer and analysis, or even whether the technology to facilitate the system at the state level would be in place.
“FMCSA is planning to have data transfer capability ready by December of 2017. If data transfer is unavailable, the printout or display options [one of which is required of all ELDs] will be used to enforce hours of service.”
A variety of factors suggest those print/display backup methods will be important in most log checks.
At press time for the July issue of Overdrive, in which this story appears, the agency was expected to deliver elements of its planned data-transfer protocol to ELD vendors to test against in late June, which it did, among early steps toward rollout of the new eRODS program to states. With the electronic data transfer system, FMCSA in some ways is centralizing hours enforcement in a federal system for most methods of data transfer.
The agency has contracted a third party to develop software housed in the federal system to analyze logs sent from the field through its central system for possible violations. State inspectors theoretically then would investigate any flagged potential violations. Many states, however, currently aren’t anywhere near 100 percent sure what that piece will look like – or how exactly they would interact with it.
The ELD mandate specified two types of devices, each type required to support at least two data-transfer methods. For local-transfer devices, Bluetooth and USB 2.0 are the required methods. For telematics-type devices – most of the ELDs on the market today, with an internet connection – the ability to upload and email hours data is required.
FMCSA hoped states would support at least one method from each pair at the roadside, thus accommodating any device. As a backup, the rule likewise required every ELD to either include a printing capability or display current and previous-seven-days hours information with a graph grid analogous to today’s paper log books.
“We have not determined the primary data transfer method we will support,” says Fran Clader of the California Highway Patrol’s communications office. Like FMCSA, though, Clader remained confident that state roadside personnel would be ready by December.
Another 15 states either were unsure or, for different reasons, didn’t plan on supporting a local-transfer option.
While in Indiana, “each inspector has his/her own laptop computer and secure email account and can send and receive emails,” says State Police Maj. Jon Smithers, “we won’t use USB devices. Our state security rules prevent us from using USB devices that have been in contact with an outside device.”
Smithers didn’t totally rule out Bluetooth for a local-transfer option, but other states in similar situations relative to USB have done so. Michigan, for instance: “Currently, the State of Michigan IT policy prohibits the attachment of any unauthorized equipment to an IT resource,” says State Police Sgt. Joseph Austin.
Given all of these issues, three primary methods of transfer for the foreseeable future are likely to be most prominent in log checks.
Among the telematics options for transfer, states are most familiar with email output from current-generation automatic onboard recording devices, the current regulated type of e-log device. Legacy AOBRDs can be used by carriers that have installed them prior to the Dec. 18 ELD enforcement date for two years, until December 2019, when full ELD implementation is scheduled. Smartphone-based log book apps popular with owner-operators such as BigRoad and KeepTruckin, both currently also offered with engine connections to function as AOBRDs, make it relatively easy to output an email with the required hours compliance information to inspectors.
In the case of BigRoad, says Mike Davies, company product vice president, “We’re taking a belt-and-suspenders approach” given skepticism about the broad rollout of the data-transfer system FMCSA wants in place in the states by Dec. 18. “We’re not taking away any of the options” for displaying required hours information to an officer. Printing with a Bluetooth-connected peripheral printer, faxing and emailing will remain options as the program comes under the ELD specification.
Come Dec. 18, Davies says, “There will be states that will de facto fall back to how they inspect AOBRD systems today. We’ll be adding eRODS [capability] and keeping all the other pieces in there as backup.”
Vermont Capt. Kevin Andrews, noting his state was not “prepared to accept [logs] any other way” than email, suggested that eRODS likely wouldn’t be a total reality before the final Phase 3 of the ELD rule, which begins in December 2019. Until then, the following options are likely to play as large a role in roadside transfer as email.
The display required by the ELD rule specifies use of a graph grid similar to that in paper logs today, but that’s not all it requires. The illustration below shows other information likewise will be available through prints and displays for officers.
Among states responding to Overdrive queries, only Missouri reported total reticence to rely on the display for current and previous-seven-days log checks. This carries over from years prior when computer-assisted logs on drivers’ laptops and cellphones (not synced with the truck’s ECM) became de rigueur in trucking. The Show-Me State only wanted those drivers’ logs shown on a piece of paper, given liability issues, says Highway Patrol Lt. Kevin Kelley.
In the ELD era, checking a device’s display or a print, however, will play second fiddle there to USB, wireless web and email transfer, Kelley says. “As a last resort, we may look at the graph grid.”
Missouri, however, is the outlier. Outside of that state, as noted Maj. Todd Armstrong of the Illinois State Police, “Most roadside inspectors today already use this option [of reviewing the display] when looking at any form of electronic hours of service allowed in today’s regulations.” Some other states also noted varying degrees of likely significant reliance on display and/or print options at roadside, particularly if no obvious issues with hours regulations compliance are noted.
Maj. Jay Thompson of the Arkansas Highway Police expressed a measure of uncertainty as to the full extent of display reliance, but speculated “officers will review the actual grid on the device and only transmit a copy if and when violations are discovered.”
Similarly, Idaho representatives remain fairly unsure about just how everything will play out, but Capt. Tim Horn says that “the majority of the time [officers] will be reviewing the screen … of the device the driver is using.” Detailed email, fax or other transfers the officer can print likely will be requested “if the trooper sees a discrepancy that he needs to investigate.”
The market for purely local-transfer devices is small at this point, with Continental’s VDO RoadLog the most prominent among them. RoadLog is the only device with a built-in printer, though it also offers logs on its display. It comes with no follow-on costs after purchase but for the printer’s high-heat paper – $10 a roll, good for about two roadside inspections.
Many owner-operators are gravitating to the base RoadLog version given the lack of a cellular connection opened up within it. For those for whom both information security and personal privacy is a concern, choosing RoadLog also could satisfy worries about overreliance of handling an operator’s ELD, in many cases also a personal smartphone.
“It’s been an important thing for those owner-operators that want their privacy,” says Jeff Waterstreet, company sales manager.
Also given the questions around rollout of the data-transfer software, Waterstreet says, “We’ve taken the angle that troopers over the next few years are going to really love the built-in printer.” That point is underscored by the relatively small number of states planning to support local-transfer options.
The ability to print with other ELDs via peripheral devices may be useful for others. Any ELD that began its life as a computer-assisted log book should contain that ability. As BigRoad’s Davies says, though FMCSA has offered guidance on accepting digital signatures of daily logs via those log book programs, that same guidance still stresses that drivers need to be able to print today if using such a program.