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FMCSA proposes electronic logging
device mandate: A look at what’s in it
Presented By
Justin Cunningham
Director of Safety
The Cline Wood Agency
E- Log Machines
E- Log Machines
Smart Phones can be used
E- Log Machines
Electronic Tablets can be used
FMCSA proposes electronic
logging device mandate:
 On March 12, 2014 The (FMCSA) Federal Motor
Carrier Safety Administration announced a
Supplemental Notice for Proposed Rulemaking to
mandate the use electronic logging devices.
 The American Trucking Associations welcomed the
proposal, while the Owner-Operator Independent
Drivers Association stated it will be closely studying the
proposed rule during the 60 Day comment period,
which started March 28, 2014.
FMCSA proposes electronic
logging device mandate:
 The electronic logging mandate’s or ELD Mandate’s
effective date and publication date in the Federal
Register were not announced. The FMCSA is targeting
for the rule to go into effect in late 2016. The proposal
states the mandate will go into effect two years after
the final rule is issued, which the FMCSA is projecting
to happen in the second half of 2014 (October or
November 2014).
 The rules estimates the annual cost of compliance will
be between $165 and $832 per truck.
FMCSA proposes electronic
logging device mandate:
 The rule consists of four parts:
(1) The requirement to use Electronic Logging
Device or ELD
(2) Protection against Driver Harassment
(3) Hardware specifications for the devices
(4) supporting documents drivers must continue
to carry after the ELD mandate.
Mandating logging devices
 The mandate will apply to all drivers who are currently
required to keep paper records of duty status. Drivers
who are required to keep records of duty status in eight
or more days out of every 30 days must use an ELD.
This is a change from the 2011 rule which outlined that
drivers who keep records of duty status two or more
days out of every seven use a logging device.
 Company’s who are using or have used what the
FMCSA calls “automatic onboard recording devices”
prior to the ELD mandate will have two additional years
(4 total) years to implement the ELD Machines.
Driver harassment
 Driver harassment in regards to the use of e-logs was the
key factor that caused a court to throw out the last ELD
mandate. The new ELD rule includes provisions to prevent
driver harassment involving the devices.
 According to the ELD rule, the FMCSA says its two “primary
focuses” 1)pressures on drivers to exceed hours of service
limits and 2) inappropriate communications that affect
drivers’ rest periods.”
 Proposed safeguards against harassment in the new ELD
rule include expanded drivers’ access to records, specific
wording about carriers harassing drivers, implementing a
complaint procedure, increasing penalties for those who do
harass drivers, “edit rights” for drivers, limitations on location
tracking, mute functionality for the devices and preserving
driver confidentiality in enforcement proceedings.
Hardware specs
 The new rule requires ELDs to be integrated with the truck’s
engine and to use GPS information.
 They also must be tamper-resistant. The devices will track
the truck’s movement but can allow for annotations by both
drivers and carriers “to explain or correct records.
 FMCSA is developing with states software to be able to
receive, analyze and display data from ELDs so that
roadside officers can use the information.
 The ELD rule also stipulates that the ELDs “present a graph
grid of a driver’s daily duty status changes either” on the
units themselves or in printouts.
 The ELD rule also stipulates the connectivity methods,
which include Bluetooth 2.1, email, and USB 2.0
Supporting documents
 Carriers and drivers will still be required to maintain
documentation that verifies drivers’ hours-of-service
records. “Supporting documents” can refer to either
paper or electronic documents.
 For every 24-hour period the driver is on duty, carriers
must maintain no more than 10 supporting documents
from either of these categories bills of lading,
itineraries, schedules or other documents that show trip
origin and destination, dispatch records, trip records or
similar documents, expense receipts, electronic mobile
communication records sent through fleet management
systems, or payroll records, settlement sheets or
similar documents that show what and how a driver is
being paid.
HOS Refresher
34 hour Restart & 30 minute Break
Refresher: 34 Hour Restart
The 34 Hour restart is “OPTIONAL” – If you can stay within your 60 or
70 hours you can use the “Recap” to get your days back.
34 Hour Re-Start:
 Limited to every 168 hours (7days)
 The time starts from the beginning of the previous 34 hour
restart period.
 MUST include two consecutive days from 1 am to 5 am.
34 hour Re-Start
 In this example, the driver reaches his/her maximum 60 hours (on-duty
and driving) in 7 days on Friday (1/7) and therefore can begin a new
34-hour restart starting on Saturday (1/8). This is because the 168-hour
period is counted from the beginning of the last prior restart, which was on
Saturday (1/1). The restart must include two periods between 1:00a.m.
and 5:00 a.m. as well.
Refresher: 30 Minute Break Rule
 Drivers must take a 30 minute Break after being on-duty not
driving or driving for 8 hours. You cannot go past the 8 hour mark
(adding lines 3 & 4 together)
 Companies that use the 100 Air-Mile Radius do not have to
document the Mandatory 30 minute break.
 This break can be taken either on the off-duty line or the sleeper
berth line on the log book. (lines 1 & 2)
 Written instructions are no longer required to be cared by the
 Only guidelines: The driver must be relieved of all duty and
responsibility of the vehicle and the load
30 minute Break
 In this example, beginning with the start of the driving window at 10:00
a.m., the driver was on duty for 1 hour, drove for 2 hours, was on duty for
3 hours, and then drove 2 more hours – totaling 8 hours (combined driving
and on-duty time). At 6:00 p.m. on Day 1, the driver takes the required
minimum 30-minute off-duty break, then goes back on duty for ½ hour,
and completes the 14-hour “driving window” at 12:00 Midnight
 In this example the driver could have also taken the 30 minute break on
line 2 – “The Sleeper Berth” Section.
Medical Certificate
CDL / Medical Merge
“Self Certification”
 By January 31, 2014 all drivers/companies should have
taken all their medical information into their local DMV
to have it added/(Merged) to their CDL.
 The FMCSA did extend the carrying of the medical card
for 1 year – BUT they did not extend the timeframe for
drivers to Merge their medical with their CDL.
 The only way to check to see if this has been done and
done correctly is run a new MVR on yourself/driver.
Medical Certification change
 Beginning May 21, 2014 all medical examiners will be required to
complete specific training to continue to conduct DOT Physicals on
 Please reference the Medical Registry website:
This website will help you locate a “Certified” medical examiner in your
area or closest to your area.
Website Front Page
Helpful Websites
 SAFER System
 PSP Program
 Data-Q