FMCSA's Last Compliance Deadline

2019 marked the final of the FMCSA mandate deadlines. On December 16, 2019, any carriers and drivers previously grandfathered in had to switch any AOBRD-type devices to certified electronic logging devices (ELDs) according to 49 CFR § 395.15 of the FMCSA’s transportation regulations, with the risk of non-compliance being a fine and/or being put out of service.

What is an AOBRD?

You might ask, what does AOBRD stand for (and what are they used for)? The acronym stands for Automatic On-Board Recording Device. AOBRDs are electronic devices that were used to track Hours of Service prior to newer (and more advanced) ELDs, and, due to a number of factors, a not insignificant amount of companies companies might have even utilized a mix of ELD vs AOBRD usage within their fleets.

Features of an ELD:
  • Records driving time automatically
  • Provides accurate recording of driver’s HOS
  • Meets technical specifications of ELD rule
  • Integral synchronization with engine of the commercial motor vehicle (CMV)
Cab-Mate Connect

What is an ELD?

ELD stands for “Electronic Logging Device”. Simply put, ELDs are used to replace paper HOS logs by connecting to a vehicle’s engine to monitor its movement, distance, and time of operation.

So, What's the Difference?

Though similar, the main difference that sets ELDs apart from AOBRD providers is that AOBRDs cannot support the electronic data transfer methods outlined in the ELD rule. However, there are still a number of other features that are different, as per the FMCSA’s mandate:

Integral Synchronization Integral synchronization required, but not defined in regulations. Integral synchronization with CMV engine electronic control module (ECM) to automatically capture data including power status, vehicle motion status, miles driven, and engine hours.
Recording Location Information of Commercial Motor Vehicle (CMV) Required for each change of duty status (manual or automated). Requires automated entry at each change of duty status, at 60-min intervals while in motion, at engine-on and engine-off, and at the start and end of personal use and yard moves.
Graph Grid Display Not required – “time and sequence of duty status changes.” “An ELD must be able to present a graph grid of driver’s daily duty status changes either on a display or printout.”
Hours of Service (HOS) Driver Advisory Messages  N/A HOS limits notification is not required. “Unassigned driving time/miles” warning must be provided upon login.
Device “Default” Duty Status N/A On-duty not driving status, when CMV has not been in-motion for 5 consecutive minutes and driver has not responded to an ELD prompt within 1-min. (No other non-driver-initiated status change is allowed.)
Clock Time Drift N/A ELD time must be synchronized to Universal Coordinated Time (UTC); absolute deviation must not exceed 10-min at any time.
Communications Methods Integral synchronization required, but not defined in regulations. Integral synchronization with the CMV engine electronic control module (ECM) to automatically capture power status, vehicle motion status, miles driven, engine hours. (Exempt: CMVs older than model year 2000.)
Resistance to Tampering Required for each change of duty status (manual or automated). Requires automated entry at each change of duty status, at 60-minute intervals while CMV is in motion, at engine-on and engine-off instances, and at beginning and end of personal use and yard moves.

ELD Required Documentation

The FMCSA also has an ELD-specific requirement that drivers carry a number of records, manuals, and other documents for inspections. Below is a list straight-from the FMCSA themselves.

A driver using an ELD must have an ELD information packet onboard the commercial motor vehicle (CMV) containing the following items:

  • ELD Operations Manual
  • Instruction sheet with step-by-step instructions, describing data transfer mechanisms and how to transfer HOS records to a safety official.
  • Instruction sheet for the driver describing ELD malfunction reporting requirements and recordkeeping procedures during the ELD malfunctions.
  • Supply of blank driver’s records of duty status (RODS) graph-grides sufficient to record the driver’s duty status and other related information for a minimum of 8 days.

Exceptions and Exemptions

ELD Mandate’s Expired Grandfathered AOBRD Exception

Prior to the final mandate deadline in 2019, the FMCSA’s policy had included an exception allowing those with AOBRDs an extended transition period. Typically, exceptions and exemptions were based on the age of the vehicle or on specific industries’ needs. Other, previous exemptions included performing drive-away-tow-away operations (depending on commodities transported) and drivers that aren’t required to keep RODS more than 8 days within any 30-day period.

Industry-Specific Exceptions

Ongoing ELD exemptions primarily affect those that aren’t required to keep records of duty status anyway, like short-haul- or timecard-exempt drivers. Other ongoing exemptions include industry-specific situations like those within the agricultural or oil-and-gas industries.

An expanded list of exceptions can be found here.

More Exemptions Include:

  • Emergency/Adverse Driving Conditions
  • Driver-Salesperson
  • Oilfield Operations
  • 100 Air-Mile Radius Driver
  • Retail Store Deliveries
  • Travel Time
  • Agricultural Operations
  • Ground Water-Well Drilling Operations
  • Construction Materials and Equipment
  • Utility Service Vehicles
Future Changes to ELD Exceptions and Exemptions

An important note is that the FMCSA is continuing to sculpt these regulations. As companies and drivers communicate challenges they experience, and as enforcement is practiced, certain rules may be added, edited, or removed. As of 2020, some proposed changes (not-yet-approved), may include adverse driving conditions, as well as short-haul, sleeper berth, and brake-related exceptions.

The Pedigree Technologies team keeps close tabs on all new rulings and, when necessary, we jump into action to update our OneView solutions to keep our customers compliant.

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