By Dave Osiecki, President of Scopelitis Transportation Consulting & ELD Consultant to PeopleNet
This post is the first in a two-part series on the upcoming April 1 deadline, which marks the beginning of a more stringent enforcement of the ELD mandate. For part 2, click here.
April 1 will bring the next phase of ELD implementation—more stringent enforcement of the mandate. But what does that mean for drivers using grandfathered Automatic On-board Recording Devices (AOBRDs)? Should your drivers expect anything different during roadside inspections? Ideally, the answer should be “no” since roadside inspectors should be very familiar with AOBRDs, and how they view and potentially obtain hours-of-service compliance data from an AOBRD. However, the Commercial Vehicle Safety Alliance’s (CVSA) recently revised its AOBRD Inspection Bulletin (in December 2017), and re-posted it on its website in January 2018. This revised Bulletin provides some brief, updated inspection guidance to inspectors.
Before covering a few details of this updated AOBRD Bulletin and the inspection-related questions it suggests, a preliminary note about enforcement preparedness. It’s likely that State enforcement officers will be well trained and, therefore, more comfortable with both the AOBRD grandfather provision and the ELD rules than they might have been in mid-December when the initial compliance date took effect. The Federal Motor Carrier Safety Administration (FMCSA) recently completed another round of AOBRD & ELD rule training for State officials. This training addressed some of the initial enforcement challenges that were identified in January 2018, shortly after the December 2017 compliance date took effect. So, your drivers can expect professional and well-trained roadside inspectors asking the right questions about both AOBRDs and ELDs. But what are those questions?
This is where CVSA’s AOBRD Inspection Bulletin helps. During an inspection, one of the first questions a driver should expect is whether the device being used is an ELD, or an AOBRD. Of course, the rules for these technologies are different, and a driver’s answer to that question will dictate the inspector’s follow-up questions and requests. On this note, it’s critical that drivers know which technology they are using (ELD or AOBRD), and be ready to communicate it with certainty.
If a driver communicates to an inspector that he or she is using a grandfathered AOBRD, the inspector is likely to ask some or all of the following questions (not necessarily in this order):
For the AOBRD portion of a roadside inspection to go smoothly, it’s important for a driver to know:
Inspections can be high-stress events for drivers, especially if they don’t experience them very often. Driver training, and preparation on what to expect, can lower the stress and facilitate the inspection for all involved. For more information, take a look at the CVSA’s AOBRD Inspection Bulletin.
Have questions about April 1 or anything else related to the ELD mandate? Visit PeopleNet’s ELD Resource Page to get your questions and answered and stay up-to-date on everything ELD.