ELD Enforcement—Will The States Be Ready?
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ELD Enforcement Blog Post

By Dave Osiecki, President of Scopelitis Transportation Consulting and ELD Consultant to PeopleNet

As the ELD compliance date nears, and a host of carriers finish their ELD implementation and training plans, many in the industry wonder how ready and prepared state enforcement officers will be to review ELD records at the roadside in order to enforce the mandate. Only time will tell, but the FMCSA-driven training and readiness plan for its own field staff, and for the state enforcement agencies, was recently laid out at the Commercial Vehicle Safety Alliance’s** annual conference in September.

FMCSA communicated that its ELD enforcement-related training, developed by its National Training Center, will be offered to state enforcement agencies, and its own federal audit staff, beginning in late October in two formats: (1) regional, on-site training seminars; and (2) live and recorded webinars.  FMCSA described the regional training seminars as a “train-the-trainer” approach, where both state and federal officials will be encouraged to attend, learn, and then take and use the material in their own states to train other front-line inspectors and auditors. The FMCSA-hosted regional training seminars will be held in the following locations, and state agencies and FMCSA auditors from the surrounding states, are being encouraged to attend:

  1. San Diego, CA
  2. Austin, TX
  3. Louis, MO
  4. Birmingham, AL
  5. Meridan, CT

Anticipating that some states, and even some FMCSA offices, may not be able to have staff attend in person, FMCSA also plans to conduct several live ELD enforcement training webinars in November and December (and perhaps even early in 2018). And, each of these webinars will be recorded for future playback as well.

FMCSA has communicated that the regional training sessions and live webinars will not be open to the industry. However, FMCSA is currently evaluating whether the recorded training webinars should be posted on the public portion of FMCSA’s ELD website. If FMCSA decides to publicly post them, these webinars will allow carrier representatives, and drivers, to listen to the training information after the fact. Given the importance of the ELD mandate, and the challenges it may bring to drivers and roadside enforcement officers alike, it’s a good idea for carrier safety and compliance staff, along with drivers, to make time to listen to one or more recorded webinars if they are posted. Stay tuned for more information on that decision.

Lastly, just prior to its conference in September, CVSA announced that the states will actively enforce the ELD rules beginning on December 18, 2017 while, at the same time, postponing use and application of the ELD portion of the out-of-service criteria against drivers until April 1, 2018.  To read CVSA’s announcement about this bifurcated enforcement approach, go to this link: http://cvsa.org/news-entry/2017-eld-implementation/

** CVSA is an organization that promotes uniformity of roadside inspections through training and enforcement-related guidance, it was clear that many State agencies.

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