Since the Electronic Logging Device (ELD) mandate passed last December, one of the most commonly asked questions we receive is: “When will PeopleNet appear on the Federal Motor Carrier Safety Association (FMCSA) Approved Supplier website for ELDs?”
As part of the final ruling, fleets subject to complying are required to use one of the devices listed on the FMCSA site by December 2017. If the fleet is using a 395.15-compliant Automatic Onboard Recording Device (AOBRD), they have until December 2019 before they need to comply with one of these registered devices.
This can be a confusing time for carriers looking to select a technology solution that will allow them to maintain compliance with the mandate. As they consider this important purchasing decision, it is crucial to understand a few things:
What does self-certification mean? The self-certification process, as defined by the FMCSA, means that device manufacturers are “responsible for registering their ELDs and certifying that they meet the technical specifications set forth in the ELD rule.”
This ruling essentially shifts the burden of certification to the marketplace, which trusts that device manufacturers are fully cognizant of all the technical specifications the mandate requires when certifying their equipment.
How are non-compliant devices discovered? Keeping the above point in mind, what if a fleet purchases a self-certified device that really isn’t fully compliant? Non-compliant devices will be identified through enforcement through roadside inspections or compliance reviews.
This means that a fleet could deploy non-compliant devices and will only find out via enforcement. If FMCSA finds that an ELD listed on its website does not comply, they may initiate removal of an ELD model from the list, or at least give the manufacturer time to correct the issue. While the carrier would not be held responsible, this discovery would be, at the very least, a frustrating experience to deal with.
Why isn’t PeopleNet currently certified? One of the primary reasons we aren’t yet self-certified is that the FMCSA has not yet released all of the technical requirements for devices.
ELDs must be able to transfer data electronically, with one option being a “telematics” method via Wireless web service and/or email. FMCSA has not yet made the Web Services URL available.
Upon receiving an electronic data file from Suppliers, FMCSA will process these data files using their own system to ensure Hours of Service (HOS) compliance. This system has been referred to as eRODs (Record of Duty Status). FMCSA has not yet granted access to eRODs and has not provided any target dates in which it will be accessible. PeopleNet will want to test eRODs to ensure that what our ELD states for Hours Available matches what the FMCSA’s eRODs system states.
We want to make sure that we have all of the necessary guidance from the FMCSA before offering a self-certified solution. Our first priority is to give our customers and their drivers the right technology to help improve safety and operations. We are working diligently to develop a device that will meet the mandate’s requirements and ensure compliance.
How do you make a smart purchasing decision? While devices are self-certified, the FMCSA site provides a great deal of product information on approved devices, including items like compliance test results and driver guides. This is aimed at helping carriers become more knowledgeable of their device options.
Like any big investment, doing your homework will help you make an informed purchase. Also, don’t be afraid to ask questions of potential suppliers to ensure you are selecting the right partner for ELD compliance.