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ELDs, HOS, RODS, FMCSRs and FAQs

On Behalf of | Mar 6, 2018 | Firm News

Oh Vanna, I’d like to buy a letter…In the abbreviated, truncated world we live, we no longer speak in complete sentences, but rather in “text-ese”, everything has an acronym or abbreviation…including you-“U”, and me-“RTC.”

In our last blog, Mike provided strategies to prepare for the catastrophic accident, along with 8 things to gather immediately. First on that list is the driver’s log, which brings us to ELDs, HOS, RODS, FMCSRs, and FAQs.

All drivers of commercial motor vehicles for regulated motor carriers that are subject to the Federal Motor Carrier Safety Regulations (FMCSRs) and its Hours of Service (HOS) regulations are required to maintain driver daily logs or Records of Duty Status (RODS), unless they meet very narrow exceptions. As of December 18, 2017, drivers required to maintain RODS must do so utilizing Electronic Logging Devices (ELDs).

The only exceptions are drivers who operate (1) under the short-haul exception, (2) who are only required to maintain RODS for 8 days or less out of every 30-day period, (3) who conduct drive-away, tow-away operations, and (4) who operate vehicles manufactured before 2000. Vehicles equipped with an AOBRD, or Automatic On-Board Recording Device (precursor to the ELD) that was installed prior to December 18, 2017, are grandfathered in and will be in compliance until December 16, 2019-at which time the vehicle must be converted to an ELD.

An ELD is a device that connects to the vehicle’s engine computers and automatically records a driver’s driving time. The ELD monitors the vehicle’s engine to capture data on when the vehicle is running, whether it is moving, miles driven, and duration of the engine operation. It provides a visual display for the driver to monitor their current status and provides the ability to print out hour logs when required by DOT inspectors.

ELD prices start at about $150.00, depending on the manufacturer and options. Some ELDs can be linked to the driver’s smartphone or tablet. It is important to note that the motor carrier is responsible for checking and monitoring the USDOT’s list of registered ELDs to ensure that the devices they are using are (1) compliant with DOT regulations when installed and (2) their devices have not been removed from the list.

Drivers must also know how to use the ELD and are required to have the following at all times: (1) an ELD User Manual, (2) Instruction Sheet for transferring their HOS data to a safety official, (3) Instruction Sheet of Procedures in the event of an ELD malfunction, and (4) at least 8 days of blank paper logs for RODS in the event of a malfunction. Failure to have these required documents physically in the vehicle will subject the driver and carrier to a DOT citation.

Vehicles found without an ELD after December 18, 2017, will be issued a citation, but will not be placed Out of Service (OOS) until April 1, 2018. After April 1, 2018, failure to have the required ELD will result in an OOS violation that will place the truck and driver out of service. In addition to the cost of compliance and the citation fine, the driver and carrier would also incur potential downtime losses as well as be assessed points against their CSA (or Compliance, Safety, Accountability) scores.

ELDs are here to stay. Hopefully this answers your FAQs about ELDs and RODS and will keep you OOHW1 with the DOT!


1. OUT OF HOT WATER

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