Officials of the Federal Motor Carrier Safety Administration (FMCSA) met with truck drivers and representatives of the trucking industry last week to clear up confusion over the ELD mandate.
The meeting occurred during the yearly Mid-America Trucking Show (MATS) at the Kentucky Exposition Center in Louisville.
The FMCSA officials who attended the world’s largest annual heavy-duty trucking industry event were led by Joe DeLorenzo, director of the office of enforcement and compliance, who took the opportunity to address confusions over portions of the electronic logging device rule.
Here are some of the things that Joe DeLorenzo talked about and clarified for commercial drivers.
DeLorenzo said carriers should ensure that drivers know what device (ELD or AOBRD) has been installed in their vehicles and how to operate it.
Drivers should always have in their vehicle a data transfer sheet that shows how a driver can transfer data to enforcement officers.
In addition, drivers need to keep a user manual, blank Record of Duty Status forms, and other supporting documents in the vehicle. These must be presented when asked for by an enforcement officer.
As for the 150 air-mile exemption granted to ag haulers, DeLorenzo said once a driver goes beyond the 150 air-mile radius, “that’s when you have to use the ELD and your 11 hours start.”
In other words, miles up to 150 air-miles (or 172 actual miles) do not count against the driver’s hours-of-service.
DeLorenzo also reminded that the FMCSA is considering whether that 150 air-mile exemption should also be implemented in the back end — which means that a driver could take 150 air-miles before 11 hours and 150 air-miles after 11 hours and still be considered compliant.
Changes to the ag/livestock hours exception and personal conveyance guidance are expected to be finalized in the middle of June, according to Joe.
The last advice for ag haulers was to keep a copy of the waiver with them.
DeLorenzo also clarified that the ELD mandate does not apply to vehicles with pre-2000 engines. The exemption does not apply to the truck year. Instead, it applies to the engine year.
For instance, you may drive a 1995 truck model, but if it has a 2004 engine, you will have to install an ELD.
DeLorenzo said enforcement officers had been instructed to follow the model year on the engine’s tag. If a company undertaking a reman of a truck engine no longer considers the engine original and puts a new-model engine, then the engine goes by that new model year.
A MATS attendee asked DeLorenzo how enforcement officers determine the model year of an engine. The FMCSA official said: “When you do an engine swap, normal DOT regulations require you to keep paperwork at the fleet location. You shouldn’t have to keep paperwork in the truck. Officials have been trained to look for the model year on the engine, and if they can’t find it, they should take the word of the driver.”
DeLorenzo, however, pointed out that if a driver has the papers with him, it will simplify the inspection process.
Joe DeLorenzo also reminded drivers the protocol that they need to follow in the case of ELD malfunctions.
If an ELD breaks down, the driver needs to record his hours on paper logs. Also, the device has to be fixed within eight days, according to the mandate.
But Joe mentioned that if a carrier needs more time for fixing the ELD, the company can ask for an extension.
Full enforcement has begun. Do you have a compliant ELD solution?