Recently the Federal Motor Carrier Safety Administration (FMCSA) released a list of frequently encountered issues that have been reported by motor carriers and drivers. These concerns have been found to be related to devices not being set up properly. Any of these issues could result in a device being investigated and possibly removed from the list of registered devices.
In a nutshell, the Electronic Logging Device (ELD) rules require commercial truck drivers to keep hours-of-service (HOS) and records-of-duty status (RODS) reports using an electronic device or an on-board recording device. The ELD mandate also lays out certification and registration as well as performance standards for the use of ELDs. It is illegal for carriers to harass drivers based on ELD data and gives drivers recourse if they believe they have been harassed.
Here are some of the most frequently reported ELD issues.
- Erroneous Fields
The ELD rule specifies that drivers submit an output file. The acceptable ranges for these field values are also specified. When there are missing fields, or the fields contain invalid values, safety officials will not accept the file. The types of issues that are commonly seen include:
- Incorrect field size (i.e. Shipping Document Number, Trailer Number or CMV VIN)
- Invalid field ranges (Elapsed Engine Hours, Accumulated Vehicle Miles)
- Missing fields that are required (Event Sequence ID Number, CMV Order Number, Last Name, Carrier Name)
- Incorrect file and line data check values
- Invalid characters
- Invalid dates, times or numbers
The above inputs are data-checked by the FMCSA File Validator system.
- Invalid Delimiters
The ELD rule requires that the formatting of the output file must include comma separators and lines must be separated with carriage returns (<CR>). If your ELD output file has a value that includes a comma or <CR> code in it, the rule requires that these be replaced with a semi-colon.
The ELD rule requires that the ELD be able to transfer output files using both a web service and FMCSA email address. These transfer methods must be pre-configured into the device based on ELD rule 220.127.116.11, 18.104.22.168(b)(1), and 22.214.171.124(c).
An ELD should never send an email or output file directly to a safety official, and a driver or motor carrier should never have to request the email address or end points from the FMCSA or a safety official.
- Event Times
The ELD output file must have time reports listed in the time zone in effect in the driver’s home terminal. While date and time are recorded in UTC, if times are reported in UTC in the output file, it will result in the incorrect time being viewed by the safety official. This can be tested by viewing the safety official view of your ELD output files that have been successfully run through the File Validator. Or, you can test files that have been successfully submitted to the web services test environment. This ELD rule can be viewed at 7.8 and 7.40.
- 30 or More Days of RODS
The ELD rule specifies that ELDs be able to send a report for the current 24 hour period as well as the previous consecutive 7 days for review during a roadside inspection. An ELD must also produce records for a subset of its drivers, vehicles and the 6 month record retention period, as specified by the safety official, including 30 days’ worth of RODS. For more information, see ELD Rule 4.9.2(b).
- Incomplete Set of the Data Transfer Option
Any system that motor carriers decide to use that offers support must provide support for data transfer through either telemetrics (web services and email) or local transfer (USB and Bluetooth) options. Local transfer must include both USB and Bluetooth. For more information, see ELD Rule 4.9.2.
While changing from a paper logging system to an electronic logging device has been frustrating for carriers and drivers alike, ensuring that your device is properly configured from the get-go will eliminate at least some of the initial headaches that have been reported.
Cline Wood offers specialized insurance expertise. We are able to help drivers and fleets identify areas of risk as well as implement solutions to mitigate risks specific to the transportation industry. For more information, contact us today.
This document is not intended to be taken as advice regarding any individual situation and should not be relied upon as such. Marsh & McLennan Agency LLC shall have no obligation to update this publication and shall have no liability to you or any other party arising out of this publication or any matter contained herein. Any statements concerning actuarial, tax, accounting or legal matters are based solely on our experience as consultants and are not to be relied upon as actuarial, accounting, tax or legal advice, for which you should consult your own professional advisors. Any modeling analytics or projections are subject to inherent uncertainty and the analysis could be materially affective if any underlying assumptions, conditions, information or factors are inaccurate or incomplete or should change.eld problems, electronic logging devices, trucking regulatory compliance, trucking technology