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EOBR Defined
Success, Challenges and
Embracing the Change
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Session Learning Objectives
1. Understand FMCSA Rules and Update, Including Hours
of Service for Commercial Drivers
2. EOBR to ELD (Electronic Logging Device)
3. Understand the Benefits of Utilizing ELD’s and Practical
Application/Integration into your Organization.
4. Realize the Value Proposition of ELD’s
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Session Speakers
• Deborah Freund FMCSA
• Glenn Bramer Trimble
• Scott Vanselous TMW Systems
• Henry Prentice Noregon Systems
(Moderator)
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Session Guidelines
• One Hour Session
• Presentations
• Questions & Discussion
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Electronic Hours-of-Service Recording
Devices Rules: Past, Present, Future
Deborah M. Freund
Senior Transportation Specialist
Federal Motor Carrier Safety Administration
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• History of legislation on HOS recording
• History of ELD and related rulemaking
• Highlights of Supplemental Notice of Proposed
Rulemaking (SNPRM)
• Next Steps
Outline of Today’s Presentation
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• Truck and Bus Safety and Regulatory Reform Act (1988)
– Required Agency rules on electronic recorders ensure
that such devices not be used for driver harassment.
• HMTAA (1994)
– Required Agency HOS rules to specify “number, type, &
frequency” of supporting documents to be maintained.
• MAP-21 (2012)
– Required Secretary to adopt rules requiring CMVs
involved in interstate commerce and operated by drivers
required to keep RODS, be equipped with ELDs.
– Set deadline for prescribing regulations by Oct. 1, 2013.
Legislative Background
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1988: AOBRD final rule
2000-2003: HOS NPRM proposed HOS recorders
for long-haul/regional carriers; final rule did not
include this provision
2004-2010: EOBR 1 rulemaking
February 2011: EOBR 2 NPRM
August 2011: EOBR 1 Final Rule vacated
2011-2012: MCSAC activity; listening sessions
February 2014: ELD SNPRM
Rulemaking History
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April 5, 2010 Final Rule
• New performance-oriented standards for recorder technology.
• Mandatory use of recorders to remediate HOS non-compliance.
• Incentives promoting voluntary recorder use.
• Applicable to all motor carriers in interstate commerce
• Mandatory only for carriers subject to Remedial Directive on/after June 2012
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February 2011 NPRM
• Drivers currently using RODS:
– Must use HOS recording devices;
– Would not have to maintain and retain certain
categories of HOS Supporting Documents.
• All motor carriers (RODS users and timecard
users) must maintain HOS management system
• Lead time: 3 years after publication of final rule.
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Court Decision to Vacate
• Owner-Operator Independent Drivers
Association OOIDA filed suit in the Seventh
Circuit to invalidate 2010 final rule.
• In August 2011, the Court vacated the rule
based on FMCSA’s failure to address the
issue of driver harassment.
• For this reason, 2011 NPRM could no longer
rely on April 2010 technical specifications for
future ELD rulemaking.
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Overview of SNPRM
Four primary components:
(1) Prescribes minimum technical standards for ELDs;
(2) Requires drivers who need to keep RODS to use ELDs,
per MAP-21 direction;
(3) Establishes explicit requirements for HOS supporting
documents, specifying the “number, type & frequency” in
accordance with statute;
(4) Prohibits harassment of drivers and establishes a
complaint process for drivers, due process for carriers, and
civil penalties.
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Applicability
• MAP-21 (2012)
– Required Secretary to adopt rules requiring CMVs
involved in interstate commerce operated by drivers
required to keep RODS be equipped with ELDs.
• (Details to be added after SNPRM is published)
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Timeline
• SNPRM published February xx, 2014
• 60-day comment period
• Comment analysis
• Development of final rule
– FMCSA, USDOT, OMB reviews
• Publication of final rule
• Implementation activities
• Compliance date
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For more information …
Refer to Reg. ID No. 2126-AB20
FMCSA website: http://www.fmcsa.dot.gov
USDOT General Counsel – Significant
Rulemakings http://regs.dot.gov
Federal e-Rulemaking Portal:
http://www.regulations.gov
Federal Digital System:
http://www.gpo.gov/fdsys
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Electronic Logging Devices in Practice
Glenn Bramer
Marketing Director
Trimble Construction Logistics
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Electronic Logging Devices
No Final Ruling yet, so
EVERYTHING is subject
to change
What we do know:
1. ELD Requirements from MAP-21
2. Who it applies to
3. Similar requirements in the European Union
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ELD Requirements from MAP-21
Section 31137 (b)(1) – Electronic logging devices
(A)(i): to accurately record commercial driver
hours of service;
(A)(ii): to record the location of a commercial
motor vehicle;
(A)(iii): to be tamper resistant;
(A)(iv): to be synchronized to the operation
of the vehicle engine or be capable of
recognizing when the vehicle is being
operated;
(B): Allow law enforcement to access data
contained in the device during a
roadside inspection
• Needs to be able to manage current in-
force HOS rules
• GPS-enabled
• To ensure validity of collected data
• To automate collection of vehicle
operational data
• Data needs to be portable, and available
on-demand in the field
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ELD Requirements from MAP-21
Section 31137 (b)(2) – Performance and Design
Standards (A) Defining standardize user interface to aid vehicle
operator compliance and law enforcement review
(B) Establishing a secure process for standardized
(i) and unique operator identification;
(ii) data access;
(iii) data transfer for vehicle operators between
motor vehicles
(iv) data storage for a motor carrier
(v) data transfer and transportability for law
enforcement officials
(C) Establishing a standard security level for an electronic
logging device and related components to be tamper
resistant by using a methodology endorsed by a
nationally recognized standards organization
(D) Identifying each driver subject to the hours of service
and record of duty status requirements under part 395
of title 49, Code of Federal Regulations
• Everyone will be required to conform to minimum usage
interface requirements
• Portability of data will be universal for all certified
Electronic Data Loggers
• Electronic Data Loggers will have to be ‘Tamper
Resistant’, conforming to a national standard
• Each driver will have a universally unique identifier
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Similar solutions in EU
• In the European Union, digital tachographs became
mandatory as part of EU Regulation 1360/2002,
effective August 1, 2005
• Although similar in some respects to ELD, digital
tachograph requirements:
– Do not mandate recording location
– Do not have standardization regarding user interface
– Speed data is stored at 1-Hertz intervals, but not
stored on driver’s card
• Does require universally unique driver identification
in the form of a EU Driver’s License
• Requires motor carriers to report electronically both
vehicle usage hours and individual driver hours
• Requires data to be delivered to law enforcement
agencies by use of a special control card
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ELD Value Proposition
Scott Vanselous
Chief Marketing Officer
TMW Systems
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Obtaining Higher Value from ELD’s
• Integration with Maintenance Systems
– What is going on with the vehicle?
• Integration with Dispatch Systems
– Communications between Operations and
the Driver
• ELD’s – Electronic Logging Devices
– More features provide increased benefit
• Analytics
– Making sense of all the information
– take the right action at the right time
Incre
ased V
alu
e
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The Value of ELD’s as standalone
• Increased data accuracy
• More hours to drive
• No paperwork, 15 1 min increment
• Less time at DMV Checkpoint
Automatic Capture of
hours
• GPS Positional data
• Speeding, Idling, Braking
• Tire Pressure Monitoring Systems
• Fault codes
Driver and Vehicle Insight
• Pre/Post Inspection Compliance
• Conformance to Inspection ProcesseDVIR’s
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Integration with Dispatch Systems
• Planning to maximize hours remaining
• Increase driver satisfaction higher pay
• Increase asset utilization less idle time
Planning based on
available HOS
• Improve Driver behavior and performance
• Decrease out-of-route fleet tracking
• Early equipment diagnosticsIn-Route
• More accurate ETA’s
• Driver Confirmation Message
• Automatic alerts via Geodocding
Confirmation of Delivery
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Integration with Maintenance Systems
• Improved equipment performance
• Early detection of potential failures
• Automatically schedule work to be done
• Increase asset utilization less down time
Fault code analysis
and remedy
• Automatically schedule work to be done
• Increase compliance higher CSA score
eDVIR’s
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Analytics
• How did we perform to KPI’s
• What was planned versus what happened
• Factors involved (e.g. equipment failure, non compliance, …)
Operations Performance
• Identify best and worst performers
• Reduce speeding violations
• Productivity
Driver Behavior
• Predictive Maintenance reduce downtime
• Fuel Savings
• Fuel Tax
• Identify Cherries and Lemons in your fleet
Equipment Performance
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ELD Value - Summary
• More than just Hours of Service (HOS)
• Higher Features = Higher Value
• Integrated with Operational Systems = Higher
Value
• Analytics Provide tremendous insight to:
– Driver Performance
– Equipment Utilization and Performance
– Compliance
– Safety
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Questions / Discussion
• Deborah Freund – FMCSA
• Glenn Bramer – Trimble
• Scott Vanselous – TMW Systems
• Henry Prentice – Noregon Systems