The approaching ELD Mandate is being implemented in three phases — as you’re no doubt aware, Phase 2 takes effect in just over a week. If you’re not already familiar with this part of the Mandate, check out our blog post and FAQ to learn what it’s all about. If you're already prepared for December 18 you might or might not still be compliant in 2019.
Phase 3 of the ELD Mandate will take effect on December 16, 2019. When this final phase is implemented, AOBRDs no longer count as compliant devices. Every qualified vehicle will need to be using an FMCSA-registered, self-certified ELD by that date.
AOBRDs don’t record as much information as ELDs, and unlike ELDs, they aren’t required to record data automatically. ELDs have to be able to produce HOS reports in a graph for law enforcement whenever they are requested. The graph needs to show the driver’s changes of duty status and can be electronically displayed or printed out. They also need to be transmittable to the officer, though if it the transfer fails or can’t be completed, the display or print-out is acceptable.
Though ELDs are not the only option for compliance until 2019, it pays to make the switch before Phase 3 takes effect. A telematics solution like ES Track offers more than just compliance—it gives you the tools and data for easier mixed-fleet management.
If you’re using grandfathered-in AOBRDs for your fleet, be aware that you can no longer purchase new AOBRDs after December 18. However, if you replace a vehicle in your fleet, you can reuse its AOBRD in the new vehicle. If you’ve already started using an ELD, you might not know that the Mandate requires drivers to keep a few items in their vehicle:
• ELD user manual
• Description of the ELD’s data-transfer capabilities and instructions on how to transfer HOS records to a law enforcement officer
• Instructions for the driver about reporting ELD malfunctions and alternate recordkeeping procedure if the ELD isn’t working
• Blank driver RODS graph-grids sufficient for recording eight days’ worth of information
This isn’t the only documentation that will be needed, so be sure all qualified vehicles and drivers carry the appropriate supporting documents.
Recently, it was announced that drivers won’t be put out of operation for noncompliance until April 1, 2018—a grace period to further encourage ELD compliance. Drivers can still get citations, but they won’t count against the driver’s CSA score until the grace period ends. However, if you’re cited for still using outdated HOS recording methods, you won’t have the AOBRD option and will need to get an ELD. Don’t risk violations, fines or being put out of service—get compliant.
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