ELD Compliance Timeline

The following is a brief background and timeline leading up to the ELD Mandate.

The ELD Mandate requires commercial motor vehicle operators to use electronic logging devices (ELDs) to record a driver’s driving time and hours-of-service (HOS) records. An ELD monitors a truck’s engine and shows a variety of variables: if the engine is running, how long the engine has been running, if the truck is moving, how many miles were driven, etc. Previously, drivers could use paper logbooks or other recording devices to track their hours, but when the mandate goes into effect, carriers will only be allowed to use compliant ELDs. The new ELD’s were designed in an effort to streamline and modernize the HOS and/or paper logbooks currently in use as the standard method of bookkeeping for commercial truck drivers. The new ELD’s will help drivers log their driving hours for both their employer and DOT inspectors and are supposed to reduce accidents related to driver fatigue.

The FMCSA’s (Federal Motor Carrier Safety Administration) final ELD Mandate deadline is on December 16, 2019. However, there other dates and deadlines to keep in mind, leading up to 2019. But before jumping into the future, it is usually important to take a look into the past. As such, we thought it would be helpful to be familiar with the ELD timeline, from its origins to the final mandate deadline.

The Origin of ELDs

Drivers of commercial motor vehicles first started to use electronic devices to record HOS (Hours of Service) in the mid-1980s. Early users tended to be private motor carriers and the first systems they operated were a “batch processing system”- all information is collected and held until being processed together as a batch, at the end of a specified cycle. Not surprisingly, there was no real-time mobile communication of the data. Some of these outdated systems are still in service and used as a primary process today.

The First Attempts of Mandating

In 1988, regulations defined Automatic OnBoard Recording Devices (AOBRDs) and set standards for their use.

The first mention of a federal mandate on electronic logging devices (ELD’s) dates back to the early 1990s, with initial suggestions being incentive based.

In 2000, the FMCSA tried to reform HOS regulations and include the use of electronic devices, but the reform was blocked by a court order in 2004.

Finally, in April, 2010, CFR 395.16 was announced in the Federal Register. On April 5, 2010, the FMCSA published a final rule, “Electronic OnBoard Recorders for Hours-of-Service Compliance,” requiring motor carriers with significant HOS violations to install EOBRs in their trucks.This rule/regulation drew the distinction between old devices (Automatic OnBoard Recording Device or AOBRDs) and newer technology (Electronic Onboard Recording Devices or EOBRs). However, this never became law as it was shut down by the US Court of Appeals.

On June 3, 2010, OOIDA filed a lawsuit with U.S. Court of Appeals for the Seventh Circuit challenging the final rule.

The FMCSA’s final rule took effect on June 4, 2010.

Because the FMCSA couldn’t address the driver harassment issues in the rule, the Court cancelled the final rule on May 14, 2012.

Two years later, on March 12, 2014, the US Congress passed a transportation reauthorization bill called MAP-21 (“moving ahead for progress in the 21st Century”) which included a provision that mandated ELD’s. This required the FMCSA to write a rule mandating electronic logging devices – which is when the term ELD was born. It replaces the older terms – AOBRDs and EOBRs – with the aim of avoiding confusion and replacing it with the correct terminology.

The Final Mandate published

After public comment periods and approval from the White House Office of Management and Budget (OMB), the final version of the mandate was released on December 10, 2015. As a result, the FMCSA published its ELD Final Rule: the ELD Mandate. The mandate outlined the timeline for compliance, with a final deadline on December 16, 2019. It also specified the required information vendors must gather from any vehicle manufactured in or later than the year 2000 and includes anti-harassment measures for current ELD users.

The Future of ELD’s

In an effort to make compliance a streamlined process, the FMCSA has set a number of deadlines that for-hire and private motor carriers must meet. AOBRDs are still allowed in the first phase, but all new devices installed by fleet managers and owners must comply with current ELD mandate standards. This phase ends on December 18, 2017. After that, all AOBRDs must be replaced with certified ELDs. However, if you install an AOBRD prior to December 18, 2017, you have an additional 2 years to update your equipment to compliant ELD’s by December 18, 2019.
The ELD Rule applies to most motor carriers and drivers who are currently required to maintain records of duty status (RODS).

Learn more and see exemptions at:
https://www.fmcsa.dot.gov/hours-service/elds/drivers-and-carriers

Get more details on ELD Rule Implementation at:
https://www.fmcsa.dot.gov/hours-service/elds/implementation-timeline
There is additional information in the ELD FAQs:
https://www.fmcsa.dot.gov/hours-service/elds/faqs

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