IN PRINT -- ELDs Part 2: The Learning Curve
When I replaced my typewriter with a laptop some years ago, everyone told me it would be an easy transition. It’s the same thing, they told me. The keyboard, at least, was more or less the same. I soon discovered I’d have a few other things to deal with, like software and operating systems and crashes and batteries and floppy disks and updates and the dreaded Blue Screen of Death – moments before a deadline.
The move to electronic logs from paper won’t be any different. The rules that govern fleet operations won’t change, so that part will be business as usual. But much will need to change when migrating to Electronic Logging Devices (ELDs).
“There is a lot of noise out there about everyone’s features and functionality,” says Tom Reader, director of marketing for ELDs at JJ Keller and Associates. We have been doing a ton of education and a lot of it is around change management for small to mid-size fleets that need to get an understanding of what the impact of ELDs is going to be.”
While fleets should invest some energy in ensuring they have compliant devices well in advance of the December 2017 deadline, Reader says they also need to focus on how the rule will affect day-to-day fleet operations and who needs to know what before putting the ELD into play.
“There are a lot of assumptions that they plug this in and they’re off and running,” he says. “But from a fleet standpoint, it might mean changes to how you route drivers, to how you dispatch them, where they go and when. From a driver standpoint, they used to write this stuff on paper and now they need to learn some technology if they’re not used to that. Even though many systems are designed for a simple installation we still have drivers who don’t use cell phones.”
Drivers will be relieved of the chore of filling out a daily log sheet, but they will have to remember a few things about ELDs that are significantly different. For example, as soon as the key is turned, the driver, or someone, is logged on duty. The daily start-up ritual may have to change. No longer will drivers be starting up the truck and then wandering around collecting paperwork and shooting the breeze with the folks in the shop – or even moving the truck into the shop for repair.
“Ignition on/off events [will be] tracked now by the ELD, so any movement will now have to be tracked as an unassigned driving event, as a yard more or be picked up by the driver,” says Elise Chianelli, director of product management at PeopleNet Canada.
It not just the drivers who will have to be aware of the time spent around the truck with the key on. Shop personnel can move trucks around, too, as long as they log in as an unassigned driver. If they do not, that time and the movement will be assigned to the driver. While that can be edited later, the movement will show on the record enforcement officers see at roadside.
“There are certain repairs that need a five-mile road test to make sure everything is okay. Those movements should be unassigned vehicle moves,” notes Tom Cuthbertson, vice president of regulatory compliance with Omnitracs and chairman of the Technology and Maintenance Council’s (TMC) ELD Task Force. “Your driver logs out then somebody moves the truck and your driver logs in once again and it notes it as an unassigned vehicle move.”
The driver assigned to that truck would have to make a note on the device that says “in the shop for repairs”, “road test”, or something like that, but the mechanic who drove the truck does not have to be in a fleet’s system – just logged in as an unassigned driver.
“That’s why you have the reconciliation part,” Cuthbertson says. “The driver puts a notation on the log and all’s well. It’s easy for me to say this now, but fleets will need this kind of policy and training in place to make it work.”
The driver would be considered “on-duty, not driving” for that time if they did not log out. Even if the driver does log out, he or she could still be hurt by the running clock within the 14-hour on-duty window because the ELD clock never stops ticking.
“In the new world all of these events will be presented upon login,” says Chianelli. “Drivers are going to hop in and log into the display. They are going to have to accept or reject all of the unassigned driving events associated with that vehicle. When they get into their trucks in the morning, drivers will have more steps and more things to get through besides just inspecting and then moving forward.”
Training beyond drivers
When it comes to routing and scheduling, drivers will need to understand that all the flexibility they previously had will disappear. They will be first to pay that price, but it will be up to fleet managers to optimize available hours, and that could involve dispatch and operations as well as the sales staff.
It’s one thing for a sales rep to promise a delivery time, but if the driver can’t do it within the Hours of Service constraints, the ELD will put a stop to it. That leaves it up to operations and dispatch teams to manage the drivers’ time. For example, even if a load could be legally delivered within a certain window, there’s no point in dispatching a driver who doesn’t have enough hours available.
That will require more transparency from the driver and dispatch as well as the shipper. It will no longer be as simple as saying an 800-kilometer trip at an average of 90 km-h will take “X” hours. You have to factor in congestion, the potential for delays, and even the availability of parking if it’s an overnight trip. Cutting a driving shift short by an hour to procure a parking space could compromise the schedule if contingencies are not built in ahead of time.
“Carriers who have drivers that are operating close to a 14-hour day may have issues that they are unaware of, or issues that they are aware of and let fester,” warns Kate Rahn, director of sales at Shaw Tracking. “These are the carriers that need to plan and implement this program early. This would allow them the time to address lingering issues with shippers and receivers, improve communications and implement any training or procedure changes with their dispatch and operations team.”
Those operational realities and the -procedural changes to overcome them could pose serious concerns for shippers and consignees, who now have a -considerable role to play in planning and executing trips.
“There is a lot of dialogue going on now between carriers and their customers,” says Reader. “They [shippers and consignees] are really interested in how ELDs are going to impact delivery time. They want to know, is there going to be more turnover in the driver population, are delivery schedules going to be impacted.”
There is an irony in the fact that some shippers are causing headaches by keeping trucks at docks for hours at a time, not honoring appointments and not being flexible. ELDs will bring that wasted time to the forefront pretty quickly, and shippers are realizing that uncooperative customers risk losing favored-shipper status with carriers.
“Now is the time to have those discussions with your customers,” advises Joel Beal of JBA Telematics, a Fort Worth, Texas-based transportation technology consultant. “They want to know how their world is going to change after December 2017 [when U.S. Federal Motor Carrier Safety Administration’s ELD mandate becomes effective]. Most of them are aware of the anti-coercion rule, and they are concerned.”
According to regulators, coercion occurs when a motor carrier, shipper, receiver, or transportation intermediary threatens to withhold work from, take employment action against, or punish a driver for refusing to violate certain provisions of the Federal Motor Carrier Safety regulations, hazardous materials regulations, and the federal motor carrier commercial regulations. No actual violation has to be involved.
Obvious examples would be carriers that withhold work from a driver who will not violate a rule. A less obvious example would be a shipper attempting to force a driver off its premises even if the driver is out of hours and unable to legally drive.
Carriers will have to be upfront with their customers in explaining the ramifications of this rule and how they could be affected. The big change will come once the ELD rule comes into play and drivers cannot sidestep the Hours of Service rules to leave the property.
“ELDs are a learning curve for all parties,” says Rahn. “Companies that are proactive and implement the program before the deadline will be much better off than those who don’t as they will have the opportunity to work with their customers and their drivers to make the new environment work for everyone.”