ARLINGTON, Va. — The  American Trucking Association has told the federal government that it supports electronic logs, as long as all the legislative i’s are dotted and t’s are crossed before the law is presented to Congress.

Specifically, the ATA says, truckers and enforcement authorities should know exactly what back-up documents they need when they use EOBRS; and the EOBR equipment itself must be clearly defined.

Which, unfortunately, is not the case yet.

"The [Federal Motor Carrier Safety Administration] must address some of the device design and performance specifications which are critical to the success of such a mandate," the ATA said in a prepared statement to the FMCSA.

These critical issues include a more secure driver-identification and authentication process, and improved standards to ensure the devices are not prone to tampering or fraud.

"FMCSA’s [current] proposal to require carriers retain a document (or documents collectively) to verify the beginning and end of each on-duty/not driving time period is unrealistic. Available documents typically lack such precision," ATA said in its comments (full version available here).

"The agency’s suggestion that carriers certify that such documents don’t routinely exist would place those carriers at great risk.”

The FMCSA had proposed that carriers make such certifications, but that they also be automatically subject to the maximum civil penalty if found to have made a false certification.

"The agency should establish a finite list of documents that carriers must maintain and declare that those that do so will be deemed to be in compliance,” ATA told the agency.

ATA also criticized FMCSA for failing to establish a list of documents that must be retained at a “reasonable cost” to motor carriers as required by Congress in the 1994 Hazardous Materials Transportation Authorization Act (HMTAA).

ATA had previously sued the agency for repeatedly failing to meet the 17-year-old Congressional mandate.