What is AOBRD?
The term "AOBRD," or "Automatic On-board Recording Device," has been defined since the 1980s as "an electric, electronic, electromechanical, or mechanical device capable of recording driver's duty status information accurately and automatically as required by §395.15. The device must be integrally synchronized with specific operations of the commercial motor vehicle in which it is installed. At a minimum, the device must record engine use, road speed, miles driven, the date, and time of day."
Many of the devices installed prior to December 18, 2017, were AOBRDs. However, as of December 17, 2019, all AOBRDs must have been updated to meet the ELD technical specifications.
What is ELD?
An electronic logging device (ELD) is the most recent type of electronic log. ELDs are capable of recording a driver's driving hours and duty status automatically. To be considered an ELD, the device must meet specific technology requirements and be listed on the FMCSA ELD registration site. As of December 17, 2019, only ELDs listed on FMCSA's ELD registry are considered compliant electronic logs.
What is ELog?
E-Logs or ELogs is a generic term used to a logging device that automatically captures certain information (such as when the driver is driving). The only acceptable e-log as of December 17, 2019, is an ELD.
What is EOBR?
Electronic on-board recorders (EOBRs) were the devices that were originally intended to replace AOBRDs, but the rulemaking to do so was never finalized.
Is electronic logging required?
The FMCSA published the ELD mandate in the December 16, 2015, Federal Register. Motor carriers had until December 18, 2017, to comply with the ELD mandate, which required the use of ELDs or grandfathered AOBRDs by most interstate drivers of commercial motor vehicles to record their hours of service. Grandfathered AOBRDs were automatic on-board recording devices that were placed into service before December 18, 2017. Grandfathered AOBRDs must have been upgraded to meet the ELD technical specifications by December 17, 2019, to remain compliant.
What benefits come with using ELDs, even if not required to?
There are numerous benefits to using electronic logs:
- First and foremost, ELDs can greatly simplify compliance by eliminating the need for paper logs. Drivers and carriers see significant time savings from going paperless.
- Some of the most common logging violations can be eliminated. Virtually all “form and manner” log violations go away, drivers always know where they stand on compliance, and drivers always have a current log. Alerts will tell driver when they are approaching an hours-of-service limit. As a result, carriers that use ELDs see 50 percent fewer hours-of-service roadside inspection violations.
- Besides making compliance easier, ELDs make auditing easier and faster. The systems typically come with automated auditing built in.
- Roadside inspections can be easier and quicker.
- Scheduling and dispatch become easier because office personnel know the location of the vehicles and how much time drivers have available.
- Location, engine use, speed, and other data captured by the devices can prove valuable during litigation or other legal proceedings, potentially protecting both the driver and company.
Can a carrier install and/or use AOBRDs??
No. A carrier that had AOBRDs installed and in use prior to December 18, 2017, was allowed to continue using AOBRDs until December 17, 2019. As of that date, all devices in service must be ELDs.
My drivers do their logs on laptops and smartphones. Are those considered a compliant ELD?
These devices are not ELDs because they are not either directly or indirectly connected to the engine to automatically collect the required vehicle data (such as movement, engine hours, and speed data). Therefore, they cannot be used to satisfy the ELD mandate requirements. These non-integrated devices are allowed for logging only if the driver has an exemption to use paper logs rather than an ELD. If the driver is using a non-integrated logging app or program, the driver must be able to produce a compliant paper (printed) log on demand.
What does a driver using an ELD have to do at a roadside inspection?
The driver must be able to electronically transfer the records for the current day and the previous seven days to an inspector. The primary methods of doing so are either telematically through a web address or email, or locally through a USB 2.0 or a Bluetooth® connection. The driver must also be able to display or print the current and previous seven days for the officer. If a display is used, the officer must be able to view it outside of the vehicle. The officer will also ask the driver to present the device’s user manual, data transfer instructions, malfunction instructions, and eight blank paper logs.
In addition, the driver must provide any supporting documents that he or she has in possession to the inspector upon request.
Do drivers using ELDs ever have to print out logs for an inspector?
Drivers that are using an ELD only have to printing if the device does not have a display the officer can view outside of the vehicle.
What happens if an ELD stops working?
If an ELD malfunctions (is no longer functioning as a compliant recorder), the driver must:
- Note the failure of the device;
- Reconstruct paper logs for the current day and the previous 7 days, less any days for which the driver has records or that the device can still display;
- Continue to prepare a handwritten log until the device is working again; and
- Notify the carrier in writing within 24 hours of the failure.
Once notified, the carrier has eight days to repair or replace the device. If it cannot be repaired or replaced within eight days, the carrier can ask its local FMCSA office for an extension.
Ensure your drivers understand the regulations surrounding ELD failure and other mandate requirements with ELD and hours of service training.
Can the FMCSA request our GPS records during an audit?
Yes, records from Global Positioning Systems (GPS) associated with fleet management, communication, and tracking systems may be subject to audit by the FMCSA (whether those systems are a part of an ELD system or not). Such records are considered "supporting documents" for hours-of-service compliance, and must be maintained by the motor carrier for six months. The FMCSA may use GPS records to verify the information contained on drivers' logs, even if the company does not do so.
What has to be carried on the vehicle in addition to the ELD itself?
A driver using an ELD must also carry:
- A user's manual for operating the device;
- An instruction sheet with step-by-steps instructions for transferring hours-of-service records to an authorized safety official;
- An instruction sheet on reporting ELD malfunctions and recordkeeping procedures during malfunctions; and
- At least eight blank paper grid graph logs to record driver duty status and related information, in case of ELD malfunction.