Trucking Regulations: 3 Days til ELD mandate, and it is going to be a mess. (for carriers and brokers)

[mosinee dave]

Was sitting home already loaded when I was checking Internet truckstop on in state frieght for the heck of it. Noon on Friday Co paying 800.00 on a 160 Mile load. 3:00 pm it's paying 1000.00. At 5:00 pm 1500.00. Someone was caught with no Truck. 160 miles for 1500.00 to bad I was loaded already this was a reefer load.

 

[ironpony]

Here's a legit question.

Let's say you're an O/O leased onto a company that requires elogs as a company policy. Let's say you're also running a pre-1999 truck. That means you're essentially running elogs on a voluntary basis, even though legally you're not required.

Would you have to get the AOBRD in 2019? If yes, what if your truck isn't compatible ie doesn't support the parameter inputs?

You'd need a new truck in 2019. AOBRDs are non-compliant after Dec whatever 2019.

 

[Hammer166]

what if your truck isn't compatible ie doesn't support the parameter inputs?

I'll answer this part...

Long before there were ECMs there were electronic logs. Installation was a pita because you had to splice into the speedometer and tach signals in order for the logging device to read those inputs. So to get a truck that you couldn't get those inputs would require going back into the early 80's when there were still a few trucks with mechanical tachs and speedos being produced.

 

[Tazz]

You have that backwards, but my guess is if your on an AOBR now because of company policy it will still work when ELDs are fully implemented.

 

[Electric Chicken]

I'll answer this part...

Long before there were ECMs there were electronic logs. Installation was a pita because you had to splice into the speedometer and tach signals in order for the logging device to read those inputs. So to get a truck that you couldn't get those inputs would require going back into the early 80's when there were still a few trucks with mechanical tachs and speedos being produced.

So are pre-1999 trucks no longer exempt in 2019?

 

[Tazz]

So are pre-1999 trucks no longer exempt in 2019?

No They will not be subject after that date

 

[Electric Chicken]

You have that backwards, but my guess is if your on an AOBR now because of company policy it will still work when ELDs are fully implemented.

I probably did get them reversed.

I have a specific scenario for asking. JB Hunt doesn't care what year your truck is but they put an elog in it. If it's an older truck it's just a hot wire and ground. It doesn't talk to the truck in any way. It's no different than using a smart phone log.

What I'm wondering is, since you're voluntarily using it (for that contract), what happens in 2019 when they're supposed to be getting all kinds of other data and parameters and such?

So all of a sudden everyone needs a 2001+ truck in 2019?

 

[Tazz]

I probably did get them reversed.

I have a specific scenario for asking. JB Hunt doesn't care what year your truck is but they put an elog in it. If it's an older truck it's just a hot wire and ground. It doesn't talk to the truck in any way. It's no different than using a smart phone log.

What I'm wondering is, since you're voluntarily using it (for that contract), what happens in 2019 when they're supposed to be getting all kinds of other data and parameters and such?

Anything your going to buy as @Hammer166 said will be compliant. It is a matter of tying into the speed sensor and tach.

You would have to buy an 89 or older probably to not have an electronic speed sensor. Maybe earlier.

 

[Hammer166]

I probably did get them reversed.

I have a specific scenario for asking. JB Hunt doesn't care what year your truck is but they put an elog in it. If it's an older truck it's just a hot wire and ground. It doesn't talk to the truck in any way. It's no different than using a smart phone log.

What I'm wondering is, since you're voluntarily using it (for that contract), what happens in 2019 when they're supposed to be getting all kinds of other data and parameters and such?

So all of a sudden everyone needs a 2001+ truck in 2019?

I see what you're asking now. AOBR don't have to pull data from the truck, but they are only good until Dec 2019. At that point everyone has to have an ELD, except the pre-2000 year model engines (and whoever else manages to get an exemption between now and then.) So if you have an old truck on with JB, they may insist on installing one, but it's not going to be required to have all the data linked to the truck.

 

[Ontario Outlaw]

I see what you're asking now. AOBR don't have to pull data from the truck, but they are only good until Dec 2019. At that point everyone has to have an ELD, except the pre-2000 year model engines (and whoever else manages to get an exemption between now and then.) So if you have an old truck on with JB, they may insist on installing one, but it's not going to be required to have all the data linked to the truck.

I thought the AOBR had to link to the truck? Whether hard wire or Bluetooth

 

[Electric Chicken]

I see what you're asking now. AOBR don't have to pull data from the truck, but they are only good until Dec 2019. At that point everyone has to have an ELD, except the pre-2000 year model engines (and whoever else manages to get an exemption between now and then.) So if you have an old truck on with JB, they may insist on installing one, but it's not going to be required to have all the data linked to the truck.

Okay gotcha. So basically talking to the truck isn't actually part of ELD compliance? Or are you saying not having that is part of the exemption? Could pre-2000 stay on paper logs after 2019?

I haven't followed too much of this because it wasn't until recently that I even considered having a truck of my own a possibility.

 

[Hammer166]

Okay gotcha. So basically talking to the truck isn't actually part of ELD compliance? Or are you saying not having that is part of the exemption? Could pre-2000 stay on paper logs after 2019?

I haven't followed too much of this because it wasn't until recently that I even considered having a truck of my own a possibility.

Talking to the truck is very much the heart of the ELD regs, pages and pages. Think of an AOBR as a 2 year waiver for ELD compliance, while pre-2000 is exempt from the ELD mandate.

 

[Electric Chicken]

So pre-2000 can do paper logs after 2019.

If pre-2000 wants to use an elog, it doesn't have to communicate with the truck.

Do I get it yet?

 

[Hammer166]

I thought the AOBR had to link to the truck? Whether hard wire or Bluetooth

The only thing in the regs concerning the truck and the AOBR is that it must notify of sensor failure. But the actual interface to the truck isn't addressed in any way by the regs, and you can make a compliant AOBR that works strictly off of GPS.

 

[Hammer166]

So pre-2000 can do paper logs after 2019.

If pre-2000 wants to use an elog, it doesn't have to communicate with the truck.

Do I get it yet?

Sounds like it.

Although I can picture having a ELD on dash making it really hard to convince Johnny Law that you're exempt.

 

[Electric Chicken]

Sounds like it.

Although I can picture having a ELD on dash making it really hard to convince Johnny Law that you're exempt.

I'd just show him the plate on the motor. Should work.

But even if you're exempt, having one wouldn't be a problem I don't imagine.

 

[Hammer166]

Should work.

Ah, young Jedi. Much to learn about the wearers of the badge, you have.



But yeah, for the most part, if it's sitting on the dash powered up, most aren't going to dig a lot deeper, and most of those with the knowledge and know how to do so will likely be the guys who know you're exempt anyways, so it wouldn't matter if there's no data connection. Frankly, I imagine most of the checking on data is going to happen at audit level, as the inconsistencies don't show on the devices, but on the back end in the office.

 

[Ontario Outlaw]

The only thing in the regs concerning the truck and the AOBR is that it must notify of sensor failure. But the actual interface to the truck isn't addressed in any way by the regs, and you can make a compliant AOBR that works strictly off of GPS.

Any links to said AOBR?

 

[Hammer166]

@dchawk81 , was perusing the FMSCA site, and saw this:

If the vehicle registration for a commercial motor vehicle reflects a model year of 2000 or newer, but the vehicle was manufactured without an engine control module (ECM), is the carrier required to comply with the ELD rule?


Yes, a motor carrier operating a vehicle with a manufactured model year of 2000 and newer and without an ECM is subject to the ELD rule. If the currently installed engine does not support an ECM and is unable to obtain or estimate the required vehicle parameters, then the operator must use an ELD that does not rely on ECM connectivity, but nevertheless meets the accuracy requirements of the final rule. See Appendix A to Subpart B of Part 395 sections 4.2 and 4.3.1 of the ELD rule for accuracy requirements.

I'd forgotten they'd put that in there. So it could be that the carrier could provide you with an ELD that didn't require ECM comms to be fully compliant. Although I would think it unlikely they'd invest in separate units for the few pre-2000 trucks in the fleet.

 

[Electric Chicken]

That says 2000 and newer without an ECM.

But at least we know the registration card should be adequate proof of exemption for older stuff.