18 4 AOBRDs v. ELDs AOBRDs v. ELDs – Highlighting Some Differences OPERATIONAL & MISCELLANEOUS ISSUES AOBRDs ELDs “Unassigned Driving” Time Not required or addressed Must be captured and driver must approve or reject at time of login. If rejected, back office staff must reconcile and retain “Special Driving Categories - Yard Moves” Not required or addressed by rule. Market has resulted in vendor inclusion in AOBRDs Defined under new “special driving categories” section. If used, must be selected and deselected manually by driver, and is captured as “on-duty not driving” while in private yard. No mileage or time limits prescribed. Carrier may elect not to use special category “Special Driving Categories – Authorized Personal Use” of CMV Not required or addressed by rule. Market has resulted in vendor inclusion in AOBRDs Defined under new “special driving categories” section. If used, must be selected and deselected manually by driver, is shown on graph grid as driving time but is, by definition, “off duty” time. Carrier may elect not to use special category Driver Edits Not required or addressed Editing function must be provided to driver for mistakes. All edits must also be “annotated.” Driving time may not be edited by driver. Office Support Staff Edits Not required or addressed Edits by office staff allowed. All edits must be “annotated” and all office staff edits are pending until accepted by driver. Driver Certification of Daily Record Not required or addressed Required driver certification after the final required entry has been made or corrected for each 24-hour period. User Accounts Not required or addressed. Market has resulted in user IDs and passwords Unique username (and other required driver information) required for all authenticated drivers/users. Device Malfunctions – Time Period to Repair or Replace Not addressed Driver must notify company in writing within 24 hours of device malfunction. ELDs must be repaired or replaced by company within 8 days. Driver must revert to paper logs during ELD malfunction period. Device Registration & Certification Not addressed All ELDs must be registered with FMCSA, and self-certified by each vendor as compliant. Registered and certified ELDs are listed on FMCSA ELD website. Carriers may only select and use certified ELDs. Information originally compiled by Scopelitis Transportation Consulting, LLC