1 Training maintaining a “safety stock” of backup ELDs which can be 10 or more hour off-duty between work shifts. Does your company swapped for malfunctioning units during the 8-day grace period. policy address this as well? Does your company have policies and procedure covering these 8. ANTI-HARASSMENT new requirements? What is the preferred company procedure for The new ELD rules include language that strictly prohibits a carrier drivers to communicate a malfunction in writing within 24 hours from using information obtained from the ELD to force a driver to (i.e., an email, a text message, listing it on a DVIR)? Who in the violate applicable hours of service rules, or drive while either ill or company is responsible for working with your ELD vendor when an fatigued. This rule is separate and distinct from FMCSA’s anti- ELD malfunctions? If your vendor cannot provide a solution within coercion rule. Does your company have a policy designed to ensure 8 days, who in the company is responsible for working with FMCSA compliance with this new anti-harassment rule? And, if a driver on an extension? believes the company may be in violation of this rule, does your company have a procedure in place to handle this type of driver 6. SAFETY & COMPLIANCE BONUSES complaint? Are drivers aware of the process to file such complaints If you have a bonus program for drivers tied to safety and/ with FMCSA? or compliance performance, does it address hours of service compliance and ELD use? If not, should you consider it to help This list is not exhaustive, and is intended to get carrier personnel facilitate driver acceptance of ELDs, and proper use? thinking about current policies and procedures that may need to be updated, and new company policies that may be needed. 7. DISCIPLINARY POLICIES Paper logs allowed, and required, drivers to log all working and off-duty time in 15 minutes increments. With this paper log limitation, a driver, who may have been a few minutes past the maximum driving time, likely reflected it on the paper log as exactly 11 hours of driving time. ELDs will capture every minute of driving time, which means 11 hours and 5 minutes of driving time will be reflected as just that. And, it is a violation. Does your company’s disciplinary policy for hours of service violations address this new ELD reality? A similar scenario could develop for drivers not taking 5