1 Training Updating Company Policies & Procedures – An Important Step in ELD Implementation Reviewing and updating company policies and procedures is an important and necessary step toward successful electronic logging device (ELD) implementation. Most carriers have formal safety and compliance-related policies and procedures, and they should be reviewed and updated as part of the transition to ELDs. Here are some issues to consider during the review process: 1. USE OF TRUCKS BY DRIVERS 3. UNASSIGNED DRIVING TIME WHILE OFF-DUTY One of the newer concepts with ELDs is “unassigned driving time.” Professional truck drivers operating their trucks (unladen) for As mentioned in B above, ELDs will capture truck movement, even personal reasons while on-the-road, and off-the-clock, is nothing if no one is logged in to the ELD. Each one of these “unassigned new. In fact, personal use (called “personal conveyance” or “PC” driving time” events must be reviewed by the driver of that truck by government regulators) is a common and accepted industry during his/her next login, and that time must either be accepted or practice. As a result, the ELD rules accommodate this type of off- rejected by the driver. If the driver rejects the time, the rules require duty truck use. For employee drivers and company owned trucks, carrier staff to review all “unassigned driving time” events, and it’s the carrier’s choice on whether it will allow use of PC. Does assign them to the appropriate driver, or explain in a note on the your company have a policy allowing it? If so, does it need to be ELD record why it is unassigned. Does your company have a policy updated? If not, should your company consider having a policy? Is and procedure on who will handle this responsibility? Does your your company aware of FMCSA’s guidance on PC? company have or need a policy designed to limit the number and type of “unassigned driving time” events? 2. MOVING TRUCKS ON A YARD 4. EDITING OF ELD RECORDS Before ELDs, when a driver moved a truck on a yard, the hours of service rules required the driver to record that time on his paper Drivers will make mistakes while using ELDs, and many of them log. It was an honor system. ELDs will automatically capture every will be honest mistakes. The new rules accommodate this reality, truck move on a yard, and record it as driving time, unless the and allow both drivers and carrier staff to make needed edits. Does driver pushes the “yard moves” button. If the yard moves button is your company have a policy regarding whether you prefer drivers pushed, the ELD will record that time as on-duty not driving time make needed edits, or company staff? Should you consider how (line 4). If a mechanic or other non-driver moves a truck on a yard quickly edits must be made? What if a driver wants to edit his/her (or on a highway to road test a truck), and doesn’t log in to the ELD record days after it was submitted? ELD device, the ELD label the person as an “unidentified driver”, and it will capture the time as “unassigned driving time.” Does your 5. ELD MALFUNCTIONS company have a policy on non-drivers moving trucks on a yard, or ELDs are computers, and computers can and do fail. When they on the road? Does your company have a policy on whether non- do, the ELD rules require drivers to notify the carrier in writing drivers, who move trucks on a yard/road, are given an ELD user within 24 hours, and default to a paper log during the malfunction account? If not, you’ll need a policy. time- period. Also, the rules require malfunctioning ELDs be fixed or replaced within 8 days. Companies may want to consider 4