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ELD Checklist for Carriers

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If you are a driver, visit the ELD Checklist for Drivers.

Also, see Tips for Choosing a Compliant ELD.

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Carrier Actions

Deadline/When to Take Action

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Understand key ELD rule requirements affecting carriers and drivers

Now, to prepare for the transition to ELDs

Access FMCSA webinars: https://www.fmcsa.dot.gov/hours-service/elds/training-and-events

Get more information online: https://www.fmcsa.dot.gov/hours-service/elds/drivers-and-carriers

Identify and understand exemptions that may apply to your drivers and operation

Now, to prepare for ELD transition

The ELD Rule applies to most motor carriers and drivers who are currently required to maintain records of duty status (RODS). Learn more and see exemptions at: https://www.fmcsa.dot.gov/hours-service/elds/drivers-and-carriers

If you are exempt from using ELDS, keep proper documentation to support your exemption

Understand when you must use ELDs in your fleet

Before Dec. 18, 2017: operators can use ELDs voluntarily – or continue using paper logs, devices installed with logging software and applications, or AOBRDs

Dec. 18, 2017 – Dec. 16, 2019, carriers must use ELDs unless they use AOBRDs installed before Dec. 18, 2017

After Dec. 16, 2019 – all carriers must use ELDs

Get more information on ELD Rule implementation at: https://www.fmcsa.dot.gov/hours-service/elds/implementation-timeline

Develop an ELD implementation plan and timeline to ensure compliance

 Now, to prepare for ELD transition

 

Evaluate and select ELDs

Prior to December 18, 2017

Be aware that ELDs must be certified by the manufacturer as compliant and listed on FMCSA’s website: https://www.fmcsa.dot.gov/hours-service/elds/equipment-registration

Develop tailored ELD processes and guidance for drivers and administrative staff

Well in advance of the ELD implementation deadline that applies to you

Create or adopt best practices:

  • Guidance for consistent & clear annotation
  • Processes for submission & retention of required supporting documents
  • Processes for reporting & resolving ELD malfunctions or other technical issues

Develop training tailored for compliance managers, drivers, administrative personnel, and other ELD users

Well in advance of the ELD implementation deadline that applies to you

Include:

  • Compliance requirements and processes
  • Supporting document requirements & processes
  • ELD operation
  • Proper editing of records
  • ELD data retention
  • Understanding & preventing harassment and coercion
  • ELD troubleshooting/malfunctions

Install & test ELDs, establish user accounts

Well in advance of the ELD implementation deadline that applies to you

Create Accounts:

  • Drivers
  • Administrative Users
  • Other ELD Users

Conduct training

Prior to the ELD implementation deadline that applies to you, and on an ongoing basis

Provide:

  • Initial/orientation training
  • Follow-on or refresher training
  • “Spot” training or user tips for common mistakes

Ensure drivers have required user documentation in vehicles

If you use ELDs before Dec. 18, 2017, keeping documentation in the vehicle is recommended

Having documentation in vehicles is mandatory beginning Dec. 18, 2017

Mandatory Items are:

  • ELD User’s Manual
  • Instruction sheet for transferring HOS records to safety officials
  • Instruction sheet on reporting ELD malfunctions & recordkeeping procedures during ELD malfunctions
  • A supply of paper tracking forms (grid graphs) for at least 8 days, in case of ELD malfunction

Retain required supporting documents

Continuous

  • Carriers must retain not more than 8 documents per day for each driver
  • Carriers retain documents for 6 months (digital versions are acceptable)

Get more information at: https://www.fmcsa.dot.gov/hours-service/elds/eld-supporting-documents-phase-2

Retain ELD data and backup data on separate systems

Mandatory beginning Dec 18, 2017

  • You must retain ELD data and backup data for 6 months
  • You must ensure secure storage of all data and backups to protect driver privacy

Understand harassment and the penalties for it

Harassment protection takes effect as soon as you begin using ELDs

  • It is harassment if a carrier uses ELD data to pressure a driver to take action that results in an HOS violation or to drive when ill or fatigued
  • Carriers are subject to a penalty for harassment as well as the penalty for the HOS violation

Learn more at: https://www.fmcsa.dot.gov/hours-service/elds/harassment-protection

NOTE: AOBRD requirements (49 CFR 395) are the same as prior to the ELD rule, but all AOBRD users are subject to the new supporting document requirements in the ELD Rule starting on the compliance date.

All paper log users are also subject to the new supporting document requirements in the ELD Rule starting on the compliance date.

Updated: Wednesday, August 2, 2017
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