Technology

ELDs: Do You Really Need Them?

Lexi Tucker
Posted on August 6, 2018

ELDs plug into a vehicle and reports every time it moves. This is used to ensure drivers are not taking liberty with the number of hours they’re actually driving. (Wikimedia photo by FleetBeat)
ELDs plug into a vehicle and reports every time it moves. This is used to ensure drivers are not taking liberty with the number of hours they’re actually driving. (Wikimedia photo by FleetBeat)
Joe Guinn and Chris Przybylski of Limo and Bus Compliance presented a webinar for LCT on May 31 that delved deeper into the question of when companies really need to implement ELDs.

“There’s a huge push right now for manufacturers who are trying to get as many sales as they can,” especially using the prospect of road checks, Guinn told a webinar audience of operators, referring to a then-pending June 5-7 inspection.

An ELD is an “electronic logging device” truck drivers have been using because they are limited by the number of hours they can legally drive that’s considered safe for the motoring public.

ELDs plug into a vehicle and report every time it moves. This is used to ensure drivers are not taking liberty with the number of hours they’re actually driving. The ELD mandate took effect in December 2017 with a claim of leniency period to allow implementation by carriers. The mandate came out over two years ago, so this has not been a surprise to ground transportation companies.

Do You Need ELDs?

If you only run sedans and SUVs, this article is likely not relevant to your operation. The Federal Motor Carrier Safety Administration has mandated regulation of any vehicle over nine passengers or more than 10,001 pounds that travels to the airport or leaves the state.

“If you have vehicles subject to FMCSA regulations, all of the basic things you think of with CDL drivers apply even if you’re just operating vans and limos to and from the airport,” Przybylski said. “Hours of service records, driver qualification files, vehicle inspections, maintenance plans, records, 45 or 90 days depending where you’re at. And then if you’re CDLs, drug and alcohol policies. The biggest thing from the DOT perspective is if you don’t have it recorded and written down, it doesn’t count. So all the policies have to be written out and you must have the things to go with them.”

Joe Guinn of Limo and Bus Compliance advises operators to carefully check if federal rules require them to install ELDs, since vendors are pushing to get as many sales of the devices as they can.
Joe Guinn of Limo and Bus Compliance advises operators to carefully check if federal rules require them to install ELDs, since vendors are pushing to get as many sales of the devices as they can.
There are two common exemptions to ELDs that apply to limousine and bus companies. The first primarily concerns bus companies. If your vehicles are 1999 or older, there are exemptions for that. Those exemptions also take into account factors such as engine swaps; older engines that didn’t have OBD2 and JBOS, which are the protocols used for ELDs. Obviously for most limo companies, fleets tend to be younger than that.

The second is called the 100 air mile exemption. “Basically, an air-mile is a nautical mile in common terms. It’s as the crow flies and about 115 miles. It’s a radius from your terminal. So if you have multiple offices, it would be from that driver start and your office, which can make a huge difference for companies operating in multiple states,” Przybylski said.

To qualify for the exemption, operators need to meet two criteria: The driver has to be off duty within 12 hours of going on duty. “It doesn’t matter if they had gaps during the day. They came in at 6 a.m., they have to be gone at 6 p.m.,” he clarified.

The other is they don’t exceed 100 air-miles from their starting terminal. Because it’s a radius, they can go 80 miles in one direction and then 80 miles in the other direction and still be within the 100 air-miles. To use this exemption for ELDs, you must qualify at least 22 times out of every 30 days. The exemption follows the driver. So some of your drivers could be exempted while others are not.

If you have a few chauffeurs who do over the road trips primarily for you, every vehicle that chauffeur touches would need an ELD. So, if you restrict them to one bus or maybe one bus and one van, you can just put ELDs in those vehicles. You don’t need the ELDs if they drive a bus, sedan, and SUV as well. You would need it in the bus, but not in the sedans and SUVs.

With creative scheduling and paying attention, you can limit the cost exposure for your company.

I Need ELDs. Now What?

If you do need to buy ELDs, there are some points to consider. The first is compliance. To register with the FMCSA, you just have to tell them your program is compliant. There’s no test or formal certification process. You simply sign a certified agreement stating you’ve read the requirements and your program adheres to them. Most ELDs are designed for trucking companies which have different rules than passenger carriers. These may be great for trucking companies, but they may not work with mixed lead or passenger carriers.

Another factor is price. “I’m seeing ELDs everywhere from $15 a month to $75 a month, but they generally do the same things,” Przybylski said. “Some units are plug-and-play, and others require hardwiring into the vehicle. There are upsides and downsides to both. Of course, the plug-and-play ones can be unplugged by the chauffeurs. The hardwire ones you have to pay someone to install, generally.”

Finally, how easy is it to use? “Anybody who’s done a technology implementation with a group of chauffeurs knows there are definitely challenges in getting everyone onboard using the program properly. It’s no different with ELDs. There’s a learning curve with it and a decent amount of management and follow-up time to be implemented.”

ProsCons
  • Creates an electronic log
  • Cost (hardware cost and a monthly subscription fee)
  • Gives you more flexibility in scheduling
  • Administrative burden
  • You don’t have to worry about losing track of the amount of time a driver works
  • Training
  • Automates some of the duty status changes
  • Possibility of outages

 

Keep Affiliate Work In Mind

Luxury transportation companies often have many events where they help affiliates in other cities. “When the Super Bowl was here in Phoenix, a bunch of companies came from Los Angeles,” Guinn said. “We even had some who came from New Mexico. They spent the better part of five days here. One thing to realize with this exemption is that on the day of travel, these companies traveled more than 100 air-miles. But every day they worked in Phoenix, they were able to actually use the

With creative scheduling and paying attention, you can limit the cost exposure for your company, said Chris Przybylski of Limo and Bus Compliance.
With creative scheduling and paying attention, you can limit the cost exposure for your company, said Chris Przybylski of Limo and Bus Compliance.
exact same exemption simply by changing their home terminal. So, whatever their partner’s address was, that became their home terminal. During the entire Super Bowl, nobody traveled more than 100 air-miles. So you can take advantage of things like this in your operation to allow you to not have to worry about maintaining your exemptions.”

Hours of service violations continue to be the number one violation companies get written up for during audits. If you sit down with your auditor and explain you use the time clock exemption, they will only scan for those 12 hours or 100 air-miles.

“So if you’re located in Austin, Texas, your auditor comes in and he’s going to look at your trip sheets for a driver. They’re all going to look for anything that [indicates] possibly going up to Dallas or going across to Louisiana or something like that. They’ll single those days out or they’ll look for anything that goes more than a 12-hour work day where the driver came in and then their last trip ended outside of 12 hours,” Guinn said.

For more information, watch the full-length webinar here

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Related Topics: buses, chauffeur training, driver safety, driver training, ELDs, fleet tracking, How To, industry education, managing chauffeurs, motorcoach operators, motorcoaches, passenger safety, Safety, trip tracking

Lexi Tucker Associate Editor
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