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Marc's Safety Corner

Ask our expert, Marc Moncion, any questions you may have around fleet safety, compliance, DOT audits, roadside inspections or CSA scores. 

Ask our panel of experts, Marc, Guy and Brayn, any questions you may have around fleet safety, compliance, DOT audits, roadside inspections, CSA scores, or installation best practices.

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Dear Marc,

If I am running AOBRD and am stopped by a DOT inspector, am I exempt from emailing the hours of service log upon request of DOT since a lot of AOBRD solutions do not have the functionality to email directly from the app?

 

Dear Reader,

According to Part 395(3)(b)(1) an automatic on-board recording devices (AOBRD) shall produce, upon demand, a driver's hours of service chart, electronic display, or printout showing the time and sequence of duty status changes including the drivers' starting time at the beginning of each day. 

Since the regulation is silent on the requirement to data transfer the logs to DOT, including by email, there is no prescribed requirement to email, unless of course a driver is able to transmit the logs and the DOT can actually receive the logs as well! Therefore, a driver will not be in violation if stopped at roadside with up to date logs. These records of duty status can be displayed electronically or printed out for the previous 7 consecutive days which are in his/her possession, and available for inspection by DOT while on duty.

Here's how you would go through a roadside inspection if you are using BigRoad AOBRD solution.

 

The scenario is quite different if a motor carrier and their drivers’ are operating under ELD. In this case, there is a whole new set of requirements to follow. 

To begin, a driver must still be able to provide either the display or a printout when an authorized safety official requests a physical display of the information. In addition, the motor carrier must ensure that its drivers’ possess on-board a commercial motor vehicle an ELD information packet, which in itself can be in an electronic format or paper copy.  Our Fleet Complete/BigRoad HOS solutions includes an electronic information packet incidentally!

This packet must include a user's manual for the driver describing how to operate the ELD.  The driver must also have an instruction sheet that describes how the data transfer mechanisms is supported by the ELD. 

It is imperative that the driver understands how the ELD works,  otherwise things will go sideways very quickly at roadside with DOT.  This includes having a clear understanding of the step-by-step instructions for producing and transferring his/her hours-of-service records to the DOT. 

The instruction sheet must also describe the ELD malfunction reporting requirements, as well as the record-keeping procedures if and when an ELD malfunctions.  In addition, the driver must have in his/her possession a supply of blank driver logs that are sufficient to record the driver's duty status and other related information for a minimum of 8 days.

Finally, the ELD must support one of two options for electronic data transfer.  The first and most common option is a “telematics” transfer type ELD. If this option is selected, the ELD solution must at a minimum be able to electronically transfer data to DOT upon request and via a wireless web service and email. The second option is the “local” transfer type ELD.  In this case, the ELD solution must at a minimum electronically transfer data to DOT upon request via USB2.0 and Bluetooth®.

If the driver is using a “telematics” ELD with email capabilities, the DOT will request that the electronic data transfer file be sent as an attachment to an e-mail. This e-mail address is preprogramed in the ELD by a vendor, such as Fleet Complete. DOT is then required to provide the driver with a routing code to reference in the email.

If the driver is using a “telematics” ELD with wireless web services capabilities, the DOT will give the driver a routing code to assist the official in locating the data once transmitted.  The driver will then initiate a web transfer to an FMCSA server to be retrieved by the DOT’S software back to the DOT at roadside.

Here is how you would go through a roadside inspection if you are using BigRoad ELD solution.

Finally, one little known fact is if the electronic means for transferring data is unavailable or fails, the driver can still be compliant by showing either a printout or the actual ELD display of their RODS. This can and will happen if there are cellular network limitations that prevent the ELD from transferring data to the Federal Motor Carrier Safety Administration’s (FMCSA) web services. In those instances, having the printout or display is the key for your driver’s to remaining compliant.

The above information is for informational purposes only, and should in no way be relied upon as legal advice.

  Feb 28, 2019     Marc Moncion

Moncion-Marc

Marc Moncion

Marc is the Head of Safety, Compliance & Regulatory Affairs at Fleet Complete. He is an author and industry subject matter expert who has worked in numerous senior transportation management roles for over 25 years, including an Inspector for the MTO. Marc sits on several Federal/State/provincial regulatory bodies and frequently provides commentary on emerging technology, best practices and regulatory affairs. In addition, Marc is a commercial driver's licence (CCD) holder and can drive all types of commercial vehicles in North America.

Get to know Marc here!

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Ask The Expert - Guy Broderick (Driver trainer)

 

Guy Broderick linkedin2

Guest Expert - APPS Transport Group

Guy is a Driver Recruiter/Training Supervisor and Social Media Specialist at APPS Transport Group. Certified under the WSIB guidelines and a member of JHSC, Guy is an integral force behind the company's impeccable driving record. The APPS Safety Team has achieved the highest rating of Commercial Vehicle Operator Registration (CVOR) given by the Ministry of Transportation in Ontario. Since 2010, Guy has written for and contributed to numerous publications and associations, as well as has been elected as Chair of Ontario College of Trades Tractor Trailer Driver Trade Board, recently re-elected as Chair for the TTSAO Carrier Group, has sat on numerous provincial industry committees and is a Award Winning Driver recognized on both sides of the border.

 


 

Ask The Expert - Brayn Levi Gomez (professional installer)

 

Brayn Gomez  linkedin2

Guest Expert - Certified Professional Installer

Brayn transformed his passion and hobby of installing multimedia devices and car kits in luxury vehicles into a career in 2004. Since then, Brayn has installed thousands of electronics and GPS systems in a variety of vehicles and machines with or without a power source, even on bicycles. Bryan provides professional installation, re-installation and on-site technical services to Fleet Complete customers. Throughout his career, Brayn has encountered the effects of improper GPS system installation on the integrity of the vehicle and driver's safety, and offers his insights and tips to help ensure fleet managers and technicians are using best practices to install GPS equipment in their vehicles.