Tom Cuthbertson – VP Regulatory Compliance – XRS Corporation

   Electronic Logging Devices:

What Happens Now? 

Agenda - Short

• Overview of some key notables

• Driver Changes

• Certification

• Transfer of Log Detail to enforcement

ELD SNPRM

• Mechanical Engines – Seeking comments• Carrier transitional operations –

AOBRD/ELD Same driver two devices in reporting period not addressed

• State and Canadian RODS Harmonization• AOBRD valid for 4 years after effective date

ELD SNPRM• Yard Moves - not Drive, Only On-Duty duty• Drive Starts at up to 5 MPH• Only Auto On Duty when stopped 5 minutes• No direction on Non-ECM vehicles• Did not specifically address OBD

Certification• Not third Party• Must supply

documentation• Description of certification

process allows FMCSA to authenticate

• Operations Manual• Registry at FMCSA

• eRODs Application Testing to insure integrity – need software

• What Level of Change requires recertification

• Security level testing

Interoperability

• Transfer eRODS file between Suppliers– Difficulty is Harmonization of State/Canadian

rules– Requirements to comprehend details required

to maintain the integrity of the previous periods information

– Not requirement – looked for comments

Items Specific For Drivers(address harassment)

• Allow Driver to edit their logs and create annotations on all entries and edits – NOT DRIVE TIME

• Drivers must approve all edits from Support Systems before applied • Require that drivers have direct access to the log information• Ensure that a driver reviews all edits before they are applied and

allow rejection• PC reduce accuracy of GPS and do not record all engine information

-10 mile accuracy• Audible muting of devices by driver• Coercion prohibited• 386.12a and 390.36 are new process regulations to file complaints

eRODS – Roadside Logs Transfer

Web ServicesBlue ToothEmail FileTransfer JetQRCODEsUSB Thumb DrivePrinting w/QRCODES

BLUETOOTH TRANSFER

• Bluetooth technically capable of transmitting large files

• Enforcement must have Bluetooth configurations specific to regulation

• Layer of Security

• Bluetooth must generate Personal ID to bond with enforcement equipment

• ELD must be made discoverable and generate a random code to be given to enforcement

• Connect to wireless personal area network and transmit via Web Service per 4.10.1.1

QR CODES

• QR Code on Right 50 characters/ Left 1250

• Each Duty status line 174 characters

• Regional, LTL and Private Fleets can have 30 status changes per day = 18-30 QR CODES for 8 days.

Transfer Jet Obstacles

• Device acquisition cost is approximately $125+

• Uses Near Field Communications – basically the Bump of devices to transfer files

Open Discussion

12