The Time Is Here for ELD’s
The ELD (Electronic Logging Device) mandate for fleets operating in the USA passed on December 18th, 2017, with the new rules now fully in effect. Large national motor carriers were generally supportive of the new rules and therefore fully compliant well in advance of the deadline. Smaller regional and local carriers were less emphatic, with some fighting the mandate until the very end, while others took advantage of the 2 year ease-in period offered by the implementation of less intrusive AORBD’s.
On the same day that the USA rules went into effect, Canadian Transport Minister Marc Garneau gathered with trucking industry leaders to announce that Canadian fleets will follow suit, with an expected mandate in 2020. According to Truck News, Minister Garneau stated, “These new measures not only make trucks and buses safer, but they also have a trickle-down effect of making the roads safer for all Canadians.” While the long awaited news was welcomed by industry groups and larger fleets due to the anticipated benefits of increased efficiency and safety, smaller fleets and owner operators are initially less enthusiastic due to the costs. However, according to the official Canada Gazette Regulatory Impact Analysis Statement regarding the ELD proposed rules, Canadian fleets will also have an additional 1 to 2 years to migrate existing ERD type devices to full ELD specifications.
In Canada, an ERD is the equivalence of the AOBRD in the US -which is an electronic recording device. Modern AOBRD and ERD solutions offer similar functions as full scale ELD’s, but the benefit of being able to edit records. Canadian fleets might want to take notice and learn from the opportunities missed out by many US fleets by purchasing an ERD system now. Doing so will buy a minimum of 3 years to become fully ELD compliant while providing the safety and efficiency gains these solutions provide, while easing the training curve for your drivers.
Regardless of whether your fleet in US or Canadian based, if you haven’t already done so, its time to get serious about implementing a solution. Its not just about becoming compliant. Its about maximizing the safety of your drivers and the public at large, while reducing operating costs and increasing fleet efficiency. Fleets that wait will be at a competitive disadvantage to those that are compliant. According to the Department of Transport cost benefit statement, “The proposed amendments would yield safety benefits by reducing crashes (less property damage and fewer injuries and fatalities); reduced out-of-service detention time of drivers for HOS violations; time savings to both the motor carrier industry (administrative costs saved) and provincial and territorial governments (quicker, more efficient and effective inspections and facility audits); and paper-based daily log savings for motor carriers.”
Considerations Before Using Your Driver’s Phones as ELD’s
Its natural for fleets to consider the visible costs as the key criteria for choosing an ELD system. In that respect, its very tempting for smaller fleets and owner/operators to have the driver use his own phone as part of the compliant ELD solution. In this case, the driver’s phone acts as both the display device (the ELD) and the data modem (to send and receive Hours of Service info to and from the HoS portal) However, there are other considerations that should be made as part of the overall decision. If you think of this from the fleet management solution provider’s perspective, its arguably a bigger win for us if you bring your own devices to the party. We’re not responsible for data consumption that way, nor are we responsible for your hardware and that makes us not really responsible for performance. Perfect! We’ll just collect the monthly and be on our way…
However, purchasing a system that does not over-complicate the lives of your drivers and your dispatcher is important. If it’s not easy to use every single day, drivers will give up on it, blaming the technology for inconsistent records. When making a purchase decision, you need to consider the not-so-visible costs as well. They’re not-so-visible until you’re in the thick of it, so to be fair, we’re giving you the heads up. You might as well go into this with your eyes wide open.
BYOD = Bring Your Own Disaster?
Be particularly careful around the concept of BYOD, which could also stand for “burden your own driver”. While the potential cost savings look appealing, depending on your drivers to use their own devices as an ELD -be it smartphone or tablet, is fraught with risks. Consider that every truck could have a different device and therefore a different mount and a different power cable and different charging system. Consider that every driver may have a different wireless carrier, a different data plan and varying degrees of bill paying acuity. Consider the potential hassles and inconsistencies this creates for both drivers and management. More importantly, consider the potential liabilities and compliance failures this creates for your fleet, that can become costly in loss productivity:
- The mount is a critical part of building a reliable solution. Its important that the device is in a mount at all times while in the vehicle for both road safety purposes and usability purposes. Having the device flopping around on the passenger seat or in the driver’s lap will not only reduce performance but create a potential for safety risks. If the driver removes the device for vehicle inspection purposes, (which he should) it should be protected in the event it is dropped. The mount should accommodate quick removal and replacement of the device. The mount should be placed such that the driver can see the road and the screen at the same time for safety purposes. It also plays an important role in not only looking professional when pulled over for inspections, but ensuring the fully charged and up-to-date device can be easily removed and handed to the inspecting officer for log review.
- When placed into the mount, it should facilitate automatic charging of its battery, rather than depending on manual connection to a cigarette lighter plug, which tends to get dirty and shared with other in-cab devices. Cigarette power cables often lack sufficient amperage capacity to keep a powered on device charged. They often put unnecessary strain on the power connector, which reduces reliability. (especially curly cords which create tension) They are also often ignition sensed, in that they power down with the truck ignition. Purpose-built devices are hard wired to the vehicle power system, ensuring a constant power supply to the integrated battery, so that it is always ready when the device is removed for inspections.
- The BYOD device will more often than not be the driver’s personal phone. This brings a whole raft of potential issues. For example, it will be tempting to use it while driving for other purposes, such as texting and phone calls, music, etc. The regulations specifically call for the HoS app to not allow input while the vehicle is moving. Yet, there is nothing stopping the driver from using his device for other purposes while driving, which is not only a safety and liability risk, but increases the odds the HoS app may become less accurate and reliable. (may lose the ECM connection) What if the driver forgot to pay his cellular bill or exceeded his data plan allotment -and now, while pulled over for inspection, cannot pull the logs for the officer or is missing some information?
Consider factors related to performance and reliability:
- The BYOD device is a consumer product in most cases, with limited durability. It is not designed to be dropped. Yet, these devices, when used as an ELD, will be subject to inadvertent abuse, increasing the likelihood of failure.
- Consumer tablets and smartphones have integrated antennas with questionable low coverage performance. Yet, truckers by their very nature tend to be often in the middle of the rural countryside, in poor cellular coverage areas. Purpose-built devices have external antennas, which are optimized for low signal environments.
- BYOD devices are likely to have smaller displays than purpose-built devices. Consider the effects this may have on a roadside inspection, in terms of the experience of the officer. A satisfied officer is one that sees accurate and complete information, easily and readily at hand.
- Not all BYOD devices will have the same performance. Not all will have the same operating system. Some may have Bluetooth versions that are older and less reliable for connecting to the truck’s ECM.
Now that you have a better sense of what the entire solution consists of, you should be able to make a more accurate cost comparison. We’ll provide some additional context below:
Let’s look at a cost comparison between a typical low-cost BYOD ELD system and a top-level purpose-built ELD system. First, I’m going to suggest that no company should allow the driver to use his phone as the ELD, for all of the reasons listed above. If you want the drivers to be responsible for the display device and data connection, then mandate that the drivers must purchase a Wi-Fi only tablet and a proper mount and power supply. This Wi-Fi only tablet can then be used on a Hot Spot that the driver creates on his personal phone. This solves the following problems:
- All the trucks will appear the same -looking more professional
- The trucks will have proper quick release brackets for the tablets, making it easy to use the tablet for inspections
- The mount will feature a protection sleeve for the tablet to protect it in the event of it being dropped
- The mount will have an integrated power connection to power it from the vehicle to eliminate connection issues
- The tablet will be situated properly in the vehicle so that the driver can see it and the road at once
- All the trucks will have the same hardware for operational consistency -ECM reader, mount, power, tablet
- By using a dedicated tablet, it can be put in kiosk mode so it is dedicated to this purpose only
- The driver will still be able to use his cellphone simultaneously for voice calls or other purposes
Approximate Costs in US Dollars for BYOD Solution
-WiFi Tablet $100.00
-Mount with protective sleeve, vehicle power supply, dash sub-mount and snap in release $200.00
-Vehicle ECM reader with integrated bluetooth and rugged ECM connection cable $150.00
Total hardware cost $450.00
Note: lower cost ECM readers are available with cables for about $50.00 but there are disadvantages
Approximate Costs in US Dollars for Purpose-Built Solution
With a purpose-built ELD device specifically designed to be an ELD, everything is built-in from durability to mounts, power, quick release, external antenna, etc. As it is designed for this purpose, it meets hot temperature and cold temperature specifications for improved reliability as well. Rather than relying on Bluetooth to talk to the truck engine, it plugs in directly to the ECM. Rather than relying on a third party connection to the driver’s phone, it has its own integrated LTE cellular data modem. Its easier to read in bright sunlight. There is no concern about excess data consumption because it doesn’t have any other apps that the driver can use. It also includes a high sensitivity GPS receiver to provide real-time tracking.
-Complete unit $650.00
Not discussed in this article are the monthly costs for HoS service, wireless data or GPS tracking, which will depend on features, volume and other factors. However, they are basically independent from the hardware package chosen.
The moral of this story is simply that, when properly implemented, the difference between a low level and high level solution is not that significant -in this case, about $200.00 per truck. The one-time costs for hardware could be considered as part of the vehicle capital cost, which is amortized over many years. Is it worth risking driver or vehicle downtime for the sake of $200.00 on a $75,000.00 vehicle? Larger organizations are taking this approach because they understand that they must retain their competitive advantage and they must service their clients effectively. Doing so means maintaining optimal fleet efficiency.
Looking at this another way, the total monthly lease cost on a $650.00 item runs just over $20.00 per month on a 3 year lease. Therefore, is it worth $1.00 per day to implement a Gold level solution?
We think so.
Range of Available HoS Solutions
GPS Commander provides a range of solutions to satisfy any US or Canadian fleet:
- AOBRD/ERD System. This is a BYOD (Bring Your Own Device) system that gets you in the door as described above with a fully compliant electronic recording device. The deadline has passed for this solution in the US but is still wide open in Canada. Once you have this system in place, you’ll be grandfathered on the Canadian ELD rules until 2021 or 2022. At that time, the GPS Commander ERD can be converted to a fully certified ELD at no additional cost. The system consists of the following: a) an ECM reader with integrated BlueTooth. This is a small inexpensive device that plugs into the engine via an included cable. It reads the information coming out of the engine and it sends that information to the drivers smartphone or tablet b) the BYOD device is the smartphone or tablet that is provided by the company or driver. It can be an Apple or Android device. This device would require a data plan from the wireless provider -average consumption is 250 MB per month. The tablet or smartphone connects to the ECM reader via a wireless BlueTooth connection. c) Our eTrack Mobile app would be used on the smartphone or tablet. This is a driver friendly app that he can log into to create trips, view or send logs, etc.
- ELD Bronze System. This is basically the same thing as #1 above. The only differences are that the device has to be Android only and the app used is eTrack Certified instead of eTrack Mobile. This is a fully certified ELD compliant solution. Migrating from #1 above to #2 involves no cost, so we can see the benefits of starting with #1 and migrating to #2, simply because the rules for #1 are less extensive and more forgiving.
- ELD Silver Solution. This is the same as #2 essentially, but the black box is more sophisticated in that it includes a full GPS receiver for fleets that also require integrated accurate GPS tracking. It should be noted that both #1 and #2 above can add on app-based GPS tracking for a nominal additional fee. App based GPS uses the GPS signal from the BYOD device (smartphone or tablet) instead of the GPS from the black box included in the silver solution. For that reason, the app-based GPS tracking it is not as accurate or as reliable because it depends on the driver running the eTrack app.
- ELD Gold Solution. This is the industry’s best solution, which includes: a) a ruggedized 7 inch tablet designed for snap-in / snap-out quick removal from the vehicle to conduct the vehicle inspections. b) the cradle that the rugged tablet snaps into contains a high performance GPS receiver, an advanced LTE cellular modem and an advanced ECM module, as well as status lights for compliance and easy trouble-shooting. c) a rugged cable that connects the truck ECM directly to the cradle. d) integrated vehicle mount -what many fleets overlook in their quest to save capital dollars is the high cost of a quality mount system. e) a complete fused vehicle wiring cable to power the device.