ELD transition: Doing the installations requires planning
Transportation Safety Management Today
In this series of articles, we are looking at the steps necessary to successfully transition a fleet from paper logs to electronic logs. This article will look at the planning process involved in installing the devices in all of the fleet’s power units that need one.
In past articles we have discussed:
Improving driver and supervisor training on hours of service to make sure misunderstandings and misconceptions when it comes to the limits and rules are eliminated.
Improving auditing to get drivers into the habit of “running legal.”
Understanding the different “types” of compliant electronic logs.
Selecting a device that fits your operation.
Developing your policies and procedures related to electronic logs.
Training drivers on using the electronic logs.
Training supervisors on how to do their job in an electronic logging environment.
As we have worked our way through the steps, we have been discussing the upcoming deadline as well. Here are the key dates to keep in mind:
December 18, 2017: Unless one of the exceptions applies, the driver will need to be using either an automatic onboard recording device (an AOBRD, which is what the current devices being sold and installed are) or an electronic logging device (an ELD, which is the next-generation electronic logging system).
December 18, 2017: All devices placed into service must be an ELD that is listed on the “ELD Registry,” which is managed by the Federal Motor Carrier Safety Administration (FMCSA).
December 16, 2019: AOBRDs placed into service before December 18, 2017, must be updated to meet the ELD performance standards or be replaced with an ELD (if not updateable).
This step will require the assistance of your maintenance personnel. They will need to be provided the installation guidelines that the electronic log provider has developed for the system you have selected. This provides general guidance for your maintenance personnel when they are developing the “standard process” for doing the physical installation. Based on this, and a little trial and error, your maintenance people should be able to develop a standard installation process and determine the shop hours necessary for each installation.
When determining the mounting location, several factors need to be considered. First, “portable” devices that work as ELDs (ones that are not built into the dash) must be mounted in a fixed location within the driver’s field of view and reach. However, as well as this regulatory requirement, there are other considerations. You do not want to mount the device in a location that:
Restricts the driver’s ability to use a vehicle switch or control
Causes the driver to continually come into unplanned contact with it (such as bumping into it with his/her hand, knee, or foot)
Allows the device to become an impact hazard in the event of a crash
Blocks the drivers view of any of the gauges
Interferes with the operation of an airbag
Obstructs the driver’s view of the road or signs
Leads to damage (such as drilling into the dash where there is a wire bundle running right behind it)
You are also going to want all wiring hidden and protected. Any wire splicing that needs to be done should be done in accordance with sound shop practices, not by “stripping the wires and taping them together.”
There is a timing issue here that you need to be aware of. You do not want to begin serious planning for the installations until you have selected a system. This is due to each system having its own unique mounting requirements. Some will need space on the dash, others will need a mount installed under the dash, and others will need a mount installed separate from the dash. There is also the issue of connecting and installing the necessary wiring. Much like the mounting, this will vary from system to system.
Once there is a standard installation procedure, the next step is rolling it out. If the company is using a phased implementation, this means training a few technicians that have not been involved in developing the standard installation process and having them install the system in the first few units. This will give you an idea of how long an “average” technician needs to install the system. It also allows you to discover the problems and challenges your average technicians will be dealing with, and allow you to devise solutions to them.
After the pilot group is done, make sure to update your installation standards and the training. If you have not done so yet, this would also be the time to document everything (standards and training). This way, it can be used as a model to train the remaining technicians and be “exported” to other facilities.
Part of routine maintenance, special work, or something else?
The next question that needs to be addressed before the wider rollout starts is whether you want to do the installation as part of a scheduled maintenance, on a “based on request” approach, or as “special work.” Installing the devices during scheduled maintenance will mean adding the appropriate amount of time to the maintenance work, but it will make for a controlled flow through the maintenance facilities.
“Based on request” involves installing the system into specific units based on driver request or management determining which specific drivers are to get the devices first. This is another controlled method, but it will require special scheduling in the maintenance facility, since the requested power units will not always be due for scheduled maintenance when the system needs to be installed.
Using one of the controlled methods means that parts inventory can be managed. As the stock of necessary parts dwindles, the parts can be reordered through the normal process. However, this might lead to it taking several months to get the system into all power units. It will also lead to “stragglers.” These will be drivers that are deliberately avoiding a maintenance facility to delay the system being installed.
The other general method involves getting the systems installed in all power units that were not part of the test group as quickly as possible. This would involve getting all of the power units into a maintenance facility as soon as possible once the installation date arrives. To accomplish this, the maintenance facilities would need to be prepared to handle the “surge” and have all of the necessary parts stocked in advance. This option will involve more planning as man-hours and inventory will need to be preplaced to make it work smoothly.
A variation of this at carriers that have multiple locations is to install the systems into all units at one facility, and then move onto the next. This allows the company to “flex” manpower and inventory to the needed location to deal with the surge.
Consider outside help
If either method (controlled or all at once) will tax your maintenance facilities beyond capacity, consider using an outside vendor to handle some, or even all, of your installations. There are companies who specialize in the installation of electronic logging systems. Your e-log provider in many cases will have a vendor (or several) that they work with on a regular basis. You could also hire an outside maintenance facility you are familiar with to install the devices, using your standard installation process.
Start thinking about it soon
A few of the issues we discussed, such as developing a standard installation process and training technicians on the process, need to wait until you have selected a system. However, other issues can be tackled well before the first device is ordered, such as the desired pace of the rollout (controlled or all at once) and the use of outside maintenance facilities.
By the way, if you use an outside maintenance company or lease your power units, most of the process will be the same. The key difference is that the people you will be talking with about these issues do not work for you directly.
This article was featured in the newsletter. Transportation Safety Management Today
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