Transition training — training drivers on electronic logs
By: Thomas Bray
Publication: Transport Safety Pro Advisor
Date Posted: 03/15/2017
In this series of articles, we have been looking at making the transition from paper logs to electronic logs. The deadline to have most drivers switched to an electronic log is December 18, 2017. As of that date, unless one of the exceptions apply, 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).
After 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). AOBRDs that were installed before December 18, 2017, can continue to operate as AOBRDs until December 16, 2019, at which time they must be updated to meet the ELD performance standards (or be replaced with an ELD if not updateable).
As far as making the transition, 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.
In this article, we will look at the next important step, and that is training drivers on using the electronic logs.
The timing of the training is important. You do not want to waste time training the drivers until you have:
- Selected a system, including all “options” that you want,
- Developed your policies and procedures related to the electronic logs,
- Developed a thorough understanding of the device and system,
- Trained the driver’s supervisor on the “back-office” functions and solutions to common problems, and
- Prepared to install and use the devices.
Until these steps are completed, there is a chance that there could be significant changes. These changes would then mean having to retrain the drivers.
Common sense will tell you that it is important to do the training before the electronic system is rolled out to a driver. However, you do not want do the training so far in advance that the driver forgets the majority of the training before actually using the device.
The training needs to include training on the device and the system. Areas that need to be trained on include:
- Using the electronic logs during normal operation.
- Setting the device up for a roadside inspection and how to present all of the required information during a roadside inspection.
- Requesting and/or making a correction.
One key with this training is that it must be thorough. You want to train the driver to the point that he/she cannot get it wrong, no matter what the circumstances might be.
The driver will need to know when and how to log in, log out, change non-driving statuses, enter shipping document numbers and “other information,” enter comments whenever an exception is used or a problem is encountered, certify and submit completed records, and use the display to display available hours.
The driver will need to know how to present the required records to the officer during a roadside inspection, and what other materials are required, based on the type of electronic log the driver is using. Here are the requirements:
- AOBRD: The driver must be able to display today’s log, and the logs for the previous seven days. If the officer wants a “hardcopy” of the logs, he/she is to request it from the company. The company then has 48 hours to provide them.
- ELD: The driver must be able to display or print today’s log, and the logs for the previous seven days (the device must only do one, not both). If the officer wants a “hardcopy” of the logs, he/she will tell the driver to “send” the logs to him/her. This will involve using either a telemetric transfer, using a website or email, or a “local transfer” using USB or Bluetooth (the device has to be able to do either telemetric or local, not both). It is the driver’s responsibility to initiate the transfer.
- If using an AOBRD, the driver must also have an “instruction sheet” explaining how to display the required records and enough blank logs to complete the current trip. If using an ELD, the driver must have a user’s guide for the device, an instruction sheet on how to initiate the transfer of the records to an officer, a card explaining the malfunction codes the device uses, and at least eight blank logs.
As you can see, there will be a considerable amount of training involved in this area. There will also be retraining necessary in the future, as most devices going into service at this time are AOBRDs. If the driver was trained on the roadside inspection process when using an AOBRD, the driver will need to be retrained when the device is upgraded to an ELD (or replaced with an ELD).
Requesting or making changes
As well as training the drivers on how to make or request changes, the training on requesting/making changes needs to include clarifying what an acceptable change is. Drivers (and supervisors) need to understand the difference between a correctable error and creating a false record. A correctable error is a driver forgetting to log off duty at the end of the day or forgetting to log in at the start of the day. Going back and making the change at the correct time would be acceptable.
Examples of changes that would create a false record would be changing the driver’s start time to avoid a 14-hour violation, creating a 10-hour break where one did not exist, or changing when a driver started driving to avoid an 8-hour violation. These changes cannot be allowed.
If you did a good job of training on the basics of hours of service (part of “step one”), this portion of the training should be fairly straightforward as the drivers (and supervisors) will have a good understanding of what constitutes falsification in general.
Finally, you will want to train the drivers on the regulations related to electronic logging. This includes training on:
- What “type” of system the driver is using — an AOBRD regulated under §395.15 or an ELD regulated under the new ELD technical standards in Subpart B to Part 395 and the associated appendix.
- What to do if the device fails — the driver must immediately reconstruct today and the previous seven days using whatever records the system can provide and the blank logs. If using an ELD, the driver must also immediately notify the company the device has failed (within 24 hours is the requirement).
- Who is responsible for displaying or providing the required information during a roadside — the driver!
As you can see, there is a lot of ground to cover when it comes to training the fleet when switching from paper to electronic logs, and training is only one component of the change. The best advice is start the transition early. When you consider everything that needs to be done to get the company transitioned and operating effectively and efficiently on electronic logs, nine months suddenly does not sound like much time.
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