OTA Issue 4 2016

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16 Oregon Trucking Associations, Inc. Oregon Truck Dispatch
FEATURE
T he trucking industry is fraught with
acronyms. Have you ever felt like you’ve
needed a secret decoder ring in order to
communicate? APU, AVI, CDLIS, CMV, CSA,
ECM, EDI, IRP, IFTA, HHG, ITS, LCV, ICC, NHS,
LTL and so on and so forth… I’m not going to
tackle the complete list today, but I will attempt to
demystify a couple acronyms of current interest.
The term “AOBRD” (Automatic On-board
Recording Device), means an electric, electronic,
electromechanical, or mechanical device capable
of recording driver’s duty status information
accurately and automatically as required by
§395.15, and has been defined as such since the
1980’s. The device must be integrally synchronized
with specific operations of the commercial motor
vehicle in which it is installed. At a minimum, the
device must record engine use, road speed, miles
driven, the date, and time of day.
The term “EOBR” (Electronic On-board Recorder),
has been used in the Transportation industry for
over a decade and refers to a software driven
device that records an electronic log. The FMCSA
used the EOBR term in the 2010 Rule – 395.16,
which was vacated in August of 2011.
The term “ELD” (Electronic Logging Device), is
the most current and refers to technology that
automatically records a driver’s driving time and
other aspects of the hours-of-service (HOS)
records. The intent is to achieve more accurate
HOS recordkeeping. An ELD monitors a vehicle’s
engine to capture data on whether the engine is
running, whether the vehicle is moving, miles
driven, and duration of engine operation (engine
hours). ELD manufacturers must certify via the
FMCSA ELD website that their ELD(s) meet the
technical standards in the ELD rule.1
On December 10, 2015, FMCSA announced its
final rule requiring the adoption and use of
electronic logging devices (ELDs) by all drivers
currently required to complete paper records of
duty status (logs). In the July 2012 highway
reauthorization law known as MAP-21, Congress
required that FMCSA mandate the use of ELDs.
The rule requires fleets and drivers required to
complete paper logs to adopt and use compliant
ELDs by December 2017, unless they are currently
using automatic on-board recording devices that
are grandfathered. FMCSA will allow fleets and
drivers using “ELD-like” devices meeting the
current standards for Automatic On-Board
Recording Devices (AOBRDs—see 49 CFR 395.15)
to continue to use such devices until December
2019, two years after the final deadline for
adoption of ELDs. If these devices can be modified
to meet the ELD specifications they may continue
to be used after December 2019. Modification of
an AOBRD would most likely amount to a
software upgrade.
Manufacturers are required to test and certify to
FMCSA that their devices meet the new standards.
FMCSA has created a public registry of devices
that have been self-certified by their manufacturer
to be compliant with the FMCSA rule. See the
registry of self-certified ELDs at
2
An electronic logging device (ELD) is not the same
as an automatic onboard recording device. The
technical specifications are different.
Manufacturers will need to notify owners of
existing AOBRDs if their devices are capable of
being updated to meet ELD requirement through
software updates. These updated devices must also
be certified and registered by the manufacturers
on the FMCSA ELD registration page.
The final rule allows limited exceptions to the ELD
mandate, including: drivers who use paper logs for
not more than eight days during any 30 day period;
or, drivers who conduct driveaway-towaway
operations, where the vehicle is the product being
1. ATA Summary of FMCSA’s
Final Rule To Mandate Electronic Logging Devices December 2015
2.
AOBRD:
Automatic
On-board Recording
Device
EOBR:
Electronic On-board
Recorder
ELD:
Electronic Logging
Device
or What
You Always Wanted to Know About AOBRDS,
EOBRS, and ELDS and Were Afraid to Ask!
By Gregg DalPonte, OTA Director of Regulatory Compliance
A L P H B ET A S OU P