Information Regarding ELD s

Transcription

1 Electronic Logging Devices (ELD) A Different Twist Douglas Glanert, Senior Special Agent Motor Fuel Use Tax Enforcement Criminal Investigation Division Illinois Department of Revenue & Jeff Hood, Director Motor Carrier Services Indiana Department of Revenue Information Regarding ELD s U.S Department of Transportation (USDOT) Federal Motor Carrier Safety Administration (FMCSA) The ELD Rule 49 CFR Parts 385, 386, 390, and 395 Electronic Logging Devices and Hours of Service Supporting Documents Department of Transportation (DOT) Federal Motor Carrier Safety Administration (FMCSA) [Docket No. FMCSA ] 1

2 Who is Required to Comply In general, the rule applies to interstate drivers of CMVs (as defined in 49 CFR 390.5) who are currently required to keep Records of Duty Status (RODS). Federal Motor Carrier Safety Administration Why ELD s The ELD Rule was put into place to increase compliance with the Hours of Service (HOS). Implementation Compliance Phases Three (3) Phase Implementation 1. Awareness and Transition Phase -Feb. 16, 2016 to Dec. 18, Phased-in Compliance Phase -Dec. 18, 2017 to Dec. 16, Full Compliance Phase -December 16,

3 Motor Carrier Responsibility The Company Under the ELD Rule, the Motor Carrier is required to monitor the ELD for proper function. Under the old AOBRD Rule, Motor Carriers were only required to monitor for Sensor Faults. Roadside Enforcement Automatically Recorded Data Date Time CMV Geographic Location Information Engine Hours Vehicle Miles Drivers or Authenticated User Identification Vehicle Identification Motor Carrier Identification 3

4 Manually Entered Information Driver Support Personnel (including but not limited to Mechanic, Dispatch, and Support Staff) Any notation of Service Hours Location Description (When Prompted) Unit Number Trailer Number Shipping Information as Required by the ELD Roadside Inspections & Investigative Techniques During the transition & awareness phases the ELD must have a printout or display. Final Implication of the ELD Rule states that the ELD most have printer or display capability as a backup. The ELD will have and/or Bluetooth capability or another form of telematics. ELD Details The ELD will display a Detail Log Data much like a spreadsheet. 4

5 Roadside Investigations Supporting Documentation Under the ELD Rule, Supporting Documentation (i.e. Manifest) is still required. The supporting document may be kept electronically as well. Safety Safety is paramount. Always remember your basic safety measures while conducting roadside investigations. Will ELD s Impact IRP and IFTA? Law Enforcement and Managers Meeting Salt Lake City, Utah September 27, 2017 Jeff Hood, Director Motor Carrier Services Indiana Department of Revenue 5

6 Jurisdictional Responsibility How many managers are responsible for both IFTA and IRP? How many managers are responsible for IFTA only? How many managers are responsible for IRP only? IFTA and IRP Audits How many audits were performed on IFTA licensees in 2016? How many audits were performed on IRP registrants in 2016? What percentage of IRP registrants were found to have inadequate records during an audit in 2016? 6

7 Audit Requirements For records produced wholly or partly by a vehicle-tracking system, including a system based on a global positioning system (GPS): the original GPS or other location data for the vehicle to which the Records pertain the date and time of each GPS or other system reading Audit Requirements the location of each GPS or other system reading the beginning and ending reading from the odometer, hubodometer, engine control module (ECM), or any similar device for the period to which the records pertain Audit Requirements the calculated distance between each GPS or other system reading the route of the vehicle s travel the total distance traveled by the vehicle 7

8 Audit Requirements the distance traveled in each jurisdiction the vehicle identification number or vehicle unit number ELD Requirements A GPS reading every hour while in motion A GPS reading on change of duty status and engine on and off Eight qualifying documents ELD Requirements Personal Conveyance. Accuracy drops to within 10 miles of actual location Maintain in electronic or paper format Maintain records for 6 months 8

9 Disconnect ELD s track the driver. IFTA and IRP are concerned with the truck Systems are self-certified by their vendors as to meeting federal ELD requirements ONLY ELD s 6 months IFTA records 4 years and IRP records up to 6 years There are exceptions Disconnect Systems are not required to record specific jurisdiction distance 60 minute intervals while in motion Disconnect At change of duty status latitudes and longitudes must be converted into geolocation information 9

10 So now what? Educate your accounts at every opportunity Warn them of financial ramifications as a result of an audit Should IFTA and IRP certify systems as compliant? Questions? If you prefer to text your question, text it to: (703)