Recently we held a webinar focusing on how changes to hours of service regulations and the ELD mandate will affect the motorcoach industry.
The session featured Lee Payne and Terry Frey from BigRoad and joining them was our good friend Rick Gobbell from Gobbell Transportation Safety.
Rick Gobbell is a fountain of knowledge when it comes to safety rules and regulations and all things US DOT. Before he became a safety consultant, Rick served 32 years working for the U.S. Department of Transportation. During this time he filled a number of roles and has conducted over 10,000 roadside inspections, over a 1,000 Safety Compliance and Hazardous Materials audits, and investigated hundreds of truck crashes.
During the webinar we also heard from Sarah Beth Imperi of Diamond Coach. She kindly took the time to explain how BigRoad was rolled out as part of the company’s safety and compliance standards. She also told us about how easily drivers took to using electronic logs.
Below is a recording of the webinar followed by answers to all the questions we didn’t have time to answer during the webinar. If you would like to see the slides from this webinar you can find them here.
All your questions answered
We ended with a Q&A session and as usually happens we did not have enough time to get to everyone’s questions. We recieved a lot of questions about Electronic Logging Devices and the ELD Mandate during the session. If you’d like more information on this subject, our ebook will explain the proposed changes and help you get a better grip on the terminology being used.
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Q. Can you explain what DataQs is and how to File it?
A: DataQs allows you to request and track a review of Federal and State data issued by FMCSA that you feel you may have received incorrectly. For example you can file concerns about inspections and other information displayed on your records from the FMCSA data. To make a request you can register an account here.
Q. What happens when mobile coverage is poor? Do e-logs work when you are out of cell phone service?
A. Mobile devices tend to have two antennas in them: one for mobile service and one for GPS signal. Even when you are out of mobile coverage, you are still tracking where you are with GPS. When you return to a mobile coverage area, the data is re-synced so you don’t lose any of your information.
Q. Will the ELD mandate require an engine-connected solution? Or will an electronic logbook meet the mandate?
A. An Electronic Logging Device (ELD) will be connected to the engine. ELDs are set to replace current electronic and paper logs but you will also be required to have a backup ready if the ELD fails.
Q. What are the best practices fleets can leverage before the new ELD rules are enforced?
A. BigRoad works on exisiting mobile technology so many of your drivers could switch to electonic logs right away. Then you can look at deploying and testing in-cab tecnology that will be upgradable in ELD. This way you can gradually prepare your drivers for when they have no choice but to use electronic logging devices.
The final ELD specifications are currently due to be published September 30th 2015. They will be mandatory for all fleets using paper logs by September 30, 2017. If, however, you are using a 395.15-compliant AOBRD like DashLink then you will not be required to use an ELD until September 30, 2019.
Q. Does law enforcement understand how to deal with the app or with an ELD?
A. BigRoad makes an ongoing effort to educate enforcement through the CVSA on how to deal with electronic logs, and the BigRoad app specifically.
We offer clear instructions in the form of a printable driver card that you can present during an inspection. There are also instrucions in the app itself to make inspections go as smoothly as possible.
When the ELD mandate is finalized, there may be a period of time where law enforcement is not yet fully aware of the rules, but during that time BigRoad will work closely with customers to help resolve any issues that might arise.
Q. Does ECM Bluetooth communicate directly to the pad?
A. Dashlink is BigRoad’s AOBRD option that uses Bluetooth to communicate data from the vehicle’s diagnostic port to your device. Currently DashLink is only available for Android devices, but an iPhone- and iPad-compatible version is in development.
Q. Will drivers be able to go off duty, and have ability to modify? How are mistakes corrected?
A. An electronic logbook replaces paper logs and like paper the is fully editable by the driver.
With current engine-connected logs like DashLink, drivers can edit everything but drive time which is automatically recorded based on engine use. Once the log is signed, it is only editable by a supervisor who can edit anything.
The proposed ELD rule says that either a driver or supervisor can propose edits to any part of the log except drive time, and that the driver must approve those edits before they are reflected in the final record of duty status. An audit trail must be kept of all edits with annotations indicating why each edit was made.
Q. Can we have a list of the states that ask motor coaches to go into inspections?
A. You should be prepared for an inspection in any state.
Q. Do non-profits (churches) fall under the same guidelines as Motorcoach Company’s?
A. Federal bus regulations for churches can have some differences. This is a great article that covers what the differences are and what you may be exempt from.
Q. Do the rules apply to all commercial vehicles carrying passengers or only to motor coaches? Does it apply to 15 passenger vans?
A. As per § 390.5 Definitions – Commercial motor vehicle means any self-propelled or towed motor vehicle used on a highway in interstate commerce to transport passengers or property when the vehicle—(1) Has a gross vehicle weight rating or gross combination weight rating, or gross vehicle weight or gross combination weight, of 4,536 kg (10,001 pounds) or more, whichever is greater; or (2) Is designed or used to transport more than 8 passengers (including the driver) for compensation; or (3) Is designed or used to transport more than 15 passengers, including the driver, and is not used to transport passengers for compensation.
As per § 395.8: Driver’s record of duty status regulations – Except for a private motor carrier of passengers (nonbusiness), every motor carrier shall require every driver used by the motor carrier to record his/her duty status for each 24 hour period.
So, the answer is, it depends on the number of passengers (including the driver), whether or not you are transporting passengers for compensation, and whether you are driving for a business or not.
Q. Pre Inspect 15 min and Post Inspect 15 min. Does this give you that ability?
A. BigRoad allows you to record any number of vehicle inspections during the day, and during each inspection the driver should log whatever time was taken as on-duty time. The driver can optionally include a note for that on-duty time indicating that an inspection was being performed. There is no requirement in the app to take a specific amount of time or perform a specific number of inspections during any shift.
Q. Do you have a printer option? How much?
A. We do not sell printers directly. However, you can find some of our recommendations for printers here.
Q. How is the data tamperproof?
A. Part of the proposed ELD rule suggests that the ELD is inoperable while vehicle is moving and is tamper-resistant. The ELD is connected to the vehicle’s diagnostic port and when this connection is tampered with, it will record the malfunction in the driver’s log. Also drive time cannot be edited in the log recorded by the ELD.
Q. How does the operator confirm he is receiving data from the correct driver?
A: From the BigRoad web app you can view all your driver and motorcoach locations. You can also see which motorcoaches are equipped with DashLink.
Q. Is there a 100-mile radius option?
A. Yes there is. This option can be selected on a per-log, per-driver, or per-fleet basis, depending on your needs. Please feel free to contact support if you would like more help setting up your hours of service rules.
Q. Does BigRoad notify the company if the driver is reaching the end of their HOS? Does it also warn the driver?
A. Yes BigRoad track all your drivers’ hours of service. Driver’s hours of service can be checked from the web app and any drive, shift, or cycle times that are running low are highlighted accordingly. Drivers using the app are also warned before they run out of time.
Q. How would this system know if a relief driver took over the coach?
A: The new driver would just need to select the coach that they would be driving so that it would show in the admin system that they are now in that coach. The original driver would just switch out of the truck.
Q. If a driver is stopped by DOT or a state trooper, how would they be able to display their logs to the officer.
A: Using BigRoad, logs can be displayed on-screen using an inspection mode, emailed, faxed or printed directly from the mobile device.
Q. Want to be sure it is compliant with the feds rules on being connected to a commercial vehicle computer?
A: You can find more detailed information about how BigRoad complies with regulations here.
Q. If a driver drives more than one motorcoach in a 24 hour period, how do you account for the mileage in each motorcoah on his logs?
A: Each time a driver switches into a different truck they would select switch “truck” from the upper right corner of the app. They will then be required to enter a new start and end mileage for every new coach they drive, or if using DashLink the engine connection would record these values on the log automatically.
Q. What’s the difference between interstate and intrastate rules?
A: Interstate refers to travelling with goods or passengers into or through multiple states, while intrastate is traveling with goods or passengers within a single state. Intrastate rules vary from state to state.
Q. Is there an easier way to keep my log books accurate? I’m looking for a dummy proof system for our drivers since we have a lot of drivers that are not computer friendly?
A. BigRoad is an easy way to keep accurate logs and is a user friendly replacement for paper logs. If you are looking for the most possible accuracy in your drivers’ logs, then our engine-connected option DashLink is probably the right choice.
Q. Will motor coaches have to use the electronic Logging or will it be just for trucks?
A. Both coach and trucks will be required to use electronic logs once the ELD rule has been finalized.
If you have any more questions, please leave us a comment or contact us at 1-888-305-8777