The ELD Rule is in effect and being fully enforced as of April 1, 2018.
However, AOBRDs (Automatic On-Board Recording Devices) are grandfathered in under 49 CFR 395.15(a), and weren’t affected by the December 2017 deadline requiring anyone using paper logs to start using ELDs.
AOBRDs can be used instead of ELDs until December 16, 2019, according to the FMCSA. After that, everyone who tracks Hours of Service (HOS) will be required to have an ELD installed and be trained on how to use it.
If your company is still using AOBRDs in the ELD age, here’s what you need to do to stay compliant until you make the switch.
Using AOBRDs Instead of ELDs
There is still a lot of confusion surrounding ELD regulations and exemptions. The FMCSA has been regularly putting out policy updates and deadline extensions too, which has added to the all the uncertainty.
For instance, the FMCSA recently revised its guidelines to allow fleets that used AOBRDs prior to the December 2017 deadline to continue installing them in vehicles that are added to the fleet. Before the change, you would have had to install ELDs into vehicles that expanded your fleet’s size, even if the rest of your fleet was still using AOBRDs. Just remember that the newly installed hardware must be ELD-capable, and you will need to upgrade all AOBRDs to ELDs by December 2019, regardless of when the AOBRDs were installed.
Working with the DOT while using AOBRDs
DOT officials tell us that while the FMCSA is still working out the rules surrounding ELDs, nothing has changed when it comes to AOBRD regulations.
Drivers still need to follow the regulations laid out by the 1988 AOBRD Rule (49 CFR 395.15) and have:
- An AOBRD direction card in the cab that outlines how to use the device.
- At least seven days’ worth of blank paper logs with them in case the AOBRD isn’t working.
AOBRDs don’t have to meet the same requirements as ELDs, but there will still be consequences if drivers don’t have what they need for DOT inspections regardless of what device they’re using.
Avoid Confusion with Proper Training
The biggest problem DOT officials see is that drivers don’t know if they’re using an ELD or an AOBRD. The common misconception is that because an AOBRD is an electronic device that tracks HOS, it’s an Electronic Logging Device.
It’s critical that you educate your drivers about the device they’re using.
Drivers need to:
- Know if they have an ELD or an AOBRD installed in their vehicle.
- Be trained on how to use the device and pull up HOS information during inspections.
- Have all the supporting documents required for the device with them.
With hundreds of different types of ELDs and AOBRDs on the market, there are simply too many devices for inspectors to know how to use all of them, so your drivers need to be properly trained on how to use the device they have.
AOBRDs Must Be Phased Out
While there have been some policy changes, the fact is that everyone who tracks HOS will have to use ELDs by December 16, 2019.
We’re here to help you make the switch. Schedule a demo with us today to see how our solutions help keep your business running smoothly while keeping you compliant with FMCSA regulations.