White paper Electronic On-Board Recorders: Benefits Beyond Compliance
The Federal Motor Carrier Safety Administration (FMCSA) has proposed new rules for electronic on-board recorder (EOBR) use. The rules will be mandated for a small fraction of the transportation industry but are encouraged for the masses, promoting voluntary use of electronic on-board recorders. The FMCSA proposes to provide some incentives for companies that voluntarily adopt the technology, but at this time the specifics of these incentives are unclear. FMCSA Administrator John H. Hill stated during a press conference, The goal is to get more trucks and buses using innovative safety technologies like on-board recorders that will improve safety on our nation s roads. Organized labor is receptive to this long awaited ruling as it is proposed, with the Teamsters Union stating, When used for its designed purpose, on-board recorders can be a valuable tool to prevent companies from pushing their drivers past advisable hours of service. If this rule helps to stop hours of service (HOS) violations and improve safety on our highways, we all will benefit from its implementation. Above and beyond the safety issue, ATA President Bill Graves has endorsed the rule for the trucking industry by stating, Rather than limit the productivity of the trucking industry as some fear, eventual widespread adoption of electronic on-board recorders actually could improve the management of trucking companies. This paper will examine the FMCSA s proposal, its effects on driver safety and the operational and financial benefits of investing in EOBR technology. Defining EOBRs In its most basic form, an electronic on-board recorder is a data logging system. Specifically, the proposal requires EOBRs to record basic information needed to track a driver s duty status, including: identity of the driver, duty status, date, time and location of the commercial vehicle, and distance traveled. It would also add a new requirement to use Global Positioning System (GPS) technology or other location tracking systems to automatically identify the location of the vehicle, which further reduces the likelihood of falsification of HOS information. HOS regulations are designed to ensure that driver fatigue does not impair a driver s ability to operate a vehicle safely. The goal of the EOBR regulations is to provide a foundation for development of EOBR solutions designed and used to enable motor carriers to track their drivers on-duty driving hours accurately, thus preventing regulatory violations or excessive driver fatigue. In addition to the safety benefits, EOBRs allow trucking companies a new level of control over vehicle scheduling and driver operations. The proposed rule allows users open selection of EOBR core technology, only specifying that the equipment must meet standards of recording and displaying the data -- either by hardwire transmission through a device that is tethered to the vehicle or with a device that can transmit the data wirelessly to display for the compliance officer at the roadside. Since 1988 the FMCSA has stated that any automatic on-board recording device (AOBRD) and its support systems must be: Certified by the manufacturer that they have been sufficiently tested to meet the requirements of the FMCSA under the conditions in which they would be used Designed to permit duty status to be updated only when the vehicle is at rest, unless the driver is registering the crossing of a state boundary Resistant to tampering to the maximum extent practicable Able to provide a visual or audible warning to the driver if it ceases to function, and any sensor failures and edited data must be identified in the driver s record of duty status (RODS) Maintained and recalibrated according to the manufacturer s specifications Additionally, drivers must be adequately trained in the proper operation of the device; and the motor carrier must maintain a second (backup) copy of electronic HOS files in a separate location. Automatic On-Board Recording + Wireless Technology = Real-time Reporting Although automatic on board recorders are not new, the technology to allow on-board recorders to communicate data wirelessly between the commercial motor vehicle (CMV) and the motor carrier s base of operations on a widespread commercial basis is a fairly recent development. Today s technologies allow for real-time transmission of a vehicle s location and other operational information. The FMCSA calls these current-generation recording devices EOBRs and proposes the following requirements: Ability to identify the individual driver Tamper resistance Ability to produce records for audit Ability of roadside enforcement personnel to access the HOS information quickly and easily Level of protection afforded other personal, operational, or proprietary information Cost Driver acceptability While many of the proposed requirements, such as that for tamper resistance, parallel the requirements for AOBRDs, others would go beyond the AOBRD requirements based on the expectation that the EOBR will have a high degree of reliability. The EOBR would not need to be integrally synchronized to the engine or other vehicle equipment but must have GPS or other location tracking systems that record location of the CMV at least once a minute. EOBRs can still use sources internal to the vehicle to record distance traveled and time. They must perform a power-on selftest on demand and must also warn the driver if the device ceases to function. Maintenance, recalibration, and self-certification requirements would be similar to those for AOBRDs. The proposed ruling also stipulates that EOBRs must produce parallel data streams of original and modified entries to provide an audit trail for data. FMCSA proposes several options for
information transfer and display; EOBRs would need to produce the driver s HOS chart in a graph-grid form similar to the drivers RODS. While the FMCSA states that data transfer could be either hardwired or wireless, the day-to-day reality is that in business, time is of the essence -- users need the real time data availability afforded by wireless technology. Real time data transfers allow companies to identify potential upcoming violations and make it possible to predict capacity and optimize business opportunities. Under the proposed ruling, who must install EOBRs? While the FMCSA has authority to adopt an industry-wide requirement that all motor carriers subject to HOS requirements install and use EOBR-based systems. FMCSA proposes to require EOBR use for a very small fraction of the carriers. The current proposal requires onlyto those carriers found to have HOS violation rates of 10 percent or more of the records reviewed during each of two compliance reviews (CRs), when the two reviews are conducted within a 2-year period. This will immediately affect 930 carriers and 17,500 drivers who have been in violation. These carriers would be required to install EOBRs in all of their CMVs and use the devices for HOS recordkeeping for two years. This approach focuses on carriers with a history of serious HOS violations. My company is not an HOS violator. Why should we install EOBRs? By exploiting the power of EOBR technology, a motor carrier can improve its safety record and greatly optimize the scheduling and routing of vehicles and drivers, as well as improve asset management and customer service. Improved Safety In its report Top Ten Management Issues (Report Number PT- 2001-017, January 18, 2001), the Department of Transportation (DOT) office of the Inspector General responded to the public s request for EOBRs onboard trucks, stating, Driver HOS violations and falsified driver logs continue to pose significant safety concerns. Research has shown that fatigue is a major factor in commercial vehicle crashes. During roadside safety inspections, the most frequent violation cited for removing a driver from operation is exceeding allowed hours of service. Use of electronic recorders and other technologies to manage the HOS requirements has significant safety value. The American Trucking Association (ATA) states, We are pleased that DOT has taken another solid step toward ensuring future gains in improved highway safety. We support this incentivebased approach to the use of electronic on-board recorders. Technology can play a significant role in enhancing road safety and help to ensure the reliability of commercial vehicle operation. Although use of EOBRs is relatively new, several companies and vendors have already publicly touted their benefits in improving safety: Werner Enterprises, which has piloted a GPS technology approach for HOS monitoring, noted evidence of safety improvements as measured by driver out-of-service rates related to HOS compliance. Its driver out-of-service rate is 1.2 percent, far lower than the national average of 6.8 percent United Natural Foods noted both compliance and operational improvements since it began using EOBRs in the CMVs based at some of its facilities Siemens asserted that European motor carriers experience with HOS recording has led not only to acceptance of conventional tachographs but also to improved designs for reduced possibilities of cheating the system. According to Tripmaster, its customers drivers saved 15 to 30 minutes per day and believed the safety and compliance assurance benefits justified the EOBRs cost. Operational Benefits Transportation companies are intimately familiar with the fact that the fixed costs on a truck, trailer and employee will continue to accumulate whether or not the truck and driver are productive. One of the best ways for a fleet to cover costs and build profits is to keep trucks rolling, using every available hour of drive time as efficiently as possible. Conversely, trucks sitting idle due to lack of driver availability, maintenance or stopped at a check point for a log violation are some of the most costly problems a transportation company can face. Historically, drivers hours of service have not been viewed as an asset to be proactively managed and optimized, but the proposed rules coupled with an EOBR solution change the paradigm. Without EOBRs, companies are in the business of selling transportation getting paid to move product from location A to location B, and the driver is in control of his time. If a driver mistakenly understates his available driving time, his miscalculation directly hampers the company s ability to make money. Miscalculations resulting in an overestimate of the driver s available hours put both the driver and the company in legal and civil peril. Now, with the help of EOBRs and wireless technology, transportation and logistics companies effectively sell blocks of transportation time and manage all of their assets to optimize revenue opportunities. In this model, drivers hours become a finite commodity that need to be managed, controlled and optimized, and up-to-the-minute data allows trucking companies to make operational decisions based on these hours dynamically and in real time -- not after the fact when the log book is turned in. Improved Customer Service In the customers eyes, a late shipment is a late shipment, no matter if the driver belatedly decided he miscalculated his logs and cannot proceed -- or if he is shut down by the DOT to wait out a violation. Unfortunately, these delays are rarely convenient to the company or easy to resolve, and frequently occur on
weekends or during long holidays when replacement drivers are non-existent. These interruptions also often occur in places where it is inconvenient to replace the power under the load, so recovery costs well outweigh any potential for profit expected from the load, driver or truck. Customer service improves dramatically when a trucking company s management has accurate and up-to-date information on driver availability. Companies that have implemented EOBRs have found accuracy of access to the driver hours available to increase dramatically. EOBR s enable operations to run at maximum available capacity, allowing customer service teams to work on maximizing revenue and profits. Costs of Owning EOBRs The cost benefits of EOBR technology should be evaluated in light of the broader, general operational benefits incurred when the technology interoperates with the company s overall solution. EOBR functionality many times may not require the purchase of a new, standalone system, but should be implemented as an expansion to the operational system already in place. Companies should look for system providers that offer applications for real-time HOS monitoring that build upon the time and locationtracking functions included in the providers existing hardware and software products. Additionally, an EOBR purchase should be justified through a documented cost of ownership analysis. No true ROI analysis is accurate without an understanding of upfront costs as well as a long-term cost study. Consider implementing a ruggedized EOBR solution to maximize ROI; equipment that is built to withstand use on the road or in an industrial environment will last longer and perform more reliably than devices built for use by the average office-bound consumer. In calculating the cost of owning EOBRs, also consider the cost of staying with pen and paper logs, as these antiquated methods can leave carriers at the mercy of the driver to calculate and report hours accurately. When businesses view driver hours as a finite commodity an operational asset to be managed it is clear that without the real time reporting afforded by EOBRs, the drivers are managing the trucking business. EOBR technology also adds efficiency to transportation back office tasks, particularly for auditing purposes. While it is physically impossible for most companies to audit all driver logs, an EOBR system allows companies to audit by electronic exception where management is flagged in the instance of something out of the ordinary, such as an overage of logged hours. This system of exception-based reporting means office employees can move straight to managing problems and no longer spend all their time looking through day after day of logs, searching for exceptions to company rules. What Incentives Are Provided by the FMCSA? The FMCSA encourages all motor carriers to install and use EOBRs. To expand use of the devices among the more than 650,000 motor carriers in the U.S., the proposed incentives for voluntary installation include the following: Using an examination of a random sample of drivers RODS as part of a company compliance review. If a carrier voluntarily using EOBRs is found to have HOS violations in 10 percent or more of the records reviewed in the initial analysis, FMCSA would conduct a second review of a random sample made up of records of duty status for the carrier s other drivers, and use the results of the second sample in determining the carrier s safety rating. If the initial sample does not disclose a violation rate of 10 percent or greater, then any violations found would not affect the carrier s safety rating. Partial relief from HOS supporting documents requirements provided certain conditions are satisfied. EOBRs meeting the proposed requirements produce regular time and CMV location position histories sufficient to verify adequately a driver s onduty driving activities, so carriers voluntarily maintaining the time and location data produced by such devices would need to maintain only those additional supporting documents as are necessary to verify on duty not-driving activities and off-duty status. It should be noted that these are only proposed incentives which must be clarified by the FMCSA. Purchase decisions should not be made based on these incentives, but on the above listed benefits of expanding an existing solution by adding EOBR technology. Can the information collected by EOBRs be used against my company in other legal matters? Some carriers and drivers have expressed reluctance to use EOBRs because of other uses that could be made of the data the devices produce. Drivers object to the devices as an invasion of privacy and as a potential source of information that could be used against them for non-hos-related issues, such as speeding, while carriers are concerned that the data could be used in post-crash litigation. Both have asked that that the FMCSA limit access to the data for the purpose of HOS compliance-related enforcement. In response to these concerns, the proposed rule FMCSA stipulates the following: The HOS information recorded on EOBRs would be accessible to Federal and State enforcement personnel only when compliance assurance activities are conducted at the facilities of motor carriers subject to the RODS requirement or when the CMVs of those carriers are stopped for purposes of conducting roadside inspections. Motor carriers would not be required to upload this information into any Federal or State information system accessible either to the public or to motor carrier safety enforcement agencies. The notice of proposed rule making (NPRM) would neither enlarge the scope of personally identifiable information collected nor change the sharing of that information (pg. 170). It is FMCSA s intent that the data recorded on EOBRs and support systems, and the information derived from those data, relate solely to compliance with the HOS regulations. One reason for proposing to eliminate the requirement for recording road speed is that 392.6, schedules to conform with speed limits, addresses road speed in a broader safety context. FMCSA reserves the right to adopt enforcement policies
and practices to take advantage of continuing technological advances. Any future proposals to use EOBRs or other electronic monitoring for enforcement, compliance, or other Agency purposes will be evaluated on their merits (pg. 119). While the legal ramifications of EOBR reporting are not yet clearly defined, there is some concern that records collected by EOBRs can be subpoenaed for legal proceedings outside of HOS compliance enforcement. In light of the new technologies available and the liabilities involved in incorrect reporting, companies should consider that they will often fare better in legal arbitration when they are able to show a legacy of a proactive stance in managing hours. Summary The trucking industry has agreed that EOBRs are the next step to ensuring road safety, and industry-wide adoption of the technology is being encouraged by legislators. But before investing in the technology, trucking companies must analyze the costs and benefits of the technology and determine if it makes sense for their business. One of the best ways to optimize profitability is to increase visibility to all of the factors that can impact your ability to run efficient operations. And since drivers hours are now one of the most prevalent gating items to productivity, having the most current and accurate data available in real time is the best way to improve operational efficiency. EOBRs put the control of accurate reporting and the time available from their drivers in the hands of the company. About Intermec Compliance with the proposed regulations and real-time HOS data transfer can be accomplished with the Intermec CN3 as a standalone hardware platform or in conjunction with existing incab devices. Using a ruggedized mobile handheld computer such as the CN3 allows the driver to present his EOBR results quickly and safely by simply handing the device out the truck door to the officer. For more information about the CN3 and other Intermec products, visit www.intermec.com or call 800-347-2636. Intermec Inc. (NYSE:IN) develops, manufactures and integrates technologies that identify, track and manage supply chain assets. Core technologies include RFID, mobile computing and data collection systems, bar code printers and label media. The company s products and services are used by customers in many industries worldwide to improve the productivity, quality and responsiveness of business operations.
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