ELD violations are now taken into account in a carrier’s Compliance, Safety, Accountability (CSA) score. This change is in effect as of April 1, 2018, which was also the ELD enforcement deadline. The Federal Motor Carrier Safety Administration (FMCSA) has released an updated CSA score matrix that includes CSA points for ELD-related violations.
While many violations are similar in scope to simple form and manner violations only carrying one point, there are some that are more heavily weighted.
In this post, we review some of the higher weighed ELD-related items and discuss how to help drivers stay compliant.
1. Operating with a device that is not registered with FMCSA.
Section 395.22A
Violation Severity Weight: 5
To avoid this violation: Ensure the device you choose is listed on the FMCSA’s Registered list of ELDs. Appearing on this list is the only evidence required as to the status of the ELD. The FMCSA does not issue certificates or documentation to an ELD vendor. New England Mobile's ELD Solution is registered with the FMCSA. Be careful because just being on this list does not automatically mean the system is even any good. NEM's ELD Solution is one of the best, if not the best system in the industry.
2. The ELDs display screen cannot be viewed outside of the commercial motor vehicle.
Section 395.20B
Violation Severity Weight: 5
To avoid this violation: Ensure the display of your ELD is not mounted in such a way that the screen cannot be seen from the outside of the vehicle. Tilting screens or undocking from mounts is acceptable. If using a portable device such as a phone or tablet, ensure your mount includes an option to tilt the screen towards the outside of the cab or allows the device to be removed and handled by the driver. Note that portable devices such as phones do not need to be handed to inspection officers, drivers may handle them on behave of officers instead.
3. Driver failed to assume or decline unassigned driving time.
Section 395.32B
Violation Severity Weight: 5
To avoid this violation: Train drivers thoroughly on the process for correcting any unassigned driving that appears in their ELD driver interface. It is also a good idea for administrative users to be familiar with the process of managing unassigned logs within the ELD.
4. Failing to note malfunction that requires use of paper log.
Section 395.34A1
Violation Severity Weight: 5
To avoid this violation: All drivers need to:
have a guide on ELD diagnostics and malfunctions (available from the ELD manufacturer), and
provide written notice to the carrier when a malfunction exists and persists such that the driver needs to switch to paper logs. It is recommended that a copy of this communication be kept in the cab with the driver in addition to being sent to the carrier.
Many other violations carry smaller weights and are equally easy to avoid. Drivers should pay attention to prompts within their ELD to fill out required information like addresses, shipping information,and trailer information. Drivers also need to know how to produce the three required ELD documents, and verify logs in a timely manner as well. The full updated CSA matrix can be found on the FMCSA website.
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credit: Kyle Dodsworth, ELD Specialist, Geotab
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