Thomas Cuthbertson - What Happens Now?

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Transcript Thomas Cuthbertson - What Happens Now?

Tom Cuthbertson – VP Regulatory Compliance – XRS Corporation Electronic Logging Devices: What Happens Now?

Agenda - Short

• Overview of some key notables • Driver Changes • Certification • Transfer of Log Detail to enforcement

ELD SNPRM

• Mechanical Engines – Seeking comments • Carrier transitional operations – AOBRD/ELD Same driver two devices in reporting period not addressed • State and Canadian RODS Harmonization • AOBRD valid for 4 years after effective date

ELD SNPRM

• Yard Moves - not Drive, Only On-Duty duty • Drive Starts at up to 5 MPH • Only Auto On Duty when stopped 5 minutes • No direction on Non-ECM vehicles • Did not specifically address OBD

Certification

• eRODs Application Testing to insure integrity – need software • What Level of Change requires recertification • Security level testing • Not third Party • Must supply documentation • Description of certification process allows FMCSA to authenticate • Operations Manual • Registry at FMCSA

Interoperability

• Transfer eRODS file between Suppliers – Difficulty is Harmonization of State/Canadian rules – Requirements to comprehend details required to maintain the integrity of the previous periods information – Not requirement – looked for comments

Items Specific For Drivers

(address harassment) • Allow Driver to edit their logs and create annotations on all entries and edits applied complaints – NOT DRIVE TIME • Drivers must approve all edits from Support Systems before • Require that drivers have direct access to the log information • Ensure that a driver reviews all edits before they are applied and allow rejection • PC reduce accuracy of GPS and do not record all engine information -10 mile accuracy • Audible muting of devices by driver • Coercion prohibited • 386.12a and 390.36 are new process regulations to file

eRODS – Roadside Logs Transfer

Web Services Blue Tooth Email File Transfer Jet QRCODEs USB Thumb Drive Printing w/QRCODES

BLUETOOTH TRANSFER

• Bluetooth technically capable of transmitting large files • Enforcement must have Bluetooth configurations specific to regulation • Layer of Security • • • Bluetooth must generate Personal ID to bond with enforcement equipment ELD must be made discoverable and generate a random code to be given to enforcement Connect to wireless personal area network and transmit via Web Service per 4.10.1.1

QR CODES

• QR Code on Right 50 characters/ Left 1250 • Each Duty status line 174 characters • Regional, LTL and Private Fleets can have 30 status changes per day = 18-30 QR CODES for 8 days.

Transfer Jet Obstacles

• Device acquisition cost is approximately $125+ • Uses Near Field Communications – basically the Bump of devices to transfer files

Open Discussion

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