By Steve Bojan
The Federal Motor Carrier Safety Administration’s (FMCSA) new electronic logging device (ELD) mandate carries an agriculture exemption for good reason. During harvest season crops need to get to storage or processing to ensure quality and meet the needs of a very fast-paced process. The window for many harvesting can be incredibly tight. Additionally, there is a huge amount of concern for the welfare of live animals during transport. The ventilation of trailers that occurs as they travel down the road is a critical component of an often complex system created to keeps the animals healthy and comfortable during transport.
The recent clarification on May 31 that the 150 air mile radius exemption will remain in effect and can be from the source of non-processed agricultural products such as a farm, silo or livestock facility provides additional flexibility. In this same directive, the FMCSA also indicated that additional changes to hours of service regulations may soon be enacted to meet the continuing challenges that truckers face.
Even with a continued extension, though, adhering to the ELD mandate could help ag haulers move toward a model of operational excellence. Electronic logging takes the burden of hours of service requirements off personnel, and can improve fleet safety and reduce operating expenses by tracking idling and speeding. Consider the following five lessons we’ve learned from fleets already using ELDs:
There are many benefits to ELD. While many agriculture haulers are not required to use ELDs, doing so will make DOT compliance and identifying at-risk drivers much easier. The utilization of electronic logging devices, which can either be a stand-alone technology or part of a broader telematics system have huge operational potential. The ELD’s take the pressure off of drivers and supervisors to complete and monitor paper logs. Time spent at various locations can be reviewed in real time and anomalies can be quickly identified and dealt with. These systems can also reduce operating expenses by tracking idling, engine performance and routing.
Driver safety is everyone’s priority. Even if your business is exempt from hours of service regulations, you’re still required to supervise drivers for fatigue and vehicle safety. Also, remember the ELD exemption only applies to truckers hauling agricultural commodities within the 150 air-mile radius rule. Once the trucker ventures beyond 150 air-miles, the hours of service exemption no longer applies and drivers will need to follow the hours of service regulations.
All drivers needs documentation. It is important to take into consideration state regulations and practices that may come into play on your drivers’ routes, because even exempt agriculture drivers will be asked to prove their identity if questioned by law enforcement. This could be as simple as an agriculture license plate. Other times, the trucker will need to produce documentation on the company’s letterhead explaining why your organization is exempt. Make sure to provide your drivers with information about applicable regulations and the necessary documentation to keep in their vehicles at all times.
Know what the ELD exemption means. If a trucker is taking advantage of the exemption, make sure they are knowledgeable about what that means. Train truckers on the rules of the exemption, when it expires and why the load they’re hauling is exempt so they can explain it to law enforcement, should they be pulled over.
Exemptions can change. As the ELD mandate evolves, its exemptions and associated regulations are likely to change. Maintain compliance by staying up to date with the latest developments. Additionally, there may be other state ELD agriculture exemptions and regulations you should be aware of. Contact the state agency responsible for commercial motor vehicle enforcement to learn more about your responsibilities.
Look out for the evolving ELD mandate
While watching for industry updates on the ELD exemption, take stock of current liabilities and prepare for any potential ELD agriculture exemption mandate roadblocks, should the exemption expire soon.
Expect it to take four to six week at a minimum to put an ELD system into place. This includes establishing a contract with a technology provider, equipment shipping/installation and implementing the technology onto a computer/dispatch system. Training and trial implementation periods should follow. Larger and more complex operations could elongate the timeline.
Steve Bojan is vice president of Fleet Risk Services for Hub International. He has 20 years of operations and risk management experience in the transportation industry and serves as a resource for brokerage operations with transportation related risks, providing risk control, safety, property, environmental and workers compensation reduction guidance.