Forget the whole unfortunate “black box” thing. It was never right to start with — really little more than an inaccurate if catchy metaphor favored by opponents of electronic onboard recorders (EOBRs) for commercial vehicles.
Other than capturing and storing data, EOBRs deployed for hours-of-service (HOS) compliance bear no resemblance to the self-contained “black boxes” that record flight data and are retrieved from aircraft after a plane crash.
For one thing, a truck EOBR typically is not a stand-alone device at all but rather a set of electronic functions built into or added onto an onboard computer system.
For another, EOBRs are not yet mandatory in U.S. commercial vehicles. But that is expected to change sooner rather than later.
Last year, the Federal Motor Carrier Safety Administration (FMCSA) published an Advanced Notice of Proposed Rulemaking on EOBRs. It's anticipated by Washington watchers that the agency will take the next step, a Notice of Proposed Rulemaking, sometime during the first quarter of the year.
February is upon us, so whether or not that timetable is correct remains to be seen. But rest assured that with no heavy resistance evident from trucking's chief lobbying group, the American Trucking Assns. (ATA), a mandate for HOS EOBRs is surely wending its way through the halls of bureaucracy. (See F0 1/06, “Black boxes coming back.”)
“The big question is whether the upcoming rulemaking will make EOBRs mandatory or just be an update to the FMCSA 395.15 rule that currently governs how paperless logs work when used voluntarily by fleets,” advises Brain McLaughlin, vp-marketing & product planning for PeopleNet
“The 395.15 rule lays out the performance requirements that must be met for a paperless log to be acceptable,” he continues. “At this point, we don't know how that might change or not, or whether a mandate will be issued.”
Opposition to EOBRs has centered on privacy concerns, as raised by both the Owner Operator Independent Drivers Assn. and ATA, and on cost concerns. ATA is especially adamant that if required, EOBRs should be made mandatory for all motor carriers at the same time to ensure all are hit with the per-truck cost equally.
Norm Ellis, vp & gm of Qualcomm Wireless Business Solutions — transportation & logistics, says his “gut feeling” tells him it will be in a “two- to four-year time frame” that a mandatory regulation will come through. “Our key thought on that,” he adds, “is if required, it should be for all carriers — not some — to ensure a level playing field.
“Trucking now knows there are reasonably priced solutions available for paperless logs out there,” he adds. “Given that, we're confident the industry and the regulators will come up with the right solution statute-wise.”
Indeed, a number of information technology vendors are already offering EOBR functionality to fleets by complying with the aforementioned 395.15 performance standard established by FMCSA to allow the voluntary use of EOBRs in place of paper driver's logs.
Suppliers of these paperless logs that FLEET OWNER spoke with indicate it's likely any EOBR mandate would hew closely to what FMCSA is already allowing under the voluntary use provision.
What's more, they all suggest they would not now be offering their paperless log features if it was not technically feasible and reasonably priced — and if there were not already fleets paying for it.
They report this customer demand is driven by how paperless logs — especially when integrated with other onboard capabilities and “back office” fleet-management programs — can boost operational efficiency and even driver satisfaction.
“The industry is starting to understand the benefits of paperless logs,” says Nathan Todd, product manager for @Road Inc.'s GeoManager GPS-based vehicle-tracking system. “We have some 3,000 customer trucks using our log feature now. The concept is becoming more widely accepted as a time-saver. That's why we are prepared for huge growth over the next year — with or without a mandate.”
ACCURATE AND VISIBLE
According to Gerry Kirouac, training manager for Cadec, which has an electronic log feature integrated into its Mobius TTS system, a prime advantage of going paperless is that it's “much more difficult for drivers to make inadvertent mistakes,” which makes log data highly accurate and highly usable.
“Because log data is captured and transmitted electronically, customers can see the available driving and duty hours of each driver on an ongoing basis,” Kirouac adds.
“We have over 100 customer fleets voluntarily using our system's EOBR function,” says PeopleNet's McLaughlin. “If asked why, they will give some key reasons: HOS compliance management and reducing the risk of non-compliance; greater operational efficiencies; and making the driver's job less burdensome.”
Ellis says that along with “handling data very effectively,” a principal design goal for Qualcomm's paperless log feature was ease of use for the driver. “It's designed so that once the driver logs onto the system in the cab to identify himself, as per the existing statute, he does not have to touch it again until sign-off, unless he takes a sleeper rest break.”
Electronic logs can be add-on modular features (such as with @Road, PeopleNet and Qualcomm) or integrated into (such as Cadec) the underlying wireless onboard solution a fleet chooses to use.
Todd points out that for @Road, electronic logs are offered as “an extension to GeoManager, our basic GPS vehicle-tracking solution paperless log.
“This means the drivers' HOS data can be transferred wirelessly to our server, enabling us to host it via a web-based service,” he continues. “This makes compliance auditing a lot easier. And also thanks to wireless data transmission, we can automatically check driver status by monitoring his activity by whether his vehicle is in motion or not.”
But at this point, what may be more telling than the technical underpinnings of each paperless log system is their already broad-based appeal.
For example, according to McLaughlin, PeopleNet's electronic log customer base is about evenly split between private and for-hire fleets. He says it's fair to say that, across the board, those fleets that have voluntarily gone paperless are those that “put safety and compliance out front.”
And while Cadec's Kirouac reports greater interest at the moment from private fleets, he figures there's “growth potential in the for-hire market due to the flexibility enabled by paperless logs.”
Clearly boosting flexibility is the combination of electronic log and wireless communication that enables fleets to keep track of driver duty status remotely.
What drives flexibility even higher is linking the driver log function with other functions of the underlying wireless solution or even other fleet-management programs.
Kirouac points out that the Cadec Mobius TTS system, which has the electronic log literally built into it, requires customers to have their own network servers on which to retain their HOS compliance databases.
“There's a fail-safe built in so no data newer than six months can be purged,” he points out. As for roadside inspections, the log can be reviewed via the onboard computer.
According to Kirouac, while the Cadec log database is maintained by the customer, Mobius TTS log data can be transmitted wirelessly via short-range radio frequency or cellular communication links, or both.
While Mobius TTS is not a dispatch system, Kirouac says it's also not the end of the data trail. “The data our system captures can be uploaded to other systems a fleet may have, so HOS data could be pushed onto a dispatch or payroll system as well.”
“Our EOBR component is one module of many offered,” says PeopleNet's McLaughlin, “and the vast majority of our customers regard it as one piece of a broader system for fleet management.
“For example,” he continues, “they can use it for proactive hours management. The system can be set up to tell both the driver in the cab and the dispatcher or manager in the office how many hours the driver has available throughout the day.
“That's important because many times an HOS violation is not the driver's fault, but the dispatcher's. To avoid this,” McLaughlin explains, “we can provide two levels of visibility to the hours. In the cab, it's in real time and to the back office over the wireless network it can be in near-real time.”
According to Ellis, Qualcomm's EOBR is an add-on service to the firm's flagship OmniTracs system. He notes that the paperless log function can be installed on all vehicles in a fleet or just a portion, such as those operated by new drivers.
Either way, Ellis says the system's ability to “automatically update each driver's hours ensures a dispatcher doesn't put a driver on a ten-hour run who has just six hours left on the clock.
“Many people think they will lose time and productivity if they move to electronic log-keeping,” he says. “But actually, they find they improve their efficiency while making their drivers happier.”
A big part of the efficiency benefit of using a wireless EOBR system is that the six-month paper trail the federal government requires be maintained for a paper-based log system vanishes.
“There's a huge back-office operational efficiency gain from these systems,” says PeopleNet's McLaughlin. “Instead of keeping all that paper, auditing can be done on screen.
“As for roadside inspections,” he adds, “the voluntary EOBR rule requires that up to eight days of HOS data be stored on board. That information is viewable through the driver's message display or it can be printed out on site.”
Another selling point of switching to electronic log-keeping is that it saves time — and aggravation — for drivers who get to quit their paper chase.
“An electronic log will save a driver 20 minutes a day over a paper logbook,” says PeopleNet's McLaughlin. “That's 20 minutes they can be driving or performing other tasks. And their work life becomes simpler, too.
“We've found,” McLaughlin adds, “that the initial reaction may be negative from drivers — ‘no black boxes!’ But once they are in place, the same drivers don't want to work without them. They don't miss the paperwork once it's gone.”