The two-year grace period allowing automatic on-board recording devices (AOBRDs) in place of electronic logging device (ELD)-compliant devices for electronically tracking hours of service in commercial trucking fleets expired in December 2019. This means that food manufacturers with distribution fleets that did not upgrade to ELD-compliant devices but were operating under the AOBRD extension should have already made a commitment to an ELD provider and service.
Additionally, food manufacturers and distributors operating under the AOBRD extension for the last two years are now faced with the same decisions that fleets had to make when the ELD mandate was initially put into place: Who do I select as my provider? It is now even more important that companies not make hasty decisions that can set them back with regard to data and technology.
The ELD conversation for food manufacturers and their distributors is larger than just an hours-of-service (HOS) determination, especially for time-sensitive and temperature-sensitive operations, due to the passing of the Food Safety Modernization Act (FSMA). ELDs are also part of a broader discussion about telematics and on-board computers and the use of telematics to optimize data that comes from the truck, as well as the use of that data for overall fleet compliance, analytics, and operations.
ELDs can be a different technology than an AOBRD. ELDs are not required to capture all the operating data that your AOBRD may have been capturing. ELD data requirements are focused and governed based on the HOS rules; what this means is that food manufacturers and their distributors need to be careful in their selection to ensure they do not focus only on ELD compliance. Food manufacturing and fleet executives need to also determine what data they need in order to continue to manage their food distribution fleet efficiently and in compliance with FSMA. For example, they may select a compliant ELD but may lose important operational data, including load data, maintenance data, and fuel data, used to monitor total cost of ownership.
AOBRDs have been around for several years and can capture an extensive amount of data. Many telematics providers have upgraded their technology to maintain their data collection and monitoring capacities and enhance them with the ELD mandate compliant functionality. These devices will continue to record the same data as the AOBRD; however, newer ELD devices and services may not be collecting the same rich data set.
The ELD mandate opened a vast market of opportunity that attracted several new providers claiming to be ELD-compliant. Many of these providers are focused on ELD compliancy and not the valuable fuel, diagnostic and fault code data, or load-specific data that might be needed for food distributors under FSMA.
When switching to ELDs, food manufacturers and their distribution fleets need a few key questions answered: Are they giving up or did they give up access to critical data they have been historically using, and are they giving up access to data that would help with FSMA compliance in the future? This depends on the viability of the technology platform offered by the provider. If fleet managers are not careful, they may lose out on critical truck data they can use, or have been using, for performance optimization via data analytics.
This additional data could be of further use to food distributors with time- and temperature-sensitive loads. These organizations rely on identifying longer idling times and, when combined with temp-sensitive orders, can greatly impact fuel expenditure and critical routing data that can also impact perishable deliveries. What’s more, FSMA mandates that sanitary transportation of food requires temperature monitoring and control to prevent refrigerated/frozen food from becoming unsafe during transportation. This information can be monitored with the right ELD telematics solution.