Paper Logs Can Ease ELD Transition, FMCSA Officer La Tonya Mimms Says

Mandate for Devices Takes Effect Dec. 18
FMCSA La Tonya Mimms
Eleanor Lamb/Transport Topics

KANSAS CITY, Mo.—Drivers bracing for the upcoming electronic logging device rule should practice driving with the new units and old-fashioned paper logs, according to La Tonya Mimms, transportation specialist with the Federal Motor Carrier Safety Administration.

The ELD rule, due to take effect Dec. 18, mandates that commercial drivers who are required to record their hours of service do so with the devices. FMCSA divided ELD migration into three periods. Phase 1, which started in February 2016 and concludes Dec. 18, allows drivers to use paper logs, logging software, automatic onboard recording devices and ELDs that are registered with FMCSA.

Mimms, who leads the ELD rule implementation plan at FMCSA, said drivers making the transition to ELDs should start by using paper logs and relying on their new electronic devices as a form of supporting documentation. She said this practice will give drivers the opportunity to appreciate how much time they are saving when using ELDs versus paper logs.

“I encourage people to take advantage of this during Phase 1 because it gives the driver the opportunity to get used to their device. They can see how much time they’re saving with their device as opposed to how much time they’re spending recording their hours on a paper log,” Mimms said at the Women In Trucking Association’s annual conference. “The ELD will record the hours of service by the nanosecond, so the driver’s saving time recording their hours of service.”



Since February 2016, ELD manufacturers have been able to register and certify their devices with FMCSA, and motor carriers could elect to use ELDs listed on the agency’s website. Mimms said the agency’s list contains about 150 ELDs.

ELD providers are required to use either telematics, such as e-mail and web services, or local connectivity, such as USB drives or Bluetooth. Mimms said that drivers working in remote areas may want to consider using local devices because not all areas have access to an internet connection. She cautioned drivers not to rely on ELDs that print solely from the fleet’s back-office system.

“We’re working with technology. It fails at times,” Mimms said. “That device must be able to display hours of service on the display screen or print hours of service [records] in the cab.”

Dee Smith, a YRC Freight driver based in Indianapolis, has experienced the technological snags that can accompany ELD adoption. Smith said she and her fellow drivers still are getting used to the devices, which the fleet installed a month ago. She said the unit is relatively easy to use, but there have been challenges tied to software and connectivity issues. For example, Smith said drivers have to step outside the terminal building for their portable devices to load information, which they need to access before they leave for a dispatch.

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ALK Technologies Inc.

“Once it works properly, then it’s fairly easy. The hard part is getting your information in there before you can leave. It takes time,” Smith said. “I think there’s a software problem. It’s slow. Once they get the bugs in the software worked out, I think it will be easier.”

FMCSA records nominal violations, which can occur when a driver exceeds his or her hours of service by a small margin. Mimms said that nominal hours-of-service violations have a minimal impact on motor carrier safety scores. She said one purpose of the nominal violation is to track small HOS offenses that may accrue over time.

“We understand that the ELD is going to record hours of service by the nanosecond and, therefore, the driver can exceed the hours of service by a minute. It’s a violation. It’s not a serious violation; that’s why we have the nominal hours-of-service violation to keep record of that driver going over the hours of service,” Mimms said. “If that driver continues to go over their hours of service for 10 minutes every day, that can add up to a significant hours-of-service violation by the end of the week.”

The ELD mandate ranked to No. 2 this year on the American Transportation Research Institute’s list of most critical issues for the trucking industry, which was released Oct. 23. Driver hours-of-service rules was No. 3. “Start now. Find an ELD on the list. Keep recording on a paper log,” Mimms said. “Sit down with your drivers to show them the differences. It’s going to speed up the roadside inspection.”