Sands of Time

ELD Mandate Transforms HOS Clock into Hourglass

If you haven’t had a heart-to-heart chat with your customers about the impact of the ELD mandate, the time is now. It’s a good idea to have that discussion or revisit this issue as commercial vehicle enforcement officers in the United States are set to begin full enforcement of the rules soon. (For details on the four-month delay in ELD mandate enforcement and recommendations on ELD mandate compliance from BarOle Trucking’s director of safety and compliance, visit our ELD implementation tips blog post.

Also, the Government of Canada late last year published amendments to the commercial vehicle drivers’ hours of service regulations and electronic recording device (ERD) requirements in an effort to align Canadian rules with U.S. requirements.

But how do you have that discussion? Where do you start? As it so happens, the Truckload Carriers Association and the Canadian Trucking Alliance offer guides with some good message points and recommendations. These recommendations provide tips on how to communicate with customers so that they can better understand the limitations under which your drivers must work according to the new rules.

Here are some of the top recommendations from both guides:

  1.  Hours of service: your customers may not realize the HOS clock cannot be halted and restarted like a stopwatch. Tell them to consider the HOS requirements as an hourglass. Once it’s tipped over, the sand in the hours-of-service hourglass keep flowing until they run out. There are no “turn-overs” or “do-overs”;
  2.  Each and every minute that ticks by during the driver’s allowed duty status not only must be digitally recorded, but also must be accounted for under the ELD mandate. Your customers may not realize that your drivers must account for the time they are detained at the dock. And once their time has run out, that’s it. Your driver and truck can go no further;
  3.  Since the ELD mandate requires carriers to document each minute drivers spend, whether they’re driving or waiting at the dock, you should discuss with customers how and when freight will be loaded and unloaded. Unless drivers are trained to handle specific equipment or cargo, or unless you’ve made alternative arrangements, your customers should be prepared to load/unload the freight in a timely manner;
  4.  Dock hours: do the dock hours align with freight volume? Your drivers should be provided 24-hour access, or as close to it as possible, to facility contact information so loading/unloading issues can be quickly resolved;
  5.  Let customers know how much drive time your drivers have available as they arrive at their loading docks. If there’s a line of trucks waiting to be loaded or unloaded, ask them to consider giving priority to those drivers who are in danger of running out of hours before their trailers can be loaded or unloaded. After they are loaded or unloaded, your drivers should also have enough time to inspect their trucks and trailers, get underway and reach a place where they can stop and get their mandatory rest;
  6.  When dock space becomes temporarily unavailable, your customers should avoid having your drivers wait at their docks. Ask them to inform you and/or your drivers before they are scheduled to arrive. If possible, ask them if they can let you know when space becomes available so you and your drivers can determine if there’s enough time to drop off or pick up the load before the HOS are up;
  7.  If you have a long-standing relationship with customers, consider asking for a facility or place where your drivers can clean and inspect their trailers and discard packaging material. Let your customers know this could help drivers maximize driving time and get their shipments where they need to go in the time available;
  8.  Ask your customers if space is available on their property where your drivers could park their trucks and use their sleeper berths to take their mandatory breaks, if necessary. If that’s not possible, seek their help in identifying nearby locations that your drivers can reach in their remaining drive time. Be sure they can park legally and safely at those locations, and can maneuver their trucks and trailers into the facility and back out onto the road quickly following their mandatory rest breaks;
  9.  Identify traffic conditions, seasonal weather, construction projects and other circumstances that might delay drivers, and ask your customers to take those things into consideration when scheduling shipments. With the data that’s available from your ELDs, perhaps you can provide value-added service by helping customers to identify and resolve those inefficiencies?
  10.  If your customers penalize late arrivals, work with them to identify and resolve the causes of those inefficiencies instead of using fines or penalty charges;
  11.  Collaborate with your customers to confirm that transit times can be realistically achieved under HOS regulations and by driving under the posted speed limits.

The Canadian Trucking Alliance produced a short video (2 minutes, 45 seconds) that offers carriers another good starting point in helping customers understand carrier limitations under the ELD mandate. As the Canadian Trucking Alliance points out, it just makes common sense for all parties to promote partnership and fulfill their responsibilities in creating a safe supply chain.

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