The December 2017 deadline for commercial vehicle drivers to begin record keeping on an electronic logging device (ELD) has held fast in spite of multiple legal challenges. Nevertheless, shortly before that date, the Federal Motor Carrier Safety Administration (FMCSA) announced a last-minute modification. In October, FMCSA decided drivers with mobile device-based ELDs — typically, in a mobile phone or tablet — would be allowed to use these to change their duty status when away from the vehicle, provided they add a note to that effect.
That raises a question: if a mobile device can be provided with software capable of performing the functions of a telematics device, why should a dedicated ELD be required?
Just another app?
We use our mobile phones and tablets for so many purposes that they’ve become indispensable tools. With the help of apps, these devices transcend mere communication. It is hardly a stretch to expect that a mobile phone with a few specific apps installed could be used to execute the range of operations mandated by the FMCSA — all of them, not only the change of duty status.
An interesting (and potentially money-saving) idea — but not the most practical, for many reasons.
First, we’re confronted with a regulatory hurdle. FMCSA has decreed a set of requirements that qualify a device as a certified ELD, and installing a few apps to a smart phone won’t automatically bring it up to those standards.
Any certified ELD solution must meet these performance criteria:
- Automatic recording of driving time, date, location engine hours, miles and driver identification at 60-minute intervals, and retain this data for seven consecutive days
- GPS location accuracy to within one mile
- Integral synchronization with the vehicle’s engine control module
- Tamper-proof safeguards, and mandatory driver review of records to verify driver identity and accuracy
- Transmission of data using specified data protocols
- A display that provides all data in a standardized format for safety officials to review on demand
- A user manual that includes instructions for recordkeeping in the event of a malfunction, and instructions for transfer of data to officials
- A function for annotating as well as verifying records, by driver or other users.
There’s more. But if a smart phone is to serve as a stand-in for a component in an ELD, it has to provide reasonable assurance that the solution operates as required — that the phone doesn’t end up being the weak link in the telematics system’s required reliability and accuracy.
Stamina is value
Reliability is an issue that stands out when considering the life cycle of most phones. Mobile phone manufacturers know that their customer base likes to upgrade to a new model every few years. That fact, plus the product’s exposure to daily hazards and handling, results in an engineered life expectancy that is short.
Purchasers of ELDs probably do not intend to replace their hardware so often, whether they’re owner-operators or fleet managers. In a business, cost control takes precedence over possessing the latest technology — and fleets would prefer to update their telematics tracking systems instead of frequently replacing them. ELD manufacturers rightly promote the durability of their solutions, as well as the scalability and flexibility to meet changing operational demands.
With mobile phones, battery power is another stumbling block. Users deal with the discharging/recharging cycle of a device that consumes current very quickly. If drivers are doing anything else with their phones during work hours, the combination of personal use and ELD logging will drain power even more rapidly.
The ELD mandate stipulates that vehicle activity must be monitored and recorded on a continuous basis. The rules do not allow for any data gaps. What happens when phone battery power drops below the storage/transmission threshold?
Who stands behind it?
Responsive technical support and a staff that keeps abreast of FMCSA regulations also back a complete ELD solution from a reputable supplier. These professionals help the client remain in legal compliance over the life of the system.
In contrast, there’s no assurance that a smart phone ELD app — from a provider for whom this is not a major market segment — will be supported even a year from now. Few business challenges are as unnerving as the sudden discovery that a crucial operating component is no longer able to do what it’s supposed to do. That feeling is compounded when the inability to meet this obligation may result in a fine or suspended license.
Specifications, reliability, durability, battery life and technical support are not the only issues that make smart phone technology an iffy proposition when it comes to meeting the government’s ELD rules. But in weighing the drawbacks of this approach these are a good place to start.