Switching from a paper logging system to an electronic logging system is not as simple as “plug in the device and let the data flow.” While electronic logging devices (ELDs) are nothing more than “very accurate logs,” the switch to an electronic logging system will impact all departments and all phases of your operation. It must be handled as a significant change, using a change management process approach. Using a change management process will allow you to maintain stability and continuity while reaching your end-state goal. In this case, the goal is the company operating effectively using an electronic logging system. With the Final Rule requiring that most drivers switch to electronic logs by December 18, 2017, carriers need to determine their end-state goal and start moving toward it sooner rather than later. There are many different change management models to work from. We are going to use one of the basic models - Prepare, Manage, Reinforce - and discuss the thoughts and actions that need to go into each step of the process. This is meant to be a summary of information contained in the rule. Be sure to review the rule and seek any legal advice from counsel. This material contains suggestions, and companies should find an approach that fits their unique operations best.
The preparation phase includes several key steps. The first critical step is determining what your “future state” should look like.
- What do you need the device/system to do?
- What would the system be capable of doing?
- How “driver-friendly” do you want it to be?
- How “user-friendly” do you want it to be?
These are all issues that need addressed up front. On completing this initial step, you will have defined the project, created an understanding of where you are and where you are going (i.e., your “future state”), and you will be prepared to plan the steps needed to arrive at your end-state.
Next, get senior management engaged in and supportive of the process. A project of this scale will require the support of all senior management. As you are going through the process, you cannot have a member of senior management undermining the change.
Once you have senior management on board, the next step is to form your project team. You will need to assign a project sponsor, which should be someone from senior management. The project sponsor will keep the project going forward if resistance is met. You will also need a project leader who will oversee the day-to-day activities necessary to plan for and implement the change. This person will also be the liaison to the vendor(s). Finally, you will want to include all the affected managers, from all areas of the company. It is wise to include driver representation at this point. The drivers have the most at stake, so having their participation and input can be critical.
Also, start looking for driver champions that can serve as mentors during the implementation phase. As well as including drivers and their supervisors on the team, be sure to communicate regularly with everyone in the company, especially all the drivers. Throughout the process you need to communicate why you are switching to an electronic logging system, what the benefits are to the drivers and the company, and what your expectations will be.
Before any system field testing starts, the foundational policies and procedures must be developed to guide the organization through the ELD transition. Some examples of basic policies are:
- Document who will have authority within the system
- How to edit hours-of-service records and ELD data retention (minimum six months)
- Procedures for submission/retention of supporting documents (no more than eight per day, per driver)
- Procedures for initial/orientation training, follow-up training, and remedial training
- Log audit procedures
- Dispatch planning
- Mechanic/vendor use of the trucks
- Approach to owner-operators
- Electronic submission of Driver Vehicle Inspection Reports (DVIRs)
- Procedure for reporting and resolving ELD malfunctions and other technical issues
- Rental vehicle ELD procedure
- Understanding and preventing harassment
- Procedure for drivers to transfer information to safety officials
After the preparations have been completed, the next step is to begin managing the change. The planning process will need to include action items for:
- Scheduling resources and training
- Determining an implementation timeline
- Developing thresholds and settings for the system
- Installing the devices
A best practice of ELD change management is to begin tightening up your hours-of-service compliance efforts. You will want to concentrate on the accuracy of logs and the adherence to limits. Remember, the transition from paper to electronic logs is not a short or easy one. If you are not ready, the time is now.
The information in this article is provided as a courtesy of Great West Casualty Company and is part of the Value-Driven® Company program. Value-Driven Company was created to help educate and inform insureds so they can make better decisions, build a culture that values safety, and manage risk more effectively. To see what additional resources Great West Casualty Company can provide for its insureds, please contact your Safety Representative, or click below to find an agent.
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This material is intended to be a broad overview of the subject matter and is provided for informational purposes only. Great West Casualty Company does not provide legal advice to its insureds, nor does it advise insureds on employment-related issues. Therefore, the subject matter is not intended to serve as legal or employment advice for any issue(s) that may arise in the operations of its insureds. Legal advice should always be sought from the insured’s legal counsel. Great West Casualty Company shall have neither liability nor responsibility to any person or entity with respect to any loss, action, or inaction alleged to be caused directly or indirectly as a result of the information contained herein.
