The comment period for the FMCSA’s Advance Notice of Proposed Rulemaking on potential changes to the Electronic Logging Device rules and Technical Specifications closed on November 15, 2022. Since then, there has been much discussion about the overall safety impact of ELDs. Several organizations have highlighted recent crash data to suggest that electronic logging devices have done little to reduce crashes and imply that ELDs may increase crash risk. But is it that easy? Is it fair to point to four pages of a 682-page rulebook as the cause of rising crashes or for a failure to reduce them? STC thinks we should consider all the facts and wait for others to materialize before calling for FMCSA’s head.
There are several facts relevant to this conversation that can help us frame the value of ELDs. Of course, top of mind is whether the promised crash reductions have materialized.
In its final rule, FMCSA estimated that 1,844 crashes would be avoided annually, eliminating 562 injuries and 26 fatalities. To put that in perspective, in 2020, there were 415,000 police-reported large truck-related crashes resulting in 101,000 injuries and 4,444 fatalities. This suggests that the impact of ELDs on fatigue and hours of service is a small part of a much larger, more complex crash picture.
Most of the predicted benefit of electronic logging devices was from an expected reduction in the administrative burden that comes with adopting ELDs. As STC is an organization that regularly works with ELD providers and motor carriers seeking to improve their compliance posture, we can attest that many of these benefits have materialized. Driver oversight and internal auditing have become exponentially easier and more effective with the development of dashboards, automated violation detection, and the reduced need for voluminous supporting document comparison. Carriers can “see” what drivers are doing in real-time and are being proactive at managing safety and compliance. Editing logs when errors are discovered is a much simpler process and identifying compliance issues is as easy as comparing reported odometer readings and location data following a duty status change. The work of carriers who aspire to follow the rules and take safety seriously has gotten easier. Yes, it came with growing pains. As carriers mature and technology improves, their lives are getting easier.
To those throwing daggers at FMCSA and ELDs for rising crashes, STC asks they consider all the ways ELDs have improved the state of play. Compliance is easier, unless non-compliance is your goal. Of course, this advice will not appease those determined to hold FMCSA accountable for their crash reduction predictions. To those, STC suggests we remember that crashes are inherently rare and complex events, with many critical reasons and contributing factors. To understand the true safety impact of ELDs, we must examine to what degree fatigue contributes to crashes before and after the ELD mandate. For this, we’ll need to wait for the next iteration of FMCSA’s Large Truck Crash Causal Factors Study, which, unfortunately, will be years away. In the meantime, FMCSA should use their expected rulemaking on revisions to the ELD rules to repeat their analysis of the safety impacts of ELDs to determine if the predicted safety and administrative burden impacts have materialized.