ELDs and CSA Scores – What you think it means versus what it actually means

No ELD will still cause violations, may cause fines but will not affect CSA Scores until April 2018

The FMCSA recently announced that a driver who receives a violation for having no electronic logging device (ELD) or compliant AOBRD between Dec. 18 and April 1 will not have points recorded against them in the Compliance, Safety, Accountability (CSA) carrier scoring system.

Sounds like a great relief for smaller carriers and owner-operators who are waiting for the last minute to implement an ELD or just ignore the mandate altogether.

But this is where confusion sets in as clarifications of the ELD mandate from the FMCSA seem to coming daily. What is reported as fact on one day has been updated the next.

What you think this ELD CSA Score news means:

It doesn’t really matter if I get an ELD now or not, this is basically an extension for a couple more months.
I won’t receive any punishment for not having an ELD in my truck after Dec 18 and before Apr 1.
This phase-in period allows a chance for the ELD Mandate to be stopped or delayed further.
Roadside enforcement are going to ignore the fact that I do not have an ELD or compliant AOBRD in my truck.

What it actually means:

It’s still a citation!
- A no ELD violation will be a “no points violation” until April 1, 2018, that will not affect the Safety Measurement System Safety Measurement System that feeds into CSA scores that feeds into CSA scores.
- Violations will still be tracked by the FMCSA for a possible intervention
You can still be fined!
- Lane Kidd, managing director of The Alliance for Driver Safety & Security said, “Tickets may not levy points against the driver, but the fines attached to those tickets will likely cost the drivers more than the price of an ELD, so I’d hardly call this announcement a win for anybody holding out on buying an ELD.”
The April 1, 2018, deadline is not an extension of the ELD mandate.
- This rule has been on record for nearly two years now and is not going anywhere
- The April 1, 2018, deadline date is a phased in approach to enforcing the mandate that allows drivers an adjustment period before ELD CSA points and Out of Service Orders are levied.
- During this adjustment period, for drivers struggling with the ELD learning curve, it is recommended that paper logs be maintained as well as recording hours within the ELD. During an inspection, if there are ELD problems, the fallback can be paper logs.
- During the adjustment period, failure to be able to show accurate Records of Duty Status during a roadside inspection, either ELD, AOBRD or Paper Log, may well result in an Out of Service Order and CSA points for no log.
After April 1, 2018, the adjustment period is over and full enforcement should be expected.