Only 3 days remain to leave your public comment on the ELD mandate. This is your opportunity to have the FMCSA hear your voice on this unnecessary regulation.

We’ve posted a definitive 3-minute guide so you can leave your own comment regarding potential exemptions to the mandate. Class A Drivers left a comment and you should too. It’s fast easy and the only way that the agency will know how you feel the ELD mandate affects truck drivers.

Ryan Wells (pictured above) has over three years in logistics. He used our guide and shared his comment with us. Read his submission below. And don’t forget to leave your own comment. Three days left.

Ryan’s Public Comment:

Respectfully to the members of the Federal Motor Carrier Safety Administration

My name is Ryan Wells and I have worked in the logistics industry for over 3 years the majority of that time in a direct management role and therefore have significant experience in the various regulations set forth for drivers and I am all too familiar with the conditions these drivers experience while on the road. My most recent position was at a Crestwood Transportation where I served as a fleet manager.

I live and breathe this stuff I have worked with drivers one on one followed them with their routes managed them and helped support their operations in the field. So I have to say I fully support the OOIDA’s proposed ELD exemption for small trucking carriers and independent drivers with a proven record of safety. My reasoning is as follows.

My initial reaction to the passing of the ELD mandate was surprise – the winter months are notoriously terrible times for driving conditions and hauling a (potentially) 80000 pound load across the road in a blizzard is no simple task. Pictures of trucks tipped over on the side of the highway are all too clear in my mind from the times of these terrible weather conditions.

So to say that it would be unsafe to impose a (controversial) system on a driver at such an already precarious time would be an understatement. The competitive nature of this industry as I’m sure you are well aware makes the driving times tight and puts these folks under tremendous pressure to begin with.

Not to mention December? The month with the greatest shopping volume largest number of interstate travelers and of course record breaking ecommerce sales I am extremely wary of the FMCSA’s decision to roll out a new and controversial plan during such conditions. I think a slower (and less weather hazardous month) to start this process would have been much more preferable.

This is my first indication that the mandate was a little rushed. The next one deals with the lack of infrastructure in place to support the systems as electronics are only as good as the way they are built (and supported).

Now I am not familar with every ELD provided to these guys but the ones I am virtually register the driver as always on duty which puts unnecessary pressure on him to engage in poor behavior and decision making (like aggressive driving driving while tired etc). Clearly this isn’t within the public good which as I understand was the whole point of the ELD in the first place.

Not to mention I really don’t think there has been significant testing on this technology nor the service providers to guarantee that they are performing up to standard. A driver I was working with had a malfunctioning ELD and spent nearly half a day trying to get through to a customer service rep to get it fixed. Again this industry is competitive and if there is going to be government intervention into the field I highly recommend that the equipment be held to as high of a standard as the man or woman who is using it.

Now please don’t take this to mean that I am against the use of an ELD by any means quite the contrary. I believe this technology can be an excellent addition to this industry but only when it has been adequately tested which by my point of view it has not.

Let us roll this out when the roads are clear and the driver is not under higher strain than usual and of course after adequate testing of the technology and most importantly the testing of the support infrastructure of the technology for when things go wrong which they will inevitably do.

Very Truly Yours

Ryan Wells