What follows is the written speech -- the Electronic Logging Devices mandate commentary -- that was delivered via Facebook Live on Monday morning, December 4, 2017.
Hello. This is Vicki Simons, broadcasting live from the Pilot Travel Center in Graniteville, South Carolina, near my home. With me today is my husband Mike Simons.
Together, Mike and I have almost 20 years of professional truck driving experience. We drove coast-to-coast as a husband-and-wife team hauling dry vans and doubles for almost 3 years. Mike has driven the rest of that time regionally and locally. He has hauled a variety of equipment including tankers, flatbeds, dry vans and refrigerated vans.
We started our website Truck-Drivers-Money-Saving-Tips.com in January 2009 in order to provide real world tips that help professional truck drivers save hard-earned money and personal reporting about products and services for use on the road. We've developed this unique website as a place to share the tips we have learned through the years -- and where other professional drivers can do the same.
In order to protect other truckers, we decided to speak out about problems like the ones we've faced in trucking. In so doing, we became "trucker consumer advocates."
Today, December 4, 2017, there are a number of protests going on nationwide about the mandate regarding Electronic Logging Devices (or "ELDs" for short). I am going to be sharing some information regarding the costs involved and the so-called safety reason behind the mandate. I will take questions when I am through with my presentation.
First, there is quite a divergence of thought regarding the cost of the Electronic Logging Devices themselves. I've seen costs ranging from $200 to $1,200 per unit.
I was recently communicating with some truckers through a Facebook group. A professional truck driver named Bud Young detailed his experience, which I will greatly summarize here:
Besides the cost of the unit itself, there is:
Will the ELD save time and money in the long run? We read online, "the net benefits of ELDs outweigh the costs with expected paperwork savings of over $1.6 billion annually" (link).
Looking at just the ongoing cost of the ELD service, if 3.5 million trucks pay $50 per month, that will be an outlay of $175 million per month. Multiply that by 12 months for an annual cost of $2.1 BILLION in service fees -- after the cost of the equipment and installation!
What about the cost of lives? The ELD mandate has been put into place to save an estimated 26 lives every year. Let's take that $2.1 BILLION annual cost and divide that by 26 lives. That means that each of those lives is worth over $80,769,230 annually. Why aren't truckers being treated and paid as if they were worth that much money?
Let's go back to the issue of the actual devices for a minute. In a very long article on TruckingInfo.com entitled "70 Answers to Top ELD Questions", Question 63 reads, "If I choose a device that turns out to not be compliant, despite the vendor's self-certification, what do I do?"
On November 29, 2017, Indiana Attorney General Curtis T. Hill, Jr. wrote a letter to the FMCSA "to propose an immediate delay in the implementation of new requirements currently set to take effect December 18, 2017, regarding the use of Electronic Logging Devices (ELDs) by commercial drivers."
In that letter, we read:
"With manufacturers of ELDs currently responsible for 'self-certifying' their compliance with government standards -- with no effective procedures seemingly yet developed to provide oversight over such 'self-certifying' -- drivers and operators are left without any way of ascertaining which brands and models of devices ultimately will pass muster. They must 'fly blindly' into investing in products they are being required to purchase."
In what other industry besides trucking has the government ever mandated the purchase of a 'self-certified' product? None that I know of.
I encourage Attorneys General from across the USA to join Curtis Hill in proposing an immediate delay in the implementation of ELDs.
In fact, based upon what I've seen so far, Electronic Logging Devices should be used only by those professional truck drivers who want to use them -- and not forced upon the entire industry.
Now, let's shift to the supposed reason why ELDs are being mandated: safety.
Supposedly, the use of ELDs industry-wide is going to save lives. Do you remember what happened in 2013 when the Hours of Service regulation was changed, purportedly to "save lives"?
I wrote a guest blog on August 1, 2013, citing, "FMCSA estimated that these new safety regulations will save 19 lives and prevent about 1,400 crashes and 560 injuries each year." Has that happened?
According to a November 29, 2017, article, "Data released by the National Transportation Safety Board (NTSB) on November 21 revealed 2,030 more people died in transportation accidents in 2016 than in 2015, with highway fatalities accounting for 95% of all transportation fatalities in 2016."
OK, what about large truck crashes?
According to Data and Statistics from the FMCSA:
In my October 14, 2017, issue of TDMST Weekly Round-Up, in point #7, I cited an October 10, 2017, article that stated: "As to fatalities resulting from crashes involving large trucks, the [National Highway Traffic Safety Administration] recorded a 5.4% jump in those over 2015, the highest since 2007."
So, annually over the period from 2012 to 2016, fatal crashes involving large trucks was up by 2 percent, down by 5 percent, up by 8 percent, and up by 5.4%, for a net increase of 10.4%. What has been happening? Are the large trucks at fault in all or even most of these fatal crashes involving large trucks?
Ohio doesn't represent the entire USA, of course, but we read in a November 22, 2017, article that "Based on statistics from 2016, the Ohio DOT confirmed that the truck driver wasn't at fault in about 75 percent of fatality crashes involving a commercial motor vehicle."
Obviously, something needs to be done to prevent the fatal crashes for which truckers are at fault. But the focus needs to be on the greater of the two contributors, which is not the commercial motor vehicles or their drivers.
According to the SCTA, "South Carolina is home to 8,230 trucking companies, most of them small, locally owned businesses. In 2013, trucking industry in South Carolina provided 88,370 jobs, or one out of 17 in the state. Over 80 percent of communities in South Carolina depend… exclusively on trucks to move their goods. Trucks transport 84% of total manufactured tonnage in the state, or 424,585 tons per day."
So truckers are important here, just as they are in most places across the USA.
The FMCSA waved the flag about the so-called safety benefits prior to their Hours of Service regulations change in 2013 -- and safety has drastically declined since then. There is no proof that the claims of increased safety from the ELD mandate will be realized either.
My husband Mike and I are opposed to the Electronic Logging Devices mandate. We believe that there is much more to this mandate than safety alone. Others and truckers will address those issues. We encourage truckers to speak out to their federal elected officials and to their states' Attorneys General regarding this matter.
Now I will take questions.
Recommended Trucker Accessories