TRALA Comments Highlight Concerns With Electronic Logging Device Rule

Yesterday, TRALA submitted comments to the Federal Motor Carrier Safety Administration (FMCSA) regarding its proposed rule to mandate electronic logging devices (ELDs) in commercial trucks where drivers are required to fill out hours-of-service (HOS) documentation. TRALA's main concerns focus on trucks that may be rented to multiple consumer and commercial entities with varying obligations to comply with logging rules. In effect, the ELD rule would require that every truck in a company's rental fleet be retrofitted and equipped with an ELD to ensure compliance, whether or not the rental customer needs to utilize the technology.
TRALA's comments also highlight the potential problems of ELDs collecting data for multiple customers using the same vehicle. TRALA is concerned that rental companies may be tasked with collecting and disseminating driver information to rental customers.  This could create unnecessary liability for the rental company.  According to the FMCSA rule, a portable device carried by the driver is allowed.  However, there is uncertainty as to whether the technology is currently available to develop a platform that is compatible with multiple customers using different technologies and vendors.  
As is often the case, the FMCSA rule apparently assumes that the driver is an agent of the truck owner and that the truck is only operated by one owner and its employees or agents.  In addition to submitting formal comments, TRALA will be meeting directly with the FMCSA to discuss the unique nature of the truck rental industry and the significant problems posed by the proposed ELD rule.
If you would like to view the formal comments TRALA submitted, please click on the following link:
You may also view the TRALA comments on our web site at:
If you have any questions regarding TRALA's comments or the issue of ELDs, please contact Jake Jacoby at or at 703-299-9120.