ELD Self-Certification, Part I: Is a Self-Test Really a Test?

As the FMCSA’s electronic logging device (ELD) mandate draws closer to its December 18, 2017 implementation date, confusion is stirring around what it means to be a FMCSA certified ELD solution provider. Some of this can be attributed to the certification process itself. Since the FMCSA has not fully developed their own criteria for testing an ELD solution, providers are being asked to self-certify their solutions. One would think with a major government mandate, a major government entity AND a major industry, the registration process would be fairly strict and extensive.

Instead, as show in the below screen capture from the FMCSA’s website, four steps is all it takes to become an FMCSA registered ELD solution provider:

As listed in this registry, currently, only a small handful of providers have self-certifiedtheir ELD solution and registered.

A couple of items stand out:

1. At the top of the page it clearly states, These devices are self-certified by the manufacturer and not by the Federal Motor Carrier Safety Administration.
2. The list of names is not very extensive. However, it’s more the names that are NOT on the list that are a curiosity. Strangely, not one of the major players in the telematics industry can be found on the list, most notably, JJ Keller, the most recognized name in the industry whose entire existence depends on providing DOT compliance solutions.

So why aren’t the major telematics providers and JJ Keller on the registry?

At this point, the FMCSA hasn’t defined all the aspects of how they will police the ELD rule. The current log jam concerns unanswered questions about how the ELD logs will be transmitted to DOT officials, and this uncertainty has led to delays.

How difficult is it to self-certify? The self-certification process varies, but all that is required is to check off the current list of requirements published by the FMCSA, run a few tests, and register with the FMCSA. The rigor and extensiveness of the testing is up to the provider.

The US government had a similar certification process in place with EPA emissions in which automakers were allowed to perform their own testing for emissions. In a highly publicized story, a major automaker was caught and admitted to creating a cheat in order to certify their vehicles.

While this example may be rather dramatic when compared to the ELD situation, it is definitely a cautionary tale to providers to not take short cuts, and for buyers to really do their homework.

Next week, we will provide a follow-up blog that helps buyers identify what to look for in an ELD solution provider.