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Using EOBR To Solve Compliance Issues? Ask Before You Buy!

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by Dave Gray, Glostone Trucking Solutions

Electronic On-Board Recorders (EOBR) can be a very viable answer to the time, expense and frustration involved with being in compliance.  Most EOBR systems market themselves as being compliant with the Federal Motor Carrier Safety Regulations regarding Hours of Service and driver logs.  Many also say their data can be used for International Fuel Tax Agreement (IFTA) tax reporting purposes.  Before you buy, make sure you have answers to a few key questions.

If you are going to use your EOBR for Hours of Service compliance, ask your vendor “does the unit meet the new FMCSA requirements for an EOBR?.”   If the answer is Yes, you may have a problem.  The FMCSA is currently rewriting the EOBR requirements and have not yet released any details.  An automatic “yes” answer to your question may mean your vendor really doesn’t understand, from a compliance standpoint, what he’s selling.  The correct answer to your question should be “the unit meets +today’s requirements and as soon as the new requirements come out, any modifications necessary will be made to stay in compliance.”

If you intend to use your EOBR data for IFTA tax reporting, many more important questions must be asked.  The correct answer can depend on the type of operation you run.

There is a big difference in the data needed to report IFTA taxes and the supporting data required to be maintained to prove the reporting data is correct.  The data needed to report your IFTA taxes is simply the total distance in each jurisdiction of your fleet and the total fuel purchased in each jurisdiction by your fleet within a 3 month time period.  Most EOBR’s can supply the distance information for the tax computation but there are some that fail when it comes to being able to supply the supporting data required for IFTA compliance.  Carriers who buy EOBR’s without asking these questions may be facing some costly problems during their next IFTA audit.

–      Can detailed trip reports be run using a starting and ending date for each unit?

–      Will the trip report identify the origin and destination?

–      Will the trip report identify the routes of travel?

–      Can the beginning and ending odometer for each unit be produced for this time period?

–      Will the report calculate total trip distance along with distance within each jurisdiction?

–      Will this data be available for the next 4 years in case of an audit?

In an IFTA audit, the auditor must be able to verify the accuracy of the equipment in calculating distance.  An answer of “Yes” to each of these questions provides the auditor what they need for verification.  An answer of “No” to any of these questions can put your company at risk at being out of compliance and cost you money during an audit.

One other important question needs to be asked in relation to accurate fuel and mileage tax reporting before you purchase your EOBR .   “How often does the EOBR record the truck location through a GPS ping?”  For a long haul operation where a truck rarely leaves the interstate, a ping rate of every 20-30 minutes may be acceptable to accurately record the trucks distance in each jurisdiction.  For short haul operations, where trucks spend much of their time on highways and streets, a ping rate of every 1-5 minutes may be necessary to accurately record the twists and turns that can add distance.  Some carriers may have both long and short haul trucks.  Buying an EOBR with a ping rate set for long haul may not be correct for the short haul units.

In an audit, an IFTA auditor will look at your operation, look at how often distance is recorded, and make a determination as to correct distance reporting.  In general, ping rates over every 15 minutes will be looked at very carefully by an auditor.

It’s important to understand the differences in EOBR compliance between the FMCSA’s Hours of Service requirements and IFTA tax reporting requirements.  If you intend to use your EOBR for both of these compliance areas, asking these questions can help you make sure you have the right equipment for your operation.


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