ELD Self Certification In Depth
Stephen G. Eick
We’ve had a number of questions about the FMCSA ELD self-certification process. Almost exactly a year ago, FMCSA published the ELD Mandate requiring mandatory use of Electronic Logging Devices (ELDs) for all drivers that are currently required to prepare hours-of-service records of duty status. For software vendors, such as VisTracks, December 10th was the start of a massive effort to create an ELD compliant solution.
Three Components in an ELD Solution
An ELD consists of three components. Firstly, there is a device that connects to the engine control module on a commercial vehicle and obtains real-time vehicle bus data. We call this a VBUS device. Vbus telematics devices are supplied by vendors such as Digi, CalAmp, Geometris, and many others. Secondly, there is an application which processes vbus data and records driving time. Our application runs on either an Android or iOS device and provides the usual “grid chart” that drivers using paper logs know and love. Thirdly, there must be a “back office” component to the system that provides the capability to send store and send the electronic driving records to the FMCSA in the case of an audit. The VisTracks back office runs on Amazon Web Services.
One of the challenges in developing an ELD solution is FMCSA’s self certification process for vendors. FMCSA provides detailed functional requirements for each part of the ELD system and then provides test cases that vendors, such as VisTracks, must run to self-certify their solution VisTracks has set up an offshore testing team in a low cost country who focuses on certification tests. Each test must be date and time-stamped, performed by a documented member of the testing team, and the result must be recorded along with any comments. Not all of the tests can be performed offshore. Of the 317 test cases 21 must be performed with vehicles here in the USA.
FMCSA Test Cases
The test cases are divided into three chapters:
Chapter 1: Accounts, Inputs and Vehicle Interface
Chapter 2: Processing, Monitoring and Recording
Chapter 3: Outputs and Data Transfer
Sample Test Cases from FMCSA
In total there are 317 test cases that the combination of ELD HOS software and hardware must pass together before a solution can be self-certified. As a software company VisTracks is is hardware agnostic to the diagnostic bus interface, but have to be very careful to test our software independently with every hardware variant. We appear on Page 2 of the FMCSA ELD Solutions list but have a separate listing for each category of hardware we support. We are currently listed with the Digi WVA, Geometris Series 80, and CalAmp 4230 Telematics Devices.
Performing the full test suite takes six to eight weeks, assuming every test passes the first time, which is rarely the case. Then, after every test is passed, we have to submit our results to the FMCSA and eventually, usually several weeks later, a new certified device will appear on the FMCSA website. We have several more telematics devices in the test queue now.
ELD Test Case Results by tester
Some Test Cases Cannot be Completed
Though we have been careful to only certify our software with devices that have been exhaustively tested, there are currently six tests that appear in Chapter 3 of ELD-FUNC-4.10 that we cannot complete because FMCSA has not released the verification web services and software. There is a new requirement that HOS data be send in an encrypted file to a compliance officer in three ways, a direct USB connection an encrypted email or Bluetooth serial transfer. FMCSA has not defined how compliance officers are to read these encrypted documents as yet. Our white label re-sellers can rest assured that we will complete this testing as soon as compliance officers are given the proper tools.
If an ELD vendor is found not to be compliant to all these test cases, they will be notified by FMCSA and have 60 days to upgrade their solution to be compliant or it will be removed from the list. We have noticed that several of the early entrants have disappeared this way.
ELD self-certification is an serious process that must be done thoroughly and with care to ensure accuracy.