| Data Transfer Methods | As part of the ELD Mandate, drivers must be able to present safety officials with a copy of their records of duty status for the current day and the past seven days upon request. Omnitracs Drive eRODS File Transfer functionality allows drivers to do so using either web services or email, which is available from the HOS Options menu. Drivers must be On Duty and within Bluetooth range of an associated vehicle to use this option. From the Omnitracs Drive Dashboard: 1. You can use the ELD Activities menu of Omnitracs Drive HOS screen to access Driver Logs and select View Logs. 2. When you select View Logs, you will be redirected to the Driver’s Daily Log screen within the compliance application. Select the 3-stacked dot menu in the upper right corner of the HOS Log screen. The HOS Options menu appears. 3. From the menu, select eRODS File Transfer. The eRODS File Transfer screen appears. 4. Select the Web Services or Email field as the appropriate transfer method specified by the enforcement officer. 5. When provided by the enforcement officer, enter the comment in the Enter a Comment (Optional) field. 6. Select Send. A message stating the eRODS file is being processed appears. 7. When the eRODS file transfer is complete, you receive a notification that the file was either sent successfully or that delivery failed. 8. If the transfer fails, attempt a second time. 9. If the transfer fails both attempts, request that the enforcement officer view the records of duty status on the display. |
| Malfunction Notes | If you receive any of the following malfunctions or errors on your ELD device, you must review your records of duty status for accuracy as soon as safely possible. You will be required to maintain paper logs if the malfunction hinders the accurate recording of hours-of-service data (which includes a location at each change of duty status). The Omnitracs ELD device immediately notifies the motor carrier of the malfunction without driver intervention. •Power - An ELD must be powered and function within one minute of the vehicle’s engine receiving power and remain powered for as long as the vehicle’s engine stays powered. • Engine Synchronization - An ELD is required to establish a link to the engine ECM and monitor its connectivity to the engine ECM and its ability to retrieve the vehicle parameters. • Timing - The ELD must cross-check its compliance with the external UTC source and must record any timing compliance malfunction. • Positioning - An ELD must monitor the availability of position measurements meeting the listed accuracy requirements and track the distance and time from the last valid measured point. • Data Recording - An ELD must monitor its storage capacity and integrity and must detect a data recording compliance malfunction if it can no longer record or retain required events. • Data Transfer - An ELD must implement in service monitoring functions to verify that the data transfer mechanism(s) are continuing to function properly. • Other - Any other ELD-detected malfunction such as Bluetooth connection |
| Certifying Statement | Omnitracs has distributed and supported AOBRDs in the marketplace since 1989 and has developed testing processes that would assess all areas of the compliance requirements for 49CFR 395.8 and 49CFR 395.15. We have a quality assurance process that follows the creation of story cards for each section of the ELD Mandate specifications. This QA process has been standard operating procedure for Omnitracs and has increased with the ELD mandate requirements. We have used the ELD Testing document issued by FMCSA as a reference to ensure that our testing parallels or exceeds the requirements. Additionally, tests have been created that evaluate fringe cases that are not included in the FMCSA document. Omnitracs employs automated script testing processes for testing of individual elements to ensure consistent and repeatable testing as well the ability to add fringe case scenarios to ensure that in each section of the ELD Mandate, compliance is achieved. We have modified our product through variance changes in the vehicle ECM, changes by OEM and SAE standards, and maintained compliance to ensure that we are continually able to supply information from the ECM. This has ensured that we comply with all the data capture and motion detection requirements specified in the ELD Mandate for the engine ECM. Our testing process includes testing in actual CMV class 6- 8 vehicles as well as using vehicle ECM simulators in testing labs. We additionally use GPS simulators to validate recovery and diagnostics for various situations that can occur in vehicles or environments when GPS may be compromised. With this and other testing processes we are able to test each requirement for diagnostics and malfunctions as required by the ELD Mandate specifications. For eRODS transfer we have provided to Volpe an eRODS test file requested by FMCSA and that file has been accepted. We currently use the FMCSA provided Validator and Web Service access for eRODS transfer to validate the transfer of ELD logs to inspectors as required. Additionally, Omnitracs has developed a 24-Hour monitoring system for eRODS transfer. Omnitracs captures statistics by method of transfer for each individual product certified. This data can be reviewed for various time periods and any failures are identified with the error indicated. We have used this data to notify the FMCSA and Volpe of conditions impacting the transfer process. Omnitracs information security program is based on NIST 800-53 Revision 4. We have ensured that the specified additional security requirements referenced in the regulation for PKI, FIPS, and other NIST specifications have been achieved for compliance to support eRODS transfer. Under penalties of perjury, I, Michael Ahart, hereby certify on behalf of Omnitracs, LLC that the ELD model AMG-C-Android-Drive and its software complies with FMCSA regulations (ELD Rule). |
