Are Printers needed for EOBRs?


I received a question from a client recently and thought I’d share the response to help clear up confusion about AOBRs (automatic on-board recorders), EOBRs (electronic on-board recorders) and some other related technologies out there.

“I had a driver pulled over yesterday

in Indiana got cited because he did not have a printer in his truck to print off his last 7 days on his EOBR – he was able to SHOW his last 7 days, but they’re telling him that we must have a printer in truck. I checked 395.8k2 about printing but it doesn’t say it is required, so my question is: do we have to supply a printer in all my trucks?”

I don’t know what type of onboard recorders you are using – there are many different models out there that have varying degrees of functionality. So the answer lies in what functionality your model has, and whether or not it complies with 395.15 (that’s where you find the specs for models NOT needing a printer).

Let’s look at the evolution of EOBRs. First, there were ‘computer-assisted logs’. I think that’s what the trooper thinks you have – it essentially corrects bad spelling and bad handwriting and can be a great time-saver, but due to the over-rideable nature of the technology, you would still have to be able to print copies upon demand.

Then, there were ‘AOBRs’ – established by the new-at-the-time part 395.15. It lists several requirements for a logging assistance device to make it so you don’t have to have a printer and you can just show them the screen.

Then there was a proposal for a true EOBR – which would have been a great improvement over AOBRs but for one really stupid reason, the agency had to remove the rule – I think it may have actually been 395.16, from the regulation. There is literally no such thing as a true EOBR.

For now, that’s all there is; you can have a computer-assisted log or you can have an AOBR. Look at your device, read 395.15 and ask yourself; does this device meet this description / definition?
If it meets the requirements, then you don’t have to have a printer.
If it doesn’t meet the requirements, then you have to have a portable printer.
Or you could take a chance….but I will say that a qualifying AOBR is not too expensive.

The next big thing will be ELDs. The agency is still working on the final wording of this new rule; they expect to have something out by April 2015, give or take a couple months. Our ‘best guess’ based on the published notice of proposed rulemaking is that after that, it will be mandatory two years later.

Here’s a shortcut to an article in Commercial Carrier Journal on the same topic:

http://www.ccjdigital.com/fmcsa-clarifies-eobr-display-rule-printouts-not-required-at-roadside/

About DOT Compliance Help Inc
Phone: 847-836-6063 web: www.dotcompliancehelp.com e-mail info@dotcompliancehelp.com DOT Compliance Help, Inc. is a full-service consulting firm specializing in the interpretation and execution of the regulations and guidelines set forth by the US Department of Transportation Federal Motor Carrier Safety Administration. •Mission Statement• To assist our clients in establishing proper safety management controls in order to minimize accidents, injuries, and fatalities. The ultimate goals are safer roadways for the public and increased profits for our clients. Our core consulting competencies include FMCSA Assessments (mock audits), DOT compliance training (on-site and via webinar) and custom safety plans and policies. We also hold DOT compliance workshops and conferences all across the country. Utilizing a proprietary curriculum developed by our President, Mike England, our classes cover everything you need to know about the FMCSRs, how to survive your next DOT Compliance Review, and how Comprehensive safety Analysis (CSA 2010) will affect you. www.dotcompliancehelp.com

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