Electronic On-Board Recorders

NSWMA's comments to the Federal Motor Carrier Safety Administration (FMCSA) about the viability of using electronic on-board recorders to verify compliance with hours of service requirements. NSWMA noted that solid waste and recycling collection trucks currently are local routes under the 100 air-mile rule. As a result, they use time cards instead of the more formal hours logs to verify compliance. Using FMCSA's cost estimates, NSWMA calculated the use of electronic on-board recorders for hours of service compliance would cost the solid waste industry $333,000,000 to retrofit its fleet of 111,000 collection trucks.