UPDATE ON ELECTRONIC LOGGING DEVICE (ELD) MANDATE
The Electronic Logging Device (ELD) mandate is one that just seems to keep going on and on. On the Canadian side of the border, the original technical standard that was produced by the CCMTA was finalised in 2013, after several years of discussions and consultations. The rule was largely based on the FMCSA’S ELD technical standard produced South of the border, with changes made to ensure that Canadian regulations and challenges were dealt with.
The original FMCSA mandate was to take effect in 2012, however was withdrawn and held in abeyance as a result of a court challenge. The FMCSA was ordered to go back to work on the standard before reintroducing it. The US Final rule was again published in December of 2015, with the compliance date being effective December 18th of 2017. Back in Canada, the CCMTA revised its technical standard and reissued it in late 2016. Indications at the time were that the standard and proposed regulation would be posted in Canada Gazette Part 1 by the spring of 2017 (after it was originally indicated this would occur in late fall/early winter of 2016). This would be followed by a 60-day comment period, then published in Gazette Part 2, once comments were addressed, with a 2-year grandfather period before it became law. Here we are in the summer of 2017 and the proposed regulation has yet to be published. Considering how slow things can move up the ladder in government, I guess I should not be surprised… however it is becoming slightly frustrating. It is time to get the standard published in Gazette Part 1 so all in the Industry can view the standard, comment on it, express their concerns, if there are any, and then move to the next phase of the process. On the US side of the border, a recent Senate bill was introduced by Texas Rep. Brian Babin. It looks to delay the implementation of the US rule by 2 years, to December of 2019. Most in the inner circle do not expect this bill to pass….however there are no guarantee’s in politics, especially true South of the border these days.
It is interesting that the latest attempt to delay the legislation in the USA is just that, a delay, it is not looking to get it thrown out, however if their delay tactic works, I assume the challenge portion will follow. I for one hope the tactics South of the border do not influence Transport Canada’s plans on this side of the border. It is well past the time to get the proposed legislation posted in Gazette 1 and get things moving to the next level….another round of delays is not needed, nor warranted, we have been sitting in limbo with ELD’S for long enough.
One thing appears clear for all in the industry to see, it is not a matter of if the ELD mandate comes into effect on either side of the border, but a matter of when.
Mike Millian is the President of Private Motor Truck Council of Canada (PMTC), the only Canadian association dedicated to the interests of private fleet operators. The PMTC provides forums for fleet operators and industry stakeholders to exchange views and resolve issues together, and is at the forefront in representing protecting and promoting their interests. For more info, visit www.pmtc. ca or call 1-877-501PMTC (7682)
This being the case, lets move forward. On that front, one word of advice for carriers out there. If you are a Canadian Carrier who operates into the United States, the law currently states you must have an FMCSA compliant ELD in use by December of 2017. If you are waiting and hoping for a delay, and one does not occur, you will find yourself in a mad dash to make your fleet compliant. This is not a simple flick of the switch, you need to research suppliers, schedule installs, train your Operations, IT and drivers. You will also need to check and verify that your current routes can be completed legally. If you are a Canadian only fleet, you may have a bit more time, with finalised dates not yet known, but it is coming, and likely with in the next couple of years. If you are not already, start researching and start planning for implementation…the government will get this published eventually, and when they do, the lead time may not be what we envisioned.
There have been a number of important updates and changes that could significantly impact parts selection and service procedures when servicing Cummins ISX15 engines.
This engine series has become a very popular power source for over-the-road and vocational trucking applications. With a power range of 430-650 hp, these changes warrant attention, whether repairing an engine or performing a complete overhaul.
“There have been five different changes to the cylinder liner design,” says Steve Scott, director of Technical Support for Industrial Parts Depot (Torrance, CA). IPD manufactures and distributes a broad range of replacement parts for Caterpillar, Cummins, Detroit Diesel, Volvo and Waukesha series engines.
Potential problems include excessive engine parts wear, premature failures, avoidable downtime, and even catastrophic engine damage.
Scott offers five tips that can help fleet specialists and engine rebuilders service Cummins ISX15 engines more accurately and efficiently, and in some cases with added savings of time and costs.
1. Choose updated critical parts:
Cylinder kits are the heart of the Cummins ISX series engine overhauls. Many over-the-road users and engine rebuilders realize the importance of using cylinder kits that reflect the latest design updates. For example, the current update of OE pistons for ISX15 (15-liter, single cam) engines features a special bushingless
design with a closed skirt that is specifically made to work with APR (anti-polishing ring) cylinder liners.
2. Use the special piston installation tool:
Cummins ISX15 cylinder liners feature a removable APR that overhangs the liner bore. To use the piston installation tool, remove the APR ring from the liner, insert the special tool, and then proceed to complete the piston installation. The piston installation tool prevents the piston rings from expanding into the APR ring groove, thus providing a smooth transition of the piston into the cylinder liner. The updated style APR cylinder liner from IPD is induction heat-treated, includes a precision-honed ID, and has an Oe-style APR carbon scraper ring. This liner also comes with a premium brass shim for ease of installation.
3. Protect oil ports and passages from particulates:
Replacement of gaskets is an integral part of every in-frame or out-of-frame engine overhaul. When it comes to servicing ISX series engines, complete gasket sets should also contain a number of small plugs that are used to protect the oil ports of the cylinder head, as well as the cylinder block from dirt or other debris.
4. Choose the correct style of connecting rod bearings:
Cummins ISX series engines use three different styles of connecting rods, making it vital to use the proper type of bearings when replacing these parts. The early engines use non-drilled rods, which do not have an oil passage running through the connecting rod. Later engines use two types of drilled rods, a saw-cut type and a fractured type. These terms refer to the surfaces between the connecting rod and rod cap.
5. Press-in type camshaft bushings:
On earlier ISX dual cam engines, the injector camshafts are massive compared to the valve camshaft, with a journal diameter of 85 mm (3.346 in.), and weighs almost 65 lbs. While it may be a common practice to drive the camshaft bushings in for other engines, installation instructions specify that the cam bushings (injector and valve) need to be pressed in (rather than driven), and also pre-lubricated. According to several cylinder head rebuilders, due to the size and amount of retention (crush) holding the injector camshaft bearings in place, the bushings cannot be driven in without distorting or otherwise damaging them, which can lead to bushing failure when the engine is put into service.
In summary, it is important to review and understand manufacturer updates and changes in order to select the correct parts for your specific application, and also to follow current procedures when servicing Cummins ISX15 engines.