Introduction:
Increasingly, carriers utilizing Electronic Logging Devices (ELDs) face challenges with unidentified driving events that can lead to violations during audits and investigations. However, by leveraging the exempt driver functionality within the ELD system, carriers may mitigate those unidentified driving events.
Understanding the Exempt Driver Functionality:
All ELD systems come equipped with an exempt driver function, allowing carriers to configure accounts for drivers who may be exempt from ELD usage. For instance, drivers operating under the short-haul exemption within 160 km of their home terminal can be designated as exempt. This designation enables the sharing of ELD-equipped commercial motor vehicles between exempt and non-exempt drivers seamlessly. The Technical Standard. 3.1.3 Configuration of user account exempt from using an ELD: As specified in 4.3.3.1.2 of the Technical Standard, an ELD must allow a motor carrier to configure an ELD for a driver who may be exempt from the use of an ELD. An example of an exempt driver would be a driver driving under the short-haul exemption under current HOS regulations (i.e. specified in regulation as within a radius of 160 km of the home terminal). Even though exempt drivers do not have to use an ELD, an ELD equipped CMV may be shared between exempt and non-exempt drivers and motor carriers can use this allowed configuration to avoid issues with unidentified driver data diagnostics errors.
Implementation and Training:
Drivers and administrators must be trained on how to utilize the exempt functionality in real-world scenarios. Administrators need to activate the exempt function when creating driver accounts, customizing it for specific drivers even if only a few will be using the exemption.
Compliance and Monitoring:
Drivers using the exempt functionality are not exempt from federal Hours of Service regulations but are excused from using a ELD to record the driver’s time. However, they still need to maintain alternative time records that meet regulatory criteria. Drivers must verify their exempt status periodically, as the ELD does not automatically maintain this status.
Challenges of the Exempt Driver Function:
Transitioning from exempt to non-exempt status can pose challenges, especially when the exemption ends, and ELD usage becomes mandatory. Drivers are required to enter time from paper logs or alternative records.
The Technical Standard 4.3.2.2.4 Indication of Situations Impacting duty-/driving-hour limitations: c) An ELD must provide the means to indicate additional hours that were not recorded for the current motor carrier during the current day or the required previous days specified in current HOS regulations:
(1) When this function is selected, the ELD must prompt the user to select one of the following
options:
i. Option 1: additional hours already recorded and reported in a RODS for another motor carrier.
ii. Option 2: additional hours not recorded since the driver was not required to keep a RODS immediately before the beginning of the day.
Conclusion:
The exempt driver functionality within ELD systems offers a valuable tool for carriers with drivers alternating between exempt and non-exempt status. While managing this transition may require additional effort from both drivers and administrators, the benefits of leveraging the exempt driver function for seamless operations and compliance monitoring cannot be overlooked. By understanding, training, and effectively implementing the exempt driver functionality, carriers may avoid unidentified driving events and avoid administrative penalties.
This is a quote from the Transportation and Economic Corridors Annual Report 2022-2023, “Innovation is core to TEC’s mandate. In 2022 ‑ 23, TEC delivered on a range of cutting-edge initiatives.” Cutting edge initiatives and you have professional auditors doing data entry because the computer system doesn’t accept time to the second? Really?
Why is Alberta Transportation paying professional auditors to do hours of manual data entry? I can tell you why!
Professional auditors, who command professional wages due to their extensive experience and education, are currently dedicating hours and hours to manual data entry tasks, highlighting the inefficiency of the current process.
The current system ARC (assessment of regulatory compliance) is designed to accept time entries only in 15 minute increments of an hour (8.25, 8.50, 8.75), which is completely unfeasible and inefficient process in 2024. ELDs (Electronic Logging Devices) record a driver's time in real-time by the second using data from the truck engine (ECM). Auditors are required to look up converted time information from a paper chart and then enter the data into ARC. In 2024 there exists a more advanced and streamlined solution that should be implemented.
During hours of service reviews, a 30-day sample of drivers RODS (Record of Duty Status) is reviewed and recorded. However, the existing computer program, ARC (Assessment of Regulatory Compliance) was not created to handle time by the second. The ARC system requires auditors to refer to a Conversion Chart in the ARC help manual to translate minutes into the appropriate decimal value for data entry. This cumbersome process not only consumes investigative resources but also contradicts the efficiency goals that technology is meant to enable.
Below is taken from the ARC help manual used by Investigator’s and Third Party Auditors (TPA).
All “Hours” fields in the New ARC take time in decimals of an hour only. For proper calculations please ensure the appropriate decimal of an hour is entered in New ARC.
Conversion Chart
Find the minutes you need to enter under the “Minutes” column and beside it in the right side column is the appropriate decimal conversion. Add this decimal conversion to the total full hours and you will have the appropriate time in decimals of an hour to enter in your field.
Consider this - a standard 5-driver audit sample can lead to 450–900 minutes or 7.5–15 hours simply being spent on manual data entry. These 7.5 – 15 hours represents just entering time, if a violation is detected a descriptive narrative of the violation is also required. If every calendar day has a violation, which happens all the time, that is a significant waste of resources. ELD systems generate a CSV files in Excel format that contain all the relevant information needed by Investigators and Third Party Auditors.
It is evident that there is a clear need to modernize and integrate ELD systems into the audit process to streamline operations, improve accuracy, and save valuable time and resources. By transitioning to a more technology-driven approach, the Transportation and Economic Corridors sector can enhance efficiency, reduce errors, and ultimately improve overall regulatory compliance.
Transportation and Economic Corridors could have been a leader in technology based solutions but, shortsightedness in leadership will keep Alberta auditors using a abacus. It is crucial that leadership drive progress and innovation within critical sectors like transportation auditing.
The Federal HOS was amended to mandate that drivers must use a certified Electronic Logging Device (ELD) to automatically record driving and working time instead of a paper logbook. The ELD section of the Federal Hours of Service (SOR/2005-313) (HOS) is 77 and the ELD mandate was fully enforced as of January 1, 2023. It is important to remember the HOS duty status limits (working time) and off duty time requirements did not change.
A driver is never exempt from the HOS duty status time limits but, the driver may be exempt from using a ELD to record time. The driver, if operating under an exemption, must record duty status time using an alternative time record such as a paper log. ELDs have the ability to accommodate exempt and non-exempt drivers, Technical Standard 3.1.3 but, the driver must be trained to use the exempt driver functionality.
It depends, each provider is different but, the costs a carrier should be aware of are: device cost, lease or buy, contract length, data charges, cloud storage and support. A ELD works exactly like a cellphone and just like cellphone contracts need to be reviewed carefully. All ELDs function the same the only difference is the user interface for the driver and carrier. Some ELD providers offer a Federal and Provincial application if you run 2 companies.
ELDs are important because it’s the law, if a driver has a serious incident without a functioning ELD the consequences can be grave for the carrier and the driver. Penalties for ELDs roadside and administrative in audit can get expensive. ELD penalties contribute to negative points on a carrier profile.
Certified ELD devices can be found on the Transport Canada website. Only certified ELDs can be used in Canada. The header page of a RODS contains the ELD Authentication Value, ELD Identifier and ELD Certification ID that confirm the authenticity. Motor carriers need to do required software updates to ensure the ELD remains compliant.
No, Raven teaches motor carriers and drivers how to use the ELD they currently have. We help carriers set up new ELDs to ensure compliance at the start. Raven can help motor carriers set up effective ELD monitoring policies to ensure compliance and limit liability in the event ELD data is needed as evidence.
What do planes, trains and semi trucks all have in common? Regulations to ensure the operators of those vehicles do not work fatigued. The Federal Hours of Service HOS (SOR/2005-313) regulates the amount of time a commercial driver is allowed to drive, be on duty and mandatory off duty time limits. The intent of regulating a driver’s time is an attempt to mitigate the number and gravity of truck crashes by tackling driver fatigue.
All carriers holding a Federal Safety Fitness Certificate (SFC) must follow the Federal Hours of Service (HOS) SOR/2005-313, which includes the mandatory use of Electronic Logging Devices (ELDs) for tracking driver hours (HOS 77). It is important to recognize that some provinces in Canada like Alberta and Manitoba have both federal and provincial SFCs, leading to potential variations in HOS regulations between federal and provincial rules. Example, a carrier with a provincial SFC has no cycle limitations and can be on duty a total of 15 hours a day. A carrier with a federal SFC is limited to 70 hrs in 7 days or 120 hours in 14 days in a cycle and on duty a total of 14 hours in a day. Moreover, some provinces like Alberta did not adopt the ELD mandate for carriers with Provincial SFCs. Regardless of the specific type of Safety Fitness Certificate held by a carrier, all drivers operating regulated commercial motor vehicles are obligated to comply with the relevant Hours of Service duty status limits. This underscores the importance of understanding and adhering to the appropriate regulations to ensure compliance.
The Federal Hours of Service (SOR/2005-313) section 4 outlines the responsibilities of motor carriers, drivers, shippers, consignees, safety officers, dispatchers, and others to help prevent driver fatigue.
They are responsible to ensure a drivers must not drive if:
ELDs record time by the second and track how much time is remaining in a drivers shift. The ELD alerts the driver 30 minutes before a duty status limit is reached, Technical Standard 4.6.4. Drivers and persons listed in Section 4 of the HOS must be trained in the rules of HOS. However, it is no longer imperative to understand the minutia of team split sleeper or deferral calculations because the ELD does and the ELD monitors and alerts the driver to available time.
On duty and driving limits: driving and on duty time is automatically recorded by the ELD. Team drivers must authenticate (log in) to the ELD, (Technical Standard 4.1.4 b). The ELD monitors and calculates time concurrently for team driving conditions such as; team split sleeper berth.
Operating zone is set by the motor carrier during the drivers account creation (Technical Standard 7.46). The ELD will track and alert the driver 30 minutes before a duty status is reached. North of 60 covers three territories: Nunavut, Yukon, and the Northwest Territories. There are no daily limits only work shift limits.
A driver is allowed to defer 2 hours of off duty time to the following day. This allows drivers to obtain two additional driving and on-duty hours in a 24-hour period (Day 1). Then, they can take the required two hours off immediately the next day (Day 2).
The ELD will track and alert the driver to the time requirements ensuring compliance to the regulation.
Certified ELDs are now required for commercial carriers as part of the law. Carriers must understand how ELDs work and how to review the data they generate. Previously, drivers used paper logbooks to track their time, with the burden of accurate recording falling on the driver. Carriers were responsible for monitoring these logs, but they provided historical information. With ELDs offering real-time certified data, it is now the motor carrier's duty to actively monitor drivers through the ELD's features and confirm the accuracy of their records of duty status (RODS). In case of a serious collision, the carrier can no longer shift blame to the driver, claiming ignorance of any violations of driving hours, as they are now expected to constantly monitor and verify compliance using the ELD data.
One of the most convenient features of smartphones is the ability of the phone to adjust time zone to match your physical location. This feature is known as "Automatic Time Zone Detection" or "Automatic Time Zone Adjustment." This functionality ensures that the device's clock remains accurate and synced with the local time wherever you may be traveling. Most of us never think twice about this technology it just happens seamlessly. When you get off the plane and connect to a network, it is magically the correct time.
The Technical Standard allows for a ELD device to be hardwired or a handheld device (smartphone) connected via Bluetooth, Technical Standard 1.3. RODS data is captured in the time zone of the driver’s home terminal, Technical Standard 7.40 & 7.41. If the ELD UTC time does not match the time zone the device is in, by more than 10 minutes, the ELD will record a Timing Compliance Malfunction, Technical Standard 4.6.1.3. If a driver has the ELD on a smartphone and does not disable the Automatic Time Zone Detection or Automatic Time Zone Adjustment function of the phone, the ELD will record the Timing Compliance Malfunction when the time zone changes.
1. Download the ELD on a tablet and disable the Automatic Time Zone Detection or Automatic Time Zone Adjustment function.
2. Disable the Automatic Time Zone Detection or Automatic Time Zone Adjustment function on the driver’s smartphone but, be prepared the driver will be late or early for everything.
Having a ELD on a driver’s smartphone is convenient but, comes with other implications. Every trucking company needs to decide what ELD application works best for them. Speak with your ELD provider about your business to determine what solution will work for you.
Drivers of commercial motor vehicles are subject to roadside inspections and NSC Standard 15 audit inspections. If a driver or vehicle is placed out of service, the driver and/or carrier would be subject to a written warning, tickets and/or points on the Carrier Profile. If the non-compliance is serious the driver and/or vehicle would be placed Out Of Service (OOS) until corrected. These are considered HOS violations. Not all provinces and territories follow the Federal Contraventions Regulations (Schedule XVIII): SOR/2023-137, which means that penalties for violations can vary depending on where the violation occurs. The penalties outlined in the contravention regulations are different for the driver and carrier involved in the violation. Specifically, carrier penalties are set at double the amount of driver penalties in order to ensure that responsibility is appropriately distributed between the driver and carrier.
77 (1) A motor carrier shall ensure that each commercial vehicle that it operates is equipped with an ELD that meets the requirements of the Technical Standard and shall ensure that it is mounted in a fixed position during the operation of the commercial vehicle and is visible to the driver when the driver is in the normal driving position. Contraventions Regulations (Schedule XVIII): SOR/2023-137 suggested penalty is $1000.00.
How to avoid: Install a $20.00 magnetic cell phone holder if the ELD is on the driver’s phone and not a wired connection.
77 (7) The motor carrier shall ensure that each commercial vehicle that it operates carries an ELD information packet. Contraventions Regulations (Schedule XVIII): SOR/2023-137 suggested penalty is $600.00.
How to avoid: Ensure each CMV contains an information packet that contains; (a) a user’s manual; (b) an instruction sheet for the driver describing the data transfer mechanisms supported by the ELD and the steps required to generate and transfer the data with respect to the driver’s hours of service to an inspector; (c) an instruction sheet for the driver describing the measures to take in the event that the ELD malfunctions; and (d) a sufficient number of records of duty status to allow the driver to record the information required under section 82 for at least 15 days.
77 (8) The motor carrier shall ensure that the driver records the information related to their record of duty status and the driver is required to record that information in a complete and accurate manner.
78.1 A motor carrier shall create and maintain a system of accounts for ELDs that is in compliance with the Technical Standard and that (a) allows each driver to record their record of duty status in a distinct and personal account; and (b) provides for a distinct account for the driving time of an unidentified driver.
Technical Standard 4.1.5 Non-Authenticated Driving of a CMV
87 (1) A motor carrier shall monitor the compliance of each driver with these Regulations.
Contraventions Regulations (Schedule XVIII): SOR/2023-137 suggested penalty 77(8) is $500.00 for the driver $1000.00 for the carrier. 78.1 suggested penalty is $1000.00 for the carrier. 87(1) suggested penalty is $2000.00 for the carrier.
How to avoid: Carrier to assign all unidentified time.
Technical Standard 4.6.1 Compliance Self-Monitoring, Malfunctions and Data Diagnostic Events Table 4
86 (3) No motor carrier shall request, require or allow any person to, and no person shall, disable, deactivate, disengage, jam or otherwise block or degrade a signal transmission or reception, or re-engineer, reprogram or otherwise tamper with an ELD so that the device does not accurately record and retain the data that is required to be recorded and retained.
Contraventions Regulations (Schedule XVIII): SOR/2023-137 suggested penalty 86 (3) is $2000.00 for the carrier.
Data diagnostic events: Table 4 Technical Standard
(Code 1) Power Data Diagnostic Event: Problem ELD is not fully powered/functional within one minute of the vehicle’s engine receiving power. How to avoid: Plug the ELD in.
(Code 2) Engine Synchronization Data Diagnostic Event: Problem the ELD loses ECM connectivity to any of the required data sources and can no longer acquire updated values for the required ELD parameters within five seconds of the need. Connectivity must be maintained while the vehicle is powered on. How to avoid/ fix the connectivity where the ELD loses ECM connectivity to the required data sources, you can try the following steps:
(Code 3) Missing Required Data Elements Data Diagnostic Event: Problem there are missing data elements (like GPS location) in the ELD event record. How to avoid: Instruct drivers to input missing information when ELD prompted.
(Code 4) Data Transfer Data Diagnostic Event: Problem the internal monitoring of the data transfer test fails and is unable to send the output file data. How to correct: consult with technical support
(Code 5) Unidentified Driving Records Data Diagnostic Event: Problem there is over 30 minutes of unidentified driving time for the vehicle over the last 24 hours. Unidentified Driving Records Data Diagnostic Events will clear when the cumulative time for unidentified driving is less than 15 minutes. How to correct: Assign all unidentified driving time.
Technical Standard 4.6.1 Compliance Self-Monitoring, Malfunctions and Data Diagnostic Events Table 4
(Code P) Power Compliance Malfunction
(Code E) Engine Synchronization Malfunction
(Code L) Positioning Compliance Malfunction
(Code T) Timing Compliance Malfunction – Drivers using a smartphone as a device must disable the Automatic Time Zone Detection or Automatic Time Zone Adjustment.
(Code R) Data Recording Compliance Malfunction
(Code S) Data Transfer Compliance Malfunction
How to avoid: Malfunctions occur when Data Diagnostic Events are not corrected, fix the data, avoid the Malfunction. When a Malfunction is detected, the driver is to stop, switch to paper logs and follow the Malfunction criteria 78 (2)(3)(4).
That’s my top 5 and the easiest to avoid and correct. In my experience 75% of issues are driver training and safety officers not understanding how ELDs work. It’s not the device, the ELD records data, the ELD does not interpret what that data means. With ELDs providing a digital record of a driver’s activity it is important for carriers to recognize the level of liability that entails if your driver is involved in a serious incident.
Ensuring that motor carriers have appropriate safety ratings is a crucial responsibility of regulatory authorities overseeing transportation. The presence of unsafe and unfit carriers on the road poses significant risk, not only to the drivers and personnel directly involved, but also to the general public. The consequences of accidents involving such carriers can be severe, leading to injuries, loss of lives, property damage, and environmental hazards.
There is a real and probable risk that federally regulated Alberta carriers have been upgraded to a Satisfactory or Excellent safety ratings using unreliable audit scores. The Province has been made aware of this, yet has taken no action to correct it, putting the Province at serious risk of liability.
The Alberta government is permitting private third-party auditors (TPAs) to use encrypted Record of Duty Status (RODS) for conducting NSC Standard 15 Audits. There are concerns about the validity of the audit results because encrypted data was used to conduct the audit. The specific concern is that encrypted RODS may lead to inaccurate and unreliable hours of service scores, which significantly contribute to the overall audit score, potentially rendering the entire audit ineffective.
Any federally regulated carriers in Alberta that have undergone an NSC Standard 15 audit by a TPA since January 1, 2023, should have their audit fees refunded, administrative penalties and conditions repealed, and their safety rating rescinded to preaudit status.
In 2021, Transport Canada updated the Federal Commercial Vehicle Drivers Hours of Service Regulations (SOR/2005-313) to include Electronic Logging Devices (ELDs), (Section 77), and also refers to the Technical Standard, developed by the CCMTA. All certified ELD devices must meet the Technical Standard.
The Technical Standard requires all ELD systems to generate standardized ELD output file (CSV and PDF) and transfer those record of duty status (RODS) to an authorized safety official upon request (System Design 1.4 d). The Technical Standard specifies the minimum data required to be included on the standard ELD output file (CSV and PDF) (System Design 1.4 e). For a TPA to audit RODS that fully meet the Technical Standard, the RODS must be sent via one of the transfer methods specified, and in the manner specified in Technical Standard 4.8.2 ELD Output File. Data must be transmitted via:
Transport Canada compiled a list of email addresses for inspectors authorized to have PKI encryption keys. PKI is an acronym for public key infrastructure, which is the technology behind digital certificates. A digital certificate fulfills a similar purpose to a driver’s license or a passport – it is a piece of identification that proves your identity and provides certain allowances.
When a government safety official receives the RODS from a trucking company, the RODS are unencrypted, via PKI, because government enforcement officials have the encryption key. TPAs do not, because they are not designated as inspectors. This is a critical gap in the auditing process when a trucking company transmits encrypted Record of Duty Status (RODS) to a government-certified TPA. The TPA cannot access all the required data for a comprehensive audit.
TPAs do not have encryption keys primarily to protect driver privacy during periods of personal conveyance. Driver privacy is paramount and there is a Technical Standard specific to that end (Technical Standard 4.7.3 Privacy Preserving Provision for use during personal uses of a CMV).
To compound the issue, TPAs are not required to retain the RODS reviewed in an audit, therefore previous audits cannot be reviewed to ensure correct RODS were used.
Both of these factors raise significant concerns about the transparency and accountability of Third-Party Auditors (TPAs) in the auditing process, particularly regarding the handling and verification of unencrypted Record of Duty Status (RODS) data. If there is no mechanism to confirm whether TPAs are using unencrypted data and no requirement for them to submit evidence for retention, it creates a potential vulnerability in the accuracy and reliability of audits.
Private industry is aware of the problem to some degree. Private Motor Truck Council of Canada (PMTC) president Mike Millian said in a 2022 press release:
“We are also waiting for a PKI vendor and system to be announced by Transport Canada that allows for ELD data to be transferred securely from the device to enforcement personnel, as well as enforcement protocols, training, and how the regulation will be enforced uniformly between jurisdictions.”
In June 2022, the CTA (Canadian Transportation Association) released information via email regarding the PKI system:
“Encryption of Record of Duty Status Email Files
The process for establishing the encryption of records of duty status (known as PKI) for email transfer to Roadside officials is the responsibility of Transport Canada. The process for implementing the Transport Canada work is the responsibility of each provincial and territorial jurisdiction, which includes submitting email addresses of enforcement officials who will be engaged in hours-of-service enforcement. The requirements and format for ELDs to produce the encrypted record of duty status are contained in the ELD technical standard, which is the result of a collaborative effort between Transport Canada, representatives from all provincial and territorial governments and ELD vendors. Devices certified through the Transport Canada and Standards Council of Canada process will meet the required format for record of duty status.”
As of January 1, 2023, NSC Audits conducted by Third Party Auditors in Alberta can not be considered accurate to a threshold that can be used to assess carrier safety risk.
There is no way to confirm the RODS used by a third party auditor were unencrypted because unlike the government auditors, TPAs are not required to submit the evidence reviewed for retention in the TSIS system. If you compare this to evidence used in criminal matters, if evidence is considered suspect or deficient, it cannot be used to convict. If the RODS used in a Third Party Auditor audit are suspect or deficient, the information cannot be used to assess an administrative penalty, condition or SFC rating.
Recommendations
There are two possible resolutions to the issues at hand.
Recommendation 1
A simple three-part solution exists to mitigate and correct the issues at hand.
Recommendation 2
Designate government-certified TPAs as “inspectors” which would enable them to access the PKI encryption key required to access full and correct ELD RODS datasets. The Federal Commercial Vehicle Drivers Hours of Service Regulations (SOR/2005-313) defines an
inspector as:
(a) a person designated under subsection 3(2); or
(b) a peace officer within the meaning of section 2 of the Criminal Code.
Section 3(2) of the same regulations notes that:
(2) A director may designate inspectors for the purposes of these Regulations.
References
A ELD (electronic logging device) is a device that automatically records information using the CMV (commercial motor vehicle) ECM (Electronic Control Module), truck sensors and GPS trilateration to automatically record driving time. Fun fact, February is Black History Month and we need to acknowledge GPS was invented by mathematician Gladys West who was the second black woman to be hired to work as a programmer for the US Navy. As a CMV is moving the ELD is receiving information from the ECM and comparing that information to GPS position to monitor compliance to the Federal Hours of Service HOS (SOR/2005-313) and the Technical Standard.
A driver’s day in ELD sequence.
The ELD records all the required information from the Federal Hours of Service HOS (SOR/2005-313) and additional device compliance health monitoring in the Technical Standard. The data collected is related to: carrier identification, driver identification, vehicle identification, driver location information at prescribed intervals and each change of duty status, a running and cumulative odometer and engine hours total, duty status totals and ELD identification information.
The drivers’ daily, workshift, cycle and off-duty requirements are continuously monitored, and a driver is alerted within 30 minutes of reaching a duty status limit.
The ELD continuously monitors the device functionality and alerts the driver if any data is missing or there is a connectivity issue. Drivers are prompted to provide missing information if data is not automatically recorded. Drivers are alerted to uncertified RODS and missing data elements. Unidentified driving records must be accepted or rejected by the driver and no other information can be entered until unidentified driving time is resolved, Technical Standard 4.1.5 3).
The data from the ELD is shared between the drivers in-truck device and a dashboard or portal for the motor carrier to monitor the entire fleet. All the data is stored on the cloud for 6 months and can be retrieved by the carrier for inspection. The motor carrier is expected to monitor the drivers continuously using the information generated from the ELD. A driver should never be in a out of service condition for HOS because as soon as the driver is alerted to a problem the driver is supposed to immediately stop and alert the carrier. The driver and carrier are supposed to work together to resolve the issue and if the issue cannot be resolved follow the OOS criteria. The data doesn’t lie and the data doesn’t go away.
