Abstract

The article presents the main stages of the development of systems of accounting and control over the periods of work and rest of drivers, which are established by the acts of the EU (EEC) and the USA. The prospects of technical regulation regarding the introduction of tech-nical systems in the construction of vehicles, the purpose of which is similar to the main purpose of modern tachographs, are described. The main characteristics of tachographs used in EU member states and AETR contracting parties and electronic recording devices (ELDs) used in the USA at various stages of the technical levels of these systems are given. In particular, it’s shown that the prescriptions that are in force in the EU now have a prelim-inary legal basis which was laid down in 1965, and the prescriptions that in force today in the USA – respectively, in 1937. Regarding technical systems, the purpose of which is similar to the purpose of a tachograph, the article provides a description of the block of requirements in rela-tion to general safety introduced by Regulation (EU) 2019/2144. The main features of the transition from recording the periods of work and rest of drivers on paper sheets to registration via analogue tachographs, digital and smart tachographs in the European system and, accordingly, using automatic on-board recording devices (AOBRD) and electronic logging devices (ELD) in USA are presented. In particular, it was highlighted that in the USA the transition from paper sheets to auto-mated registration systems took place for about 30 years, while in the European Union (EEC) it took about 10 years. It is also worth noting that the time difference between the introduction of the mandatory use of automated registration systems in the EU (EEC) and the USA was about 40 years. The requirements of the EU and US acts that apply to the design, functions and characteris-tics of tachographs and ELD devices are given. A comparative analysis of the requirements of the acts in force in the EU and the USA was carried out. This analysis identified differences in the «European» and «American» approaches in part, in particular, the procedures used in the EU, such as the type approval of tachographs and the circulation of cards. Recommendations are provided regarding measures aimed at further improving the level of perfection of tachographs as registration systems for monitoring compliance with social legisla-tion and certain indicators that have an impact on the safety of transportation. Keywords: tachograph, electronic logging device, ELD device, social legislation, periods of work and rest of drivers, AETR Agreement, smart-tachograph.

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