Hours-of-Service Proposed Rulemaking

moose

Veteran Expediter
Mark my word . i WILL definitely comment on this proposal .

"DAILY" DUTY PERIOD "
speaking from an OTR trucker POV,
the 13 H limitation will have a drastic effect on my daily routine .
it will force me to do a safety inspection by the end of the day ,instead of the beginning .
since most of my runs are over 2,800 mil. i normally take a break ,once every 2nd load . and run consecutive 11/10/11 .
unlike most out there ,i run my 11 daily ,and at 59 MPH ,it normally take almost 14houres to complete. trying to make it within 13 hours ,will force me to simply either speed up (which i wont ,or not have a 24 hours daily routine - which will make me fatigue no mater how mach time i spent in the sleeper.

the 30 min. mandatory break is unreal in the real world ,you can't even stop for a shower .
it's have being tried and failed in Europe (they tried 15min.).
the main problem in EU was drivers getting back to the truck after on duty time ,and forced to simply seat in the truck before they can start the engine to pull away from the dock .
it will force trucks to look for parking where parking is simply not available .at best it will take a trucker 45 min. to an hour to find parking in the middle of the day ,so the off duty clock can be started .
truckers will have to start pulling off the hwy after only 6 hours .
in today parking availability ,being in full compliance with this rule simply won't happens .
seance most none injury truck accident happened getting in or out of the hwy and in or out of parking lots ,(remember reading this at the ATA website some years back) ,this role will increase non injury truck accident ,and increase truck traffic in and around already limited and crowded trucks parking area .tangle that with the 13 hour limitation ,and trucks will simply speed up to make up for lost time .
drivers will be forced to spend needed limited allowed driving time looking for parking .
by the time they will be back on the hwy ,they will be all but rested .

the :" with release from duty required at end of driving window"
requirement is very troubling ,if it's need to come from the carrier (the one holding the DOT # and accountable for safety).
as most of the freight in our trailers must be guarded 24/7.
it's also have a very troubling privacy and contract issues ,as my carrier treat me as fully independent . i am 'on my own' delivering the freight ,which normally takes about 5 days ,in which they never hear from me .
i am an independent ,i have being contract to do my job ,it is up to me to be on time for the delivery . calling the carrier for release from duty every end of driving period will simply force long haul freight to be delivered by either team or multiple regional solo's .with no added safety .

as sated ,at this time i do not understand how the new "DEFINITION OF ON-DUTY TIME" will apply to 'guarded loads' as mach of the freight i was contracted to haul is simply that .

i have a 'ready to be installed' RV toilet ,that will be placed where the jump seat used to be come spring time . and wondered how that can be logged off duty . if that's not a daily exhausted duty then why we even have HOS ...

is this a new beginning ? are we expecting to see more of terry ?
 

moose

Veteran Expediter
During the listening sessions they said that they heard the drivers asking for flexibility, well it seems we can see how well they listened.
Youbetchyha ,this proposal will only serve the ATA and lawyers .
it will make compliance almost impassible (paper or electronic ).and will force more freight to be moved by large carriers.
this is not about safety ,it's about money and control.
 

nightcreacher

Veteran Expediter
This new proposal is going to kill the income of the solo driver,us teams will work around it.In any event,can't see how this is going to help safety.
 

melanieanne

Seasoned Expediter
We dont have to worry about that. We get the good loads.
so we dont have to run hard. We never have to use all our hours. Just like Paul & kathy of Mr White. We get the good stuff.
 

TeamCaffee

Administrator
Staff member
Owner/Operator
Here is the addresses to submit your comments or thoughts:

ADDRESSES: You may submit comments, identified by docket number FMCSA-2004-19608 or RIN 2126-AB26, by any of the following methods

• Federal eRulemaking Portal: Regulations.gov.

• Fax: 202-493-2251.

• Mail: Docket Management Facility (M-30), U.S. Department of Transportation, West Building Ground Floor, Room W12-140, 1200 New Jersey Avenue, SE, Washington, DC 20590-0001.

• Hand delivery: Same as mail address above, between 9 a.m. and 5 p.m., Monday through Friday, except Federal holidays. The telephone number is 202-366-9329.

To avoid duplication, please use only one of these four methods. See the "Public Participation and Request for Comments" portion of the SUPPLEMENTARY INFORMATION section below for instructions on submitting comments.

FOR FURTHER INFORMATION CONTACT: Mr. Thomas Yager, Chief, Driver and Carrier Operations Division, Federal Motor Carrier Safety Administration, U.S. Department of Transportation, 1200 New Jersey Avenue, SE, Washington, DC 20590, (202) 366-4325.

What do we want changed and to what? One comment they are asking for is driving 10 hours or 11 hours. If nothing else comment on that.

We are our own worst enemy and we do not like to take breaks. I know when I had my 9 to 5 job if I had not had my two breaks in my work day I would have raised heck now that I am being told I HAVE to take a break I am not very happy.

I think the restart will be very difficult for teams as the FMCSA wants us to change our sleep patterns which will lead to sleepier drivers.

I hope someone who is a better writer then me might post a sample letter that we all could personalize and get in the mail.
 

jjoerger

Veteran Expediter
Owner/Operator
US Army
Has anyone posted a sample letter yet?
If we had a good one we could copy and edit it then send it on.
 

nightcreacher

Veteran Expediter
Thanks Terry. I see they didn't do anything to let teams go back to driving 5/5 as many had thought.

I put a comment in having to do with the split sleeper rule,explaing why we should be back in the 5 and 5.From what comments I'vr read,no one is saying anything about the old 5 and 5.WE need more people commenting on this issue
 

diehard76

Seasoned Expediter
Make sure you get your voice heard i did Panther has link to leave comments to the feds some good reading to
 

gotta go

Veteran Expediter
I've got a question for teams about the 34 hour restart and don't know if I can ask it so it makes sense.
Can one driver start their 34 hour break while the other driver is driving? That way a team could now do a 34 with the truck only parked for 24 of the hours.
I want to make one of my comments about the parking shortage that would be exasperated by the mandatory midnight to 6 periods. Plus that portion reduces the opportunity for trucks to avoid the heavier travel hours making accidents more likely.
 

cheri1122

Veteran Expediter
Driver
Good points, Jeanie. But nothing has really been done to alleviate the parking shortage, so I don't expect they'll change their mind for that.
They can't seem to shake loose from the 'one size fits all' model, ie: everyone drives OTR, beginning their workday in the morning, ending at night.
We are square pegs forced into round holes by the rules, when we drive at night, and sit during the day. An excellent remedy to both congested roads and parking shortages that ought to be facilitated, rather than made harder to do.
 

layoutshooter

Veteran Expediter
Retired Expediter
It is all about the money, as in who is buying these bums off. It is really hard to win when the deck is stacked against you. Politics is all about who buys who and this is all about politics.
 
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