Fuel for Thought

To PC or Not To PC, That Is The Question

Since electronic logging devices have become the norm and personal conveyance has been a part of the ELD, I have always found it to be the most undefined duty line in my log book. There has always seemed to be a lot of guidance, but not any well defined rules for its use. Each carrier defined what is or is not personal conveyance of a CMV at their own discretion. All of the other duty statuses have well defined terms of use. Off duty is all time spent off duty. Sleeper berth is all time spent in the sleeper berth of the truck. Driving or On duty driving is all time spent driving the CMV. On duty is all time spent performing tasks involving the CMV except for driving (loading, unloading, maintenance, etc). Then there is this new line that we never had on paper logs called Personal Conveyance. There is not a set amount of time or miles that a driver can utilize the CMV for personal conveyance per calendar day. Limits on time or miles may be set by a carrier for their drivers, but it can vary from one carrier to another, some carriers not placing any limits at all on their drivers regarding personal conveyance use. Sure, there has been some guidance from the FMCSA on the matter over the years, but no hard and fast rules, just more guidance year after year. This guidance comes in the form of questions carriers asked of the FMCSA to try to better understand the proper use of personal conveyance in order to remain compliant and reduce OOS (Out Of Service) violations. Over the years, the guidance has changed, but it is still just guidance. 

Recently, the CVSA (Commercial Vehicle Safety Alliance) announced that it will again petition the FMCSA for regulatory requirements for the use of personal conveyance. They have tried twice before to get the FMCSA to set enforceable regulations on the use of PC without success. This time around, they have data from ELDs obtained during inspections to back up their claims of improper use being rampant and the need to set limits on the use of personal conveyance.

The CVSA is  planning to petition for setting a limit of 2 hours of PC per calendar day. They want to prohibit time spent using PC from being counted as Off Duty time. They are also seeking to define that it is not acceptable to continue driving after reaching an hours-of-service limitation to get to a safe haven because there is no available parking (you should just drive in violation to seek safe parking). They are also trying to define yard moves. 

Any regulations that do not have well defined rules are easy for drivers to abuse, knowingly or unknowingly, and difficult for law enforcement to enforce when not clearly defined. A stop sign means stop. A red light means stop. Personal conveyance, well… let’s check the current guidance to see if it is being used properly according to the person interpreting the guidance.

If the CVSA is successful this time around, maybe we will finally get some well defined regulations regarding Personal Conveyance, then you can use it properly. if you need to use it, without fear of being in violation when you thought it was legitimate.

Would you like to see personal conveyance better defined? Do you use it? Do you think a 2 hour limit per day is enough?

A journey is a person in itself; no two are alike. And all plans, safeguards, policing, and coercion are fruitless. We find that after years of struggle that we do not take a trip; a trip takes us. 

-  John Steinbeck

See you down the road,

Greg