HOS comment letter
- Thread starter moose
- Start date
moose
Veteran Expediter
docket number FMCSA-2004-19608 or RIN 2126-AB26
Comments for FMCSA proposed HOS:
Comments submitted by CDL holder.
To Fax: 202-493-2251.
• "Driving Window":
= drivers must be able to obtain release from duty 24/7, regardless of carriers working hours.
= Drivers will need to have the opportunity to take safety breaks while under a load.
Drivers are still responsible for the freight in the trailers; no ‘duty’ is required.
= the release from duty latter by the carrier, can be consider by the IRS, as ‘control of a worker time’, which will make all drivers employee’s.
• ”Max. On-duty within driving window”:
= Needs to stay at 14.
= 13 hours window will force OTR drivers to work in different time zones every day.
= The 14 hours window, allow drivers to have a full 24 hours work cycle.
= 13 hours window, will not allow the drivers enough time to take ANY break during the window.
= the 13 hours limitation will force drivers to do the safety inspection by the end of the work shift.
• “Max. driving within driving window”
= needs to stay @ 11
= the last hour of the day is the safes one. Drivers are already behind the wheel.
Forcing drivers off the roads more often during the work week, will create congestion,
Increase travel time and distance, without increasing productivity, which will result in more opportunities for accidents to happened.
= the 10 hours limit, will force more trucks on the hwy, which will result in more congestion, more accident opportunity.
We will simply needs more trucks to deliver the same freight.
• “Limit on consecutive hours of driving”
= finding a place to park a truck in today parking shortage, will make this task impossible in many cases.
Drivers, especially the ones with electronic enforcement, will park their rigs just about everywhere they can, including unsafe places, fuel islands and shippers docks.
This will create the opportunity for road rage and aggressive driving.
= same idea was tried in Europe; they tried 15 min., and failed.
= forcing drivers off the Hwy, will create more opportunity for none injured accidents.
= in many parts of the country, finding a safe place to park, is an exhausting effort,
By the time truckers will be back on the Hwy, they will be all but rested.
=finding parking in the middle of the night, simply won’t happen.
= in many cases ,getting off, and back on the road, will take more than the mandatory rest time, this will reduce productivity, and force more trucks on the road, to deliver the same freight, which will reduce safety.
= drivers that are planning only one stop a shift, will be forcing themselves to drive 7 consecutive hours, rather than taking a rest break when they need to.
Or when they can.
• “Max. on-duty hours”
= please allow drivers to drive 80 hours in 7 days.
This practice will allow more freight to be moved by experience drivers.
As accidents more likely to happen in the beginning of the work period.
• “"Restart”
= we need to go back to 24 hours restart, to allow long haul drivers to work in a weekly, and daily routine schedule.
How can we be expected to be rested, if the restart ends a day and a half after it started?
• “Limits on Restarts”
= IMHO this is the most dangerous items to be considered in the PRM.
For the 1st time the FMCSA is considering taking trucks off the grave yard shift, and forcing drivers to drive during the day.
= professional drivers will ALWAYS refuse driving at night, if this will be the law.
= asking drivers to limit drive/on duty is one thing, forcing drivers to drive when the biological clock say sleep, will force drivers to drive when they are fatigue.
= every person have his own biological daily clock, and most can work with that. Ignoring the daily biological clock, will force drivers to drive, legal, while fatigue.
=the proposed restart will force the same freight to be delivered by more trucks, resulting in safety decreases.
=if a driver biological clock wakes him up at 3am, he will be forced to start his day only a few hours later.
=the once a week designated restart, will take away ALL long haul drivers.
With no added safety.
We must allow drivers to restart when possible.
Limiting drivers rest will always decrease safety.
=many truckers out there are working on a non regulated work week. When they simply cannot plan more than a few days in advanced. With so many unknowns, drivers can never really know what will happen next, and designating a restart will lead for many trucks sitting at a parking spot for days in, with no added safety at all.
• “On-duty time”
= if sitting in the passenger seat can be consider a part of a resting period, then it needs to be consider a part of a resting period at all times.
Not only when the vehicle is moving,
And not only when next to a sleeper berth period.
** The FMCSA have asked the public to submit not only their comments, but also their thoughts.
Here are MY thoughts.
= we must allow the more freight to be moved by experienced, already driving drivers.
=we must allow team drivers more flexibility in controlling their sleep patterned.
It seems like the 5/5 split used to worked well for most.
= we needs to allow more flexibility in splitting rest periods.
=the new HOS needs to be written to accommodate EOBR.
= the new HOS needs to be written with the parking shortage in mind.
Drivers must be able to drive, after completing their duty, toward a ‘safe haven’.
= the HOS needs to allow drivers to take safety breaks when they can, rather than when they are being forced to.
= there seems to be no real data showing safety decrease at the eleventh hours of driving.
= we needs to limit the ‘on duty / driving’ time, not rest periods.
Sincerely:
Name:________________________CDL holder from the state of:__________________
Comments for FMCSA proposed HOS:
Comments submitted by CDL holder.
To Fax: 202-493-2251.
• "Driving Window":
= drivers must be able to obtain release from duty 24/7, regardless of carriers working hours.
= Drivers will need to have the opportunity to take safety breaks while under a load.
Drivers are still responsible for the freight in the trailers; no ‘duty’ is required.
= the release from duty latter by the carrier, can be consider by the IRS, as ‘control of a worker time’, which will make all drivers employee’s.
• ”Max. On-duty within driving window”:
= Needs to stay at 14.
= 13 hours window will force OTR drivers to work in different time zones every day.
= The 14 hours window, allow drivers to have a full 24 hours work cycle.
= 13 hours window, will not allow the drivers enough time to take ANY break during the window.
= the 13 hours limitation will force drivers to do the safety inspection by the end of the work shift.
• “Max. driving within driving window”
= needs to stay @ 11
= the last hour of the day is the safes one. Drivers are already behind the wheel.
Forcing drivers off the roads more often during the work week, will create congestion,
Increase travel time and distance, without increasing productivity, which will result in more opportunities for accidents to happened.
= the 10 hours limit, will force more trucks on the hwy, which will result in more congestion, more accident opportunity.
We will simply needs more trucks to deliver the same freight.
• “Limit on consecutive hours of driving”
= finding a place to park a truck in today parking shortage, will make this task impossible in many cases.
Drivers, especially the ones with electronic enforcement, will park their rigs just about everywhere they can, including unsafe places, fuel islands and shippers docks.
This will create the opportunity for road rage and aggressive driving.
= same idea was tried in Europe; they tried 15 min., and failed.
= forcing drivers off the Hwy, will create more opportunity for none injured accidents.
= in many parts of the country, finding a safe place to park, is an exhausting effort,
By the time truckers will be back on the Hwy, they will be all but rested.
=finding parking in the middle of the night, simply won’t happen.
= in many cases ,getting off, and back on the road, will take more than the mandatory rest time, this will reduce productivity, and force more trucks on the road, to deliver the same freight, which will reduce safety.
= drivers that are planning only one stop a shift, will be forcing themselves to drive 7 consecutive hours, rather than taking a rest break when they need to.
Or when they can.
• “Max. on-duty hours”
= please allow drivers to drive 80 hours in 7 days.
This practice will allow more freight to be moved by experience drivers.
As accidents more likely to happen in the beginning of the work period.
• “"Restart”
= we need to go back to 24 hours restart, to allow long haul drivers to work in a weekly, and daily routine schedule.
How can we be expected to be rested, if the restart ends a day and a half after it started?
• “Limits on Restarts”
= IMHO this is the most dangerous items to be considered in the PRM.
For the 1st time the FMCSA is considering taking trucks off the grave yard shift, and forcing drivers to drive during the day.
= professional drivers will ALWAYS refuse driving at night, if this will be the law.
= asking drivers to limit drive/on duty is one thing, forcing drivers to drive when the biological clock say sleep, will force drivers to drive when they are fatigue.
= every person have his own biological daily clock, and most can work with that. Ignoring the daily biological clock, will force drivers to drive, legal, while fatigue.
=the proposed restart will force the same freight to be delivered by more trucks, resulting in safety decreases.
=if a driver biological clock wakes him up at 3am, he will be forced to start his day only a few hours later.
=the once a week designated restart, will take away ALL long haul drivers.
With no added safety.
We must allow drivers to restart when possible.
Limiting drivers rest will always decrease safety.
=many truckers out there are working on a non regulated work week. When they simply cannot plan more than a few days in advanced. With so many unknowns, drivers can never really know what will happen next, and designating a restart will lead for many trucks sitting at a parking spot for days in, with no added safety at all.
• “On-duty time”
= if sitting in the passenger seat can be consider a part of a resting period, then it needs to be consider a part of a resting period at all times.
Not only when the vehicle is moving,
And not only when next to a sleeper berth period.
** The FMCSA have asked the public to submit not only their comments, but also their thoughts.
Here are MY thoughts.
= we must allow the more freight to be moved by experienced, already driving drivers.
=we must allow team drivers more flexibility in controlling their sleep patterned.
It seems like the 5/5 split used to worked well for most.
= we needs to allow more flexibility in splitting rest periods.
=the new HOS needs to be written to accommodate EOBR.
= the new HOS needs to be written with the parking shortage in mind.
Drivers must be able to drive, after completing their duty, toward a ‘safe haven’.
= the HOS needs to allow drivers to take safety breaks when they can, rather than when they are being forced to.
= there seems to be no real data showing safety decrease at the eleventh hours of driving.
= we needs to limit the ‘on duty / driving’ time, not rest periods.
Sincerely:
Name:________________________CDL holder from the state of:__________________
Moose great job! You have done your homework and I appreciate you posting this.