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 ?
"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 ?