The Truckload Carriers Assn. delivered a letter to FMCSA Acting Administrator Annette Sandberg earlier this month, voicing concerns over the new hours of service regulations.
Specifically, TCA urged support for two industry petitions requesting FMCSA to reconsider its requirement that the 14-hour period during which drivers would be permitted to work each day must be consecutive hours.
The letter was in response to TCA member concerns regarding the 14-consecutive hours requirement in the new HOS regulations.
The two petitions TCA supported were filed by Wal-Mart and the Arizona Public Service Co. Both requested FMCSA to change the 14-consecutive hours requirement to 14 cumulative hours. In expressing support for such a change in the final rule, TCA told FMCSA that implementation of the consecutive hours requirement would undermine safety, "by taking away rather than creating an incentive for those non-sleeper berth drivers to pull over and take a short rest when they feel it is needed.
"In other words, by requiring the time clock to continue running no matter what, the final rule will actually induce drivers to continue driving even when it may have been more prudent for them to stop."
TCA's letter further described "the disincentive [the consecutive hours requirement] will create for a driver to pull off the highway and eat a relaxing meal . . . [and would instead] promote the same unsafe conduct in truck drivers that has become so extremely commonplace among automobile drivers -- eating in their vehicles while driving."
TCA also told FMCSA that while it "may believe and have intended for the increase from 10 to 11 hours drive-time to have increased the industry's productivity, whatever productivity gain that specific change could have produced will, unfortunately, be offset by the huge pending loss in driver and carrier productivity that the 14 consecutive hours requirement will cause."
TCA cited, by way of example, "the significant wait times [drivers experience] at many of the loading and unloading docks across the country" and pointed out that "carriers have little, if any, ability to prevent these delays from happening or to minimize their duration." Finally TCA told FMCSA that, "by allowing the driver the freedom and discretion to take a rest break when the driver feels one is needed, take care of personal needs, and also eat a relaxed meal without being financially punished because of the rigidity and inflexibility of the 14 consecutive hours requirement, the requested change to the final rule [from consecutive hours to cumulative hours] would actually increase both productivity and improve highway safety and also help to reduce driver fatigue."
Specifically, TCA urged support for two industry petitions requesting FMCSA to reconsider its requirement that the 14-hour period during which drivers would be permitted to work each day must be consecutive hours.
The letter was in response to TCA member concerns regarding the 14-consecutive hours requirement in the new HOS regulations.
The two petitions TCA supported were filed by Wal-Mart and the Arizona Public Service Co. Both requested FMCSA to change the 14-consecutive hours requirement to 14 cumulative hours. In expressing support for such a change in the final rule, TCA told FMCSA that implementation of the consecutive hours requirement would undermine safety, "by taking away rather than creating an incentive for those non-sleeper berth drivers to pull over and take a short rest when they feel it is needed.
"In other words, by requiring the time clock to continue running no matter what, the final rule will actually induce drivers to continue driving even when it may have been more prudent for them to stop."
TCA's letter further described "the disincentive [the consecutive hours requirement] will create for a driver to pull off the highway and eat a relaxing meal . . . [and would instead] promote the same unsafe conduct in truck drivers that has become so extremely commonplace among automobile drivers -- eating in their vehicles while driving."
TCA also told FMCSA that while it "may believe and have intended for the increase from 10 to 11 hours drive-time to have increased the industry's productivity, whatever productivity gain that specific change could have produced will, unfortunately, be offset by the huge pending loss in driver and carrier productivity that the 14 consecutive hours requirement will cause."
TCA cited, by way of example, "the significant wait times [drivers experience] at many of the loading and unloading docks across the country" and pointed out that "carriers have little, if any, ability to prevent these delays from happening or to minimize their duration." Finally TCA told FMCSA that, "by allowing the driver the freedom and discretion to take a rest break when the driver feels one is needed, take care of personal needs, and also eat a relaxed meal without being financially punished because of the rigidity and inflexibility of the 14 consecutive hours requirement, the requested change to the final rule [from consecutive hours to cumulative hours] would actually increase both productivity and improve highway safety and also help to reduce driver fatigue."
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