I've heard a lot of talk about the Federal Motor Carrier Safety Administration's new hours of service proposal. It's too complicated, it would harm productivity, it wouldn't improve safety, and so on. But have you told all that to the agency yet?

I was struck earlier this week listening to Larry Minor, associate administrator for the FMCSA, in an appearance on "The Lockridge Report" on Sirius XM Satellite Radio's Road Dog trucking channel, hosted by HDT Contributing Editor Evan Lockridge. After nearly every comment or question from a listener, Minor emphasized the agency's desire to get feedback on the proposal and how it would work -- or wouldn't work -- in the callers' individual operations.

For instance, one driver asked, "What are you supposed to do when a shipper takes more than three hours to unload?"

Minor replied, "This is definitely something that's going to require a fundamental change in the industry, not only with carriers and drivers, but also shippers and receivers. They're going to have to recognize these drivers as professionals, and recognized that we can't have them sitting idle waiting to be loaded and unloaded."

OK, that would be great if that indeed happened. But then Minor added, "We encourage everyone to submit their comments as to how likely they think they could achieve compliance."

Another caller talked about how the proposal to require two midnight-to-6 a.m. rest periods in the 34-hour restart would "devastate" his company's operations. He drives during the week and comes home each Friday between midnight and 3 a.m., leaving out again Sunday afternoon. "It would potentially end us," he said.

Minor, after saying the proposal was based on "reconsideration of scientific and medical information concerning driver work/rest cycles and human circadian rhythms," said, "We recognize this is going to be a difficult challenge for a lot of drivers, but we thought it was something we should propose and seek public comment on it."

When asked why the proposal is so complicated, Minor replied, "We recognize that this is a significant change over what we currently have, and we're hoping through repetition and some of the outreach materials we're going to be developing that folks will realize it's not that big a change. We were hoping that a lot of drivers were already getting a break sometime during the day. And we were hoping that for a lot of the drivers, the 34-hour changes would not pose a tremendous burden on them. But we're open to comments on how extensive a change it would require them to make in their current practices."

So there you have it. Now it's time to make your comments. Go to the FMCSA website and you'll find directions for how to make comments online, or by fax, mail or even hand delivery. Be respectful, and offer specifics on how the proposed changes would affect your operations. How would they affect safety? How would they affect productivity and the health of the business? Don't wait long; the deadline is Feb. 28.

Update: The FMCSA announced today that it is holding an HOS listening session Feb. 17. If you can't make it to Arlington, Va., it will be shared via live webcast.