RSA Comments on FMCSA proposed Hours of Service Rule
Mar 2nd 2011, 09:01
Co-Founder Steve Owings submitted a common sense response to the complicated new proposal from FMCSA to adjust truck driver drive time rules. In a nutshell, if it's going to make the roads safer, we are for it. But this plan may not go far enough.
Road Safe America/Steve Owings Comment on
Hours of Service Proposed Rule 75 FR 82170, December 29, 2010
Based on data I've seen in MCSAC meetings, it is clear that fatigue is significantly increased after 8 hrs. Also, from other data we've been presented, there is no question but that the "wee hours" are when humans are sleepiest. So we are supportive of going back to 10 driving hours but think that 8 is more humane and safe. Also, requiring the two midnight-to-6am periods for the restart seems reasonable but we'd rather not have any restart at all, like it was before the new rule. Another thing we like is the required breaks. Again, based on data we've heard in MCSAC, this would allow "power naps" which we've been told are very effective.
The mandate filed 1/31 for EOBRs is the best thing happening in this area. Finally, we will be able to look at real drive time data instead of relying on the antiquated and too often fraudulent paper logs.
Additional things that would positively affect fatigue issues are:
-Get the medical examiners properly appointed and trained/accountable
-Require sleep apnea screening and treatment/monitoring
-Provide reasonable systems to help drivers locate good places nearby to rest
-Eliminate the type II drug exception for truck drivers while driving
Opponents say that the new rules will require more trucks on the road. We challenge that claim; there won't be more freight. There will need to be more drivers, though, which is a good thing from an unemployment perspective.
The drivers of large commercial vehicles, we believe, have at least as much responsibility for the safety of the public as do airline pilots. After all, we buy tickets to voluntarily get on commercial aircraft. However, all of us share the public roadways on a daily basis.
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