Our nation's roads are shared by all Americans. City streets or county roads; US highways, state highways, or interstate; our roads are a smorgasbord of vehicle types. This is a website that deals with trucking issues, and few Americans would disagree that America's roads are places for cooperation and understanding.

In the 21st Century, American truckers are struggling to maintain their proud profession, which is beset on all sides with erosion of its integrity.

If you're a trucker, and you're reading this, remember that this issue is for all Americans to comprehend, just as our highways are built for all Americans to use.

OK, we have to take note of restricted routes, weight limits, split speed limits, low underpasses, city ordinances, off limit county roads, tight corners, etc......... Back to the subject at hand............

Hours Of......Service.

HOS rules and regulations are everybody's business, every American. However, truckers are expected to understand them inside and out, and obey them. If you're not a trucker, here's your chance to know something about HOS. You know, the log book; the trucker's logs.

A trucker is restricted to 11 hours of driving, and then the driver must stop. A rest of 10 hours is required, and then a trucker may go. The driving time and the rest time must be recorded in a log book. The log book must be kept current, and it must be presented upon demand to law enforcement officials any time that the driver is on duty.

There are four possible duty statuses in a log book. They are: LINE ONE-off duty.....LINE TWO-sleeper berth.....LINE THREE-on duty driving.....and LINE FOUR-on duty not driving.

HOS rules have been in effect for over 70 years. The stated intent of the rules is to protect drivers and the public at large from the dangerous effects of fatigue upon truck drivers. There have been some changes made to HOS rules over the years, and one of those recent changes is a matter of concern for all Americans. We all drive on the same roads. We all interact with each other on those roads in the way we drive. When something goes wrong, we are all liable to suffer.

Something has gone wrong with HOS rules. Rules that were intended to keep drivers healthy and alert are having the opposite effect.

Split Time.......Also Known As .......Split Sleeper Berth.......AKA.......Split Sleeper Berth Provision...........

Split time means this: Instead of driving 11 hours and resting for 10, a driver may opt to drive for 5 1/2 hours, then sleep for 5, then drive for 5 1/2, and sleep for 5............easy to understand.

It should be no more difficult to understand that split time can be more adaptive.

Using split time, a driver may drive for 6 hours, rest for 3 hours, drive for 5 hours, rest for 7 hours, then drive for 6, etc...... Notice in the above example that the split driving time added up to no more than 11 hours, and that the rest time added up to at least 10 hours.

In fact, split time has always been valid as long as a block of rest was at least 2 hours.........examples: 2 and 8, 3 and 7, 4 and 6, 5 and 5, 3 1/2 and 6 1/2, etc.......

Driving time could be split up in the same way, as long as the total driving time of no more than 11 hours was properly and legally matched by at least 10 cumulative hours of rest, the smallest block of which could be 2 hours.

The split sleeper berth provision was a part of HOS rules until..........October 1, 2005.

The Fourteen Hour Clock.......

For many years, instead of 11 driving and 10 resting, the rules were 10 driving and 8 resting, and no more than 15 cumulative hours on duty, driving or otherwise, without 8 hours of rest before driving again.

In January, 2004, the first comprehensive rule change in many years was enforced. The 10 hours driving and 8 hours rest became the 11 and 10, respectively, and the 15 hours cumulative on duty became the 14 hour clock.....

If this is getting a little confusing for you, congratulations! You have potential as an over the road trucker. It is confusing for all of us until we get used to new rules, which keep getting newer all the time! Please continue. Remember, we all drive on the same roads and not one of us wants anything to go wrong, believe me. This is about all of us.

The difference between the 15 cumulative hours on duty and the 14 hour clock is significant.

The 14 hour clock rule means that once a driver logs on duty, that driver must stop driving 14 hours later, and cannot resume driving until 10 hours rest is completed. It makes no difference what the driver was doing during that 14 hours. The driver may have been off duty and watching TV in a truck stop, taking a shower, eating a meal, etc......

The one thing that would stop the 14 hour clock was bunk time..........until October 1st, 2005.

The stories you are about to read are true.........the names have not even been changed to protect the innocent.

The people you are about to experience are the ones who drive the monster trucks which deliver just about everything you and I need in order to live.

The next time you look up at a big rig, remember your trip to this website. The driver of that rig may be one of the true stories you read here.....................................................


Frank D. Becker - Comments 01/30/2008 PUBLIC SUBMISSIONS
General Comment:
I'm a 58 year old owner operator leased to a carrier. I have 38 years driving experience in vehicles up to Class 8 (and larger at times). My comments are based on my experience operating under several variations of the HOS regs over the years.

I urge the inclusion of a split-sleeper break of less then 8 hours length that can stop the 14 hour clock be made applicable to both team and solo drivers. Most drivers could benefit from the ability to stop and take a nap of just several hours when needed without needing 8 hours of a nap which results in total disruption of their entire working week.

The ability to stop and nap to allow rush hour traffic to dissipate or bad weather to leave the area would only enhance highway safety and help lessen the number of vehicles on urban roads during rush hour periods. The driver's inability to do this now due to having his entire week's schedule become totally messed up due to the 14 hour rule and the inability to rectify that is short-sighted and counterproductive to efforts to improve both safety, driver health issues and traffic clogging. This is obvious and failure to allow a break of less then an 8 hour sleeper break to stop the 14 hour clock will demonstrate to all drivers that strictly cosmetic changes to any HOS rules are the desire in order to molify critics that have no real working knowledge of what's involved in a truck driver's job or workday. I urge you to listen to those who have knowledge of the job gained from experience, people who have to try to live and work safely by whatever regulation devised.

A vast majority of OTR drivers have no way to implement the pie-in-sky desires of the alleged safety groups regarding the theoretical and falacious workday where each workday starts and ends at the same time. Drivers usually have no, or little, control over the main impediments to their acheiving that theoretical consistency in start/stop times of their working day. Shippers, receivers, traffic and weather are the main obstacles to reaching that state of consistency that other workers have grown to expect in the setting of their hours of work. Adding an inflexible regulation regarding when a driver can rest without having his entire week compromised or safety, in fact, adversely affected by following that regulation is counterproductive and demonstrates that safety isn't the actual objective, keeping critics of trucking happy is. Please don't continue that impression to truck drivers by failing to allow a sleep break of less then 8 hours to stop the 14 hour clock. A 2 or 3 hour nap by a driver when he's tired gives the desired objective of not having a sleepy driver at the wheel. The proposed 14 hour rule and what stops that clock doesn't allow a driver to get that desired nap when it's really needed.

The 11 hours driving limit and voluntary 34 hour reset should be kept in force. The critics complaints that it allows a driver to work longer and more hours per week just aren't dealing in the reality of the circumstances. The 34 hour reset allows a driver a longer off-duty period at the end of his week then the old rule, which just has a driver taking off until midnight of his 8th day, then picking up whatever number of hours he dropped from the prior week. Real world application of the regs differ greatly from the theoretical ways they can be applied, which is the world the critics of the reset and 11 hour driving limit seem to be living in.


Charlie L. Snider - Comments 02/25/2008 PUBLIC SUBMISSIONS
General Comment:
With the political pressure to which you have had to acquiesce, you have made it impossible for a Driver in the Refrigerated Trucking business to do their job. Food Distributors all receive in the middle of the night from Midnight until 5AM. You have made it impossible to operate with no flexibility in the Split Sleeper Berth Rule and compounded it by the 14 hour rule. You have us in a nice little box with a bow on top.

The Shipper and Receivers are not going to change how they do business just because you as an agency have decided to impose rules upon us. You are absolutely mandating Falsification of Logs. The FMCSA is the cause of the increase you are seeing in Falsification.This business does not fit into your nice and tidy little scheme. How am I supposed to operate the following day after a delivery at 1AM? The 14 hour rule either completely obliterates the day before the delivery (which I cannot stop and wait 10 hours because I have to get TO the Receiver) or it obliterates the day following the delivery (because of the 14 hour rule and nothing less than 8 hours to extend the 14 hours).

I am 62 years old and have been in Trucking for 12 years. I am actively seeking other employment. I can do something else rather than Trucking. With further regulation such as EOBR's, you will have the opportunity to witness the mass Exodus of experienced drivers. I will be gone by April 1, 2008. That is a guarantee. You have made life absolutely miserable and filled with stress in the trucking business. I will tolerate it no longer.


Lynn B. Carl - Comments 02/25/2008 PUBLIC SUBMISSIONS
General Comment:
The biggest mistake of the HOS rules was taking away the split sleeper birth. Drivers keep saying it, and no one listens, but thats the government isn't it? This I guarentee you has been the cause of many accidents. If a driver is tired, but trying to beat the eleven hour clock, he will continue on, and not take a nap. If you have never drove a large truck OTR, you can not understand this. Taking that split sleeper birth away was one big mistake. If its your wife, or family in the car next to someone who didn't get that nap he needed, hopefully they will survive. Sorry to put it that blunt, but some people just don't get it any other way.


Ron F. Mermis - Comments 02/15/2008 PUBLIC SUBMISSIONS
General Comment:
Einstien was no dummy----He took frequent naps. Stop sleepy drivers---bring back the 2-4-6 hour split sleeper berth break.The rest of the present HOS is ok.


Missouri Department of Transportation, Division of Motor Carrier Services

General Comment:
The Missouri Department of Transportation, Division of Motor Carrier Services partnered with Missouri?s motor carrier industry to comment on the Interim Final Rule on Drivers Hours of Service.

During a recent meeting, MoDOT Motor Carrier Services, several Missouri motor carrier associations and motor carrier industry representatives resolved that both the 11-hour limit and 34-hour restart regulations should remain intact. The existing rules that allow 11 hours of driving time within a 14-hour window from the start of the workday, following 10 consecutive hours off duty (11-hour limit) and the 34 hour restart provision that allows drivers to restart weekly on-duty time limits after the driver has at least 34 consecutive hours off duty (34-hour restart) have not detrimentally impacted safety or motor carrier operations.

However, we have a primary concern with the current rule's inability to allow drivers to safely extend the 14-hour window in conjunction with a split-sleeper berth provision to increase transportation efficiency.

It is important that all parts of the rule include provisions that will make it effective, safe and efficient. The U.S. Department of Transportation's Federal Motor Carrier Safety Administration and National Highway Traffic Safety Administration conducted a multiyear, nationwide study of factors that contribute to truck crashes.

The Large Truck Crash Causation Study examined reasons for serious crashes involving large trucks (trucks with a gross vehicle weight rating over 10,000 pounds). From the approximately 120,000 large truck crashes recorded between 2001 and 2003, a sampling of 963 crashes resulted in 249 fatalities and 1,654 injuries. The study further focused on driver involvement and assigned the c rashes to four critical drivers related groupings. They were driver non-performance, recognition, decision, and performance.

Of particular significance was the driver non-performance category. It included crashes in which drivers fell asleep, were disabled by a heart attack or seizure, or were physically impaired. Fatigue was only cited as a critical reason for a crash in 12 percent of the driver non-performance category.

Other associated factors were collected for each vehicle in each crash. According to the study, the top 10 factors coded for large trucks and their drivers in descending order were:
1) brake problems,
2) traffic flow interruption,
3) prescription drug use,
4) traveling too fast for conditions,
5) unfamiliarity with roadway,
6) roadway problems,
7) required to stop before crash,
8) over-the-counter drug use,
9) inadequate surveillance, and
10) driver fatigue.
Driver fatigue was the least of the associated factors.

Although these comments focus on the FMCSA?s current rule making, serious consideration should be given to future rule making in order to alleviate real world problems with the HOS rules.

Flexibility in the HOS rules has always played a major role in the balance between safety and productivity. Each individual is different and obtains rest in different ways under different circumstances. Each shipment that a driver takes has a particular set of influences that affect that driver?s ability to obtain rest. With so many variables and influences on the driver?s itinerary, the rules should empower drivers to get the sleep they need when they need it. Unfortunately, this is the not the case with the inflexibility of the current sleeper berth provision.

The inability for drivers to select individualized periods of rest presents highway safety hazards. Drivers complying with the hours-of-service regulations are forced to stop wherever they can. As a consequence, truck drivers park on shoulders and entrance/exit ramps. In 2007, the average quarterly number of trucks parked in Missouri rest areas and lots exceeded the average number of available truck parking spaces by 19.6 percent. When designated truck parking is full drivers park anywhere they can including the entrance and exit ramps of rest areas and nearby overpasses. In 2007 over 1,150 trucks parked on ramps within 15 miles of rest areas.

In some ways, the recent changes to HOS rules have taken positive steps towards providing flexibility. However, additional adjustments can make them more conducive to the drivers? real world environment. One possibility to improve flexibility is to offer a true split sleeper berth option. One that does not put the eight hour restriction on the driver or restricts the work day, but would allow him/her to take the ten hours of rest as they need. Doing so would allow continued compliance with the rest requirements and also provide the driver with the flexibility to meet personal rest needs and conform to their itinerary. Focusing on drivers only, the Large Truck Crash Causation Study rated driver fatigue tenth among the top twenty factors attributed to poor driver performance resulting in a crash. We recognize that fatigue is still a major issue, but we do not agree with the new sleeper berth rest option that restricts the driver's ability to reduce that fatigue. Drivers are professionals and they deserve to be empowered with choices on how to obtain their rest.


Robert V. Harsell - Comments 01/30/2008 PUBLIC SUBMISSIONS
General Comment:
The HOS rule disallowing clock stops for naps could stand some sober reconsideration.

HOS rules are deadly if they require a driver to stay on the road when sleepy in order for him or her to meet a delivery requirement.

Disallowing split sleeper berth time and clock stops for naps also encourages driving at maximum speeds. Please consider the following:

If a driver realizes he might not arrive at his delivery destination soon enough to complete a full eight hour clock stopping rest period, he will also be aware of the following consequences:

Although he may get 6 or 7 or even 7 1/2 hours of good, restful sleep before he must sign in at a receiving office, it is worthless, HOS-wise. If he gets several additional hours of sleep while being unloaded, that also is worthless. He will not be legal to take another load until it's too late in the day. He will lose a day's work and be forced to spend another entire day and night in a parked truck, even though he's well rested. The scenario is highly stressful. It is not good for the health. I know because I have lived with it since October, 2005. Nobody, especially an over the road trucker, has enough time in their lives where they can afford to ignore 6 or 7 hours of their time, as if it were worthless, several times a week.

Considering the above, which represents real life trucking under real life conditions, the present HOS rule disallowing split sleeper berth time and clock stopping for naps often places drivers in circumstances where they feel compelled to drive when sleepy (at maximum speed) and park their trucks when they're rested and should be driving.

Furthermore, since October, 2005, drivers often feel compelled to drive through rush hour traffic in population centers instead of taking a rest break and passing through at a more efficient hour. Why? Because their rest break wouldn't stop the clock and they'd not be able to meet a delivery requirement. Real life trucking? If you can't meet delivery requirements, you're out, quickly!

It's easy to suggest that we should all have eight uninterrupted hours of sleep each day, but how many Americans really need it, or get it? Legislating such a requirement for truckers unintentionally leads to the above mentioned stressful and potentially dangerous consequences.

It is highly speculative that legislating eight uninterrupted hours of sleep improves highway safety or driver health in light of the above mentioned consequences of an HOS rule.

Drivers who wish to keep honest and legal logbooks presently have every incentive to arrive at their destination at least 8 hours, not 7 1/2 or 7 3/4 hours before a hard and fast appointment time.

Who would like to share in the responsibility for a lost life where an otherwise responsible trucker pushed the envelope in order to gain the time needed to meet an HOS requirement?

A regulation asserting that eight hours of sleep is safe, while almost eight hours followed by another two or more hours is unsafe, or is unhealthy, is a regulation worthy of further consideration.

A regulatory posture inadvertently ignoring the danger of encouraging maximum speed and the danger of driving while sleepy, is one that needs to be amended.


Virginia L. Ganster - Comment 02/19/2008 PUBLIC SUBMISSIONS
General Comment:
It seems that when drivers ask for something, like a reasonable split-sleeper provision, lawmakers and the public automatically assume that the request is something drivers can use as a loophole to operate outside the law. It seems that people think that truck drivers have no regard for anyone's safety, including their own. The truth, however, is that no driver wants to drive tired and take the risk of falling asleep at the wheel and possibly hurting or killing themselves or others. Let's get past this image of renegade truckers and move on to the reality of men and women just trying to make a living without killing themselves.

In fact, it's quite likely that the vast majority of log book falsification is not due to a greedy desire to make more money in less time, but rather due to a desire to safely make a living.

Whether due to illness, stress, or just a long, boring drive, fatigue can pop up unexpectedly on anyone. When that happens, a driver should not feel forced, either by scheduling pressures, or economic circumstances (loss of pay, loss of job) to push on through that fatigue. With the current rules, the only option left available to those who wish to operate safely without facing economic sanction, is to falsify their log books to allow an additional rest period.

Sleep requirements are not one-size-fits all. Although the FMCSA has attempted to address this issue by offering rules that are designed for optimal sleep time, and added some wonderful flexibility to the rules with the 34 hour restart, it has completely neglected the fact that sometimes people just get tired.

The Hours of Service are intended to protect the public from fatigued truck drivers, as well as to protect truck drivers from abuses by carriers. The way the rules currently stand, drivers have little control over the hours they work in relation to their actual rest needs. With rules that do not allow for split-sleeper berth time, drivers that feel the need to pull over and rest will find that time counted against them. Certainly, they can stop anyway, as most responsible drivers do. In order to legally log such a break, however, a driver must either take a full ten hours off, and lose any driving time they still had available for that day, or lose the length of the rest period.

Considering the tight schedules most of today's freight is shipped on, both options could make for an angry carrier or shipper. Carriers often discipline drivers for not making delivery times, which gives a driver a powerful incentive to skip the much needed nap and push on to avoid getting in trouble.

Truck driving is a risky enough profession without the added challenge, imposed upon drivers by their own government, of having to choose between driving while fatigued or falsifying log books to afford a little extra sleep. A reasonable split-sleeper berth provision is necessary to create Hours of Service that actually promote safety.


Gary B. Hull - Comments 02/25/2008 PUBLIC SUBMISSIONS
General Comment:
I believe the Hours of Service we are currently under are very dangerous. The reason is that it does not give the driver the flexibility to safely do his job. Yes the safety stats are the best they have ever been However, I believe that is because the drivers are taking matters into their own hands. Not because of the rules.

And one issue that has not been addressed publicly is the physiological impact of the rules. Simply stated. If the rules are written and because of the content of the rules he feels he/she is being treated like a 5 year old. He will act like one. If you treat him/her like a professional adult. Most often they will act like one. Professionals do not need a mother to watch over them. They need guidelines to work by so they can do their job safely and get home to their families on time.

And the only change that is needed is so we can split the sleeper berth for both teams and single drivers.


CJ Anderson - Comment 01/02/2008 PUBLIC SUBMISSIONS
General Comment:
I have been a truck driver for 14 yrs, both as single & team operation. I currently drive a dedicated run. My run is 632 miles round trip, I drive out & back to my home terminal. If we do not keep the 11 hrs driving rule I will loose my job as it is. My situation is different than most I have a dissabled husband at home so it is imperative that I keep this job. Driving the 10.5 miles is not hard for me I do drop and hook but I have to wait on my return load. While I am waiting for the return load I take a nap. What is bad is that I have to take that nap in a sleeper and it does not stop the clock and if the return load takes longer then I can not get back to my home terminal before running out of hours(14 hr rule). Not only does it effect the company and customers but it effects me getting back to my husband. Also since I have driven in a team situation the idea of not being able to split the sleeper time is unreal this is not safe. I speak from experience! Not to mention that 10 hours in the sleeper is hard to do. I do not know if other working people would like it if you forced them to work in this manner. There are many situations and circumstances that I could go on about but I feel that until you get out and drive the roads like we do you will not be able to grasp them. The bottom line is not being able to split the sleeper berth no matter what the driving hours are is not safe. My one question to all those out there is do you feel good all the time everday?


David Oberhausen - Comments 01/30/2008 PUBLIC SUBMISSIONS
General Comment:
The only change that needs to be made to the hos rule is to allow us to take a break during our drive time. If we try to take a nap now it counts against our drive time. The drive time clock should stop when we need to take a break.


William C. Johnson - Comments 02/28/2008 PUBLIC SUBMISSIONS
General Comment:
I think the hours of service regulations and enforcement is a total waste of time and resources. As a truckdriver with over 22 years and 2 million plus safe miles I can tell you that the rules are regularly broken by virtually all over the road truckers.

Adhering to these rules forces drivers to drive while tired and to sit when rested. It makes no sense at all. It is certainly not in the interest of safety.

The driver that drives the truck is the one who should decide if and when he/she is rested and ready to drive. There is already a regulation 392.3 that covers ill or fatigued drivers. What should be done is a widespread campaign to inform all drivers of the dangers of being fatigued and that if they should refuse a load because of being tired they won't suffer any consequences from their employer, and that the DOT will stand behind the driver.

Alternatively, instead of an hours of service logbook, how about an hours of rest log? Drivers should have to account for their rest daily, but only required to show 8 consecutive hours in bed whether in a sleeper or in a building. Teams should be able to break their rest period up with a minimum of say 4 or 5 hours. Solo drivers should also be able to break up their time but it should add up to 10 hours.

As a 52 year old driver I am currently looking for work outside of trucking because of the restrictions put on me by the Hours of Service rules.


C.D. Stipp - Comments 02/11/2008 PUBLIC SUBMISSIONS
General Comment:
While leaving the 34 hour restart in place is a good idea, not addressing the need for drivers to stop their clocks during the day, needs to be addressed. Many drivers, myself included, use the ability to stop their daily clock as a way to avoid driving while not fully alert. I would much rather pull over and take a short nap after lunch then force my body to keep going. I have also always found it useful to be able to pull over and wait an hour or so then to keep driving and join all of the four wheelers in rush hour traffic.

Leaving the ability to stop your clock out of the hours of service, you are asking drivers to decide between safety and income. If your mission is to truly make the roads safer, the ability to stop your clock must be put back into the hours of service regulations.


Cynthia Martinez - Comments 03/03/2008 PUBLIC SUBMISSIONS
General Comment:
Please reconsider the split sleeper berth provision in the hours of service rules. The ability to split our time in the sleeper gave us so much more flexibility in getting the rest we need at the time that we need it. Some days you need a break in the straight 11 hours of driving. It gives you options of avoiding rush hour traffic in large cities. It gives you the option of taking a sleep or nap break during bad weather driving.

Not everyone sleeps the same every day. Some days you need more sleep. Some days you don't need as much sleep. Everyday is not a day that you want to spend 10 hours in a sleeper berth.

According to the letter of the law you can't even sit in the passenger seat and have a conversation with your spouse or codriver. That action requires us to log on line 4.

According to the letter of the law you cannot leave the truck for restroom breaks. This action could require you to break the straight 8 hrs rule. We ask you to please reinstate the split sleeper berth rule. It gives us so much more flexibility in a days work where no two days are ever the same. I have 19 years of driving over the road and am considering leaving the industry due to the sleeper berth rule. Staying in that sleeper for that length of time is very stressful. Also driving for 10 or 11 hrs. straight knowing that you have no way of stopping the clock if you need to is very stressful.

Respectfully submitted,
Cynthia Martinez
Fresno, CA

Herbert C. Wilcox - Comments 02/28/2008 PUBLIC SUBMISSIONS
General Comment:
On the HOS FMCSA 2004 19608 The split sleeper berth sould be reinstated and the the rest of the HOS regulations should be left intact. Traing and education of all vehicles sharing the road with large trucks would go a long way since most accidents (70-75%) are caused by the cars. Put the blame with the ones who are the main cause.


Mike W. Collins - Comments 01/17/2008 PUBLIC SUBMISSIONS
General Comment:
Having resisted the original change of the HOS, I have come to enjoy working with the change of 2003. But, with the last change, you took away the ability of a tired trucker to stop his 14 hour workday and take a needed rest. which was the whole reason of changing the HOS in the first place. I implore you to put back in place the ability to extend our workday after a much needed break and to allow us to split the sleeper berths time again. You are forcing truckers to drive while tired, exhausted, and otherwise be unsafe on the roads. For us to be safer, you, the government need to be smarter.


Cynthia Wolfenberger - Comments 02/11/2008 PUBLIC SUBMISSIONS
General Comment:
I would like to respectively ask the Agency to reconsider the requirement of 10 hours in the sleeper berth. My husband and I have driven team for 19 years. We always had plenty of rest under the old rules. No one, driver or not, does things exactly the same way every day. If I was having a rough day, my husband would do a little bit more. If he was having a rough day, I would pick up the slack. As with most team work we each have our job duties. He does more of the strong work and I do the customer service work. That is how a "team" works. Each person has their job. Without the split sleeper berth provision one or the other of us is required to stay in the sleeper for 10 hours. We cannot work as a team. The truck is run as two individual 10 hour operations. We all know that this is not the intention of the Agency. We need some flexibility.

No one person sleeps the same day after day. No one person works the same day after day. No one person does personal hygiene the same day after day. No one person does the same relaxation the same day after day. We need some flexibility.I know that I don't do things the same as I did 15 years ago. Some days I'm faster; some days I'm slower. We need some flexibility.

I would appreciate your consideration in reinstating the split sleeper berth provision. Any other rule that you have in effect can be worked within if you have the fexibility of sleep. Staying within the 70 hours is workable. Staying within the 14 hours is workable as long as sleep stops the clock. Driving 11 h ours is not so dangerous as long as you can take a break (even dad and mom and family on vacation take turns driving).
Thank you for this opportunity to express my opinion and thank you for taking it into consideration.

Cynthia Wolfenberger
Concerned, experienced and professional driver


Robert V. Harsell - Comment 02/19/2008 PUBLIC SUBMISSIONS
General Comment:
The HOS rule disallowing split sleeper berth time and clock stops for rest is an issue with implications for all Americans.

Because of its unintended consequences, which have been expressed to the FMCSA in many comments, the rule places the lives of over the road truckers, as well as the lives of other highway users, at risk.

But there's more. There is another danger uniquely implicit to this particular HOS rule; a danger to all Americans; and that danger will be the topic of this comment. The rule is a regulatory incursion into our lives which is not, and cannot be, justified by safety concerns. It effectively allows police intrusion 24 hours a day for every driver as long as he or she is out on the road. Under the rule, police intrusion micromanages the timing of even the smallest detail of life. This problem has been discussed at length in previous comments to the FMCSA.

In this comment I will attempt to illustrate the unique danger of the present rule and I hope that my comment may move others to express themselves to the rule makers.

When America began building our economic infrastructure with the motor vehicle as centerpiece, we may have underestimated, perhaps innocently, the dangers inherent to the developing system. In the 21st century few people are unaware that our highway legacy includes significant loss to life and limb.

The enormity of our automotive infrastructure is closely paralleled by its inherent dangers. We have attempted to attenuate the dangers of our highway system. The vast infrastructure is followed closely by automotive lawmaking, and inevitably by law enforcement.

Perhaps it's best described by a metaphor.

I believe that in creating our highway system, we have created a monster. It has been said poetically that we are a nation of people in love with our automobiles. We are also, with the exception of tee-totalers, a nation of people who like our alcoholic drinks. We are a nation of people on the move, fast. The level of our economy is measured largely by people who want what they want when they want it.

In our desire to have everything we want, including blood free highways, we have placed an unduly heavy burden upon law enforcement.

Every time we pass a law, we do two additional things: One, we place a further burden upon law enforcement officers, and two, we bestow further police powers upon law enforcement officers.

For law enforcement officers, we now have men and women with firearms, tasers, mace, bulletproof vests, etc…. Furthermore, those officers are often supervised by superiors who issue explicit instructions to be aggressive in law enforcement activities. In some states, we already have police with the authority to use a needle on a motorist if, in the officer's discretion, a blood sample is called for. This is an example of what our way of life has cost us in terms of our personal freedom at the hands of our own police.

The motor vehicle can be, and often is, an instrument which opens the door for the expression of many less than admirable human inclinations.

Here comes another figure of speech.

Highway traffic (likewise police intrusion) usually resembles the flow of water. People behave hydraulically. People flow around obstacles in their path like they were water flowing around the boulders and fallen trees in a river channel.

I've heard other truck drivers describe the phenomenon this way: "They're programmed to fill every available hole."

It's true. Whether approaching a traffic light or on the open road, often with their cruise control on, people will drive as if they needed to immediately seize every advantage in traffic. Personal restraint is not exercised. Because personal restraint is not exercised, often at high speed, law enforcement is called upon to provide the restraint.

Here, the same metaphor can be used. By placing a heavy burden upon law enforcement, and imbuing the police with ever expanding authority and weaponry, (weaponry which police refer to as tools) we create another monster.

If we, the public at large, drive our vehicles in such a way that restraint is minimized and opportunity is seized, then what should we expect from law enforcement?

The reference to hydraulics, the movement of water, is one way the phenomenon can be described. Why should police officers, who are often under pressure from higher up be any less human than we who empower them? In not restraining ourselves, we create an opening for a law enforcement officer, who's under pressure, to move in. Then, we have just allowed the fist of law to exercise its authority and power over us. We can only hope that law enforcement officers' restraint is better than our own. However, that which is exercised is that which becomes larger and more powerful.

Police officers are human beings. Here I will repeat what I stated above: "The motor vehicle can be, and often is, an instrument which opens the door for the expression of many less than admirable human inclinations."

When police act out their own less than admirable human inclinations, often withthe approval of their superiors, we have the makings of a police state. The police state creeps upon us and into our lives gradually, usually with our own tacit approval, sometimes at our own request. We need to wake up here and holler.

The HOS rule disallowing split sleeper berth time and clock stopping for rest places drivers in the intolerable position of choosing to either meet a delivery requirement or rest. The driver needs to do both, not choose between the two.

Under the present rule, drivers are placed in a position, by the law, where they are pressured to do things which go against their better judgment. Under the rule, drivers are pressured to forego sleep when they need it most, which can be torturous. Do we really want to have police enforcing this kind of rule?

Remember that the HOS rules have the force of law. Every driver who feels that he doesn't have time to rest, or stop and eat, or shower, or buy groceries, etc….., because of a clock that doesn't stop, will be a driver who will feel police presence twenty four hours a day, pushing him to drive when he's sleepy and ordering him to stop when he's rested.

If we do not correct the present HOS shortcoming that is being discussed here, then we will have allowed law enforcement to enter our lives on a very intimate and personal level, around the clock, dictating not only how much we sleep, but more absurdly, when. Our every move, throughout the entire day, week, month, will be accompanied by the anxiety of police scrutiny. This is how laws and law enforcement behave hydraulically, just like people on the highway, flowing into every available space.

Are you a truck driver? If the above mentioned incursion is overlooked in the case of one class of American, the American truck driver, then how much is your own privacy worth? Would you like to have the police with you 24 hours a day, telling you when to sleep, eat, go to the bathroom, or relax?


Robert V. Harsell - Comments 02/25/2008 PUBLIC SUBMISSIONS
General Comment:
I don't think that there was ever before a good opportunity to comment on the split time issue.

The option of doing away with split time was just one of so many different possibilities when the 2003 regs were being formulated that nobody paid much attention to it.

Also, like the song goes, "you don't know what you got, until you lose it."

When the October, 2005 ruling was effected, it hit us like a ton of bricks, unexpected.

Now we all know what it's like to try and live on the road without being able to stop the clock for naps or sleep when we feel the need. The feds have given us a little taste of just how bad things can really be.

Even though they have indicated that they do not have any intentions of restoring the split sleeper berth provision, or allowing us clock stops for naps, (we need both provisions) this is still an opportunity, the best we've had, to holler about the particularly oppressive rule of October 2005.

The more comments, the better.

Actually, there are quite a few comments informing the feds of the difficulties of living with the present rule disallowing clock stops and split time.

One of my worries is that the feds will allow split time for teams, but tell us solo guys that it's not for us.

Although I have to admit that the present rule hits teams hard, health and safety wise, it also hits us solos hard.

The feds might buy the argument, valid as it is, that sleeping restfully for 10 hours in a moving truck is impossible. The team driver who has been in the bunk then has to face 10 or 11 hours of driving without a rest.

It's easier to visualize the danger with a team situation than for solos, however, solo drivers are also forced to choose between safety and delivery requirements by the present rules.

We solo drivers have to speak now, so that: one, we get the return of safe and sensible HOS rules as soon as possible, or two, if the matter has to go to court, any plaintiffs in our behalf can show the judges the overwhelming comments of drivers who need clock stops and split time in order to operate safely.

Again, here is our chance to work within the system. Now is the time to show that we are sincere about our dissatisfaction with the inherent dangers of present rule. Now is the time to show that we are sincere about our desire to effect change properly within the framework of our society.

If anybody is going to show themselves up to be chumps, let it not be us.

Holler now, strong, loud, and clear.


Gregory D. Reeser - Comments 02/11/2008 PUBLIC SUBMISSIONS
General Comment:
I can live with the new rules. I just want to point out that the split sleeper berth provision gives the driver the flexibility that they need to perform their duties safely and efficiently. Please add this neeeded provision back to the rules. Thank You, Gary Reeser


William W. Park - Comments 02/25/2008 PUBLIC SUBMISSIONS
General Comment:
The hours-of-service rules as they are now need to be maintained but in addition the sleeper-berth rule as it was previously needs reinstated. The present sleeper-berth rule where time in the sleeper does not count toward a break is counter-productive and actually makes drivers more tired because they can not take a 4 hour break, get refreshed and then drive safely. The rules force them to pack driving time in more confined space of time so they may drive even when tired. The sleeper-berth is misunderstood by most and the new rules show how grossly misunderstood it is. It accomplishes exactly the opposite of what is intended.



Matthew D. Pearce - Comments 02/25/2008 PUBLIC SUBMISSIONS
General Comment:
I wish to comment on the final interim ruling allowing drivers to continue using the 11th hour of driving and the 34 hour restart. As a professional driver, I believe that this is the best ruling for everyone. I get plenty of rest when using the 34 hour restart. I believe with the use of this part of the rule, the motoring public is safer as well.


In future discussions on driver's Hours of Service, discussion regarding permitting a solo driver the use of a split sleeper berth option would be of merit. It would be wonderful if a solo driver had the option and could benefit from the use of a split sleeper berth option. There are days when I can drive all day long and not feel tired. However, there are times that we all get a little tired 5 or 6 hours into the trip. It would be much safer for all on the highways (fellow drivers, motoring public, etc) if I could pull over and take a 2-3 hour rest. However, I cannot because my 14 hour clock does not stop. I am forced to drive in a tired or drousy state of mind, creating a potential harm to everyone else out there traveling the highways with me. It would also help a person sitting on a "bad" customers dock where it is not unheard of to sit half a day or better waiting to be loaded or unloaded. When at a customer like this, although one may still be "on duty" as is currently defined in regulations, it is not unusual for most drivers to be resting in the sleeper during this time. Just a thought for future discussions.

Thanks for you time and thank you for thinking about the professional driver moving all your daily necessities across this great country on a daily basis.
Respectfully,
Matthew D. Pearce



Mona Dornbusch - Comments 01/30/2008 PUBLIC SUBMISSIONS
General Comment:
I think that the 11 hour rule and the 34 hour restart need to stay the way they are. But something needs to be done about the 14 hour clock and the sleeper berth. I have been driving for 17 yrs and when the sleeper berth could be split up it was the best. Having to be in the sleeper for 10 straight hours is harder on the body then driving 11 hours. There are days that I would like to take a nap after driving 3, 5 or 6 hours and I cant without messing up my 14 hour clock. I think by adding the 14 hour clock you have made it harder on the drivers. Please look into putting a stop to the 14 hour clock and letting us split up our sleeper time. We are not like other industries and should not and can not be expected to work like others do. Our bodies have become accustomed to things that no other industry can understand



William G. Lisle - Comments 01/07/2008 PUBLIC SUBMISSIONS
General Comment:
Eleven hours of drive time with a fourteen hour work day is not the best when a driver is unable to stop the fourteen hour clock for meals and/or rest periods. The thirty four reset works well for most drivers. I would hate to see drivers go backwards working less hours in such a time sensitive business. I really would like to see a system that would allow to split the sleeper time. So many drivers start their day early morning hours with down time before completion of their work day. Appointments are not always carried out in this industry, which allows for a lot of drivers sitting and waiting for their loads, either delivered or pick up. Drivers that are aware of their own schedule are better suited to allow for proper sleep or down time. The current system creates alot of waiting for the clock to catch up and the driver is more than rested and ready to continue his route for the day or week.


James L. Heiser - Comment 02/19/2008 PUBLIC SUBMISSIONS
General Comment:
The hours of service, as they are now, are great, except for the sleeper birth time. This needs to be more flexable. I know when I get tired, i like to pull over and take a nap, but if I have to run everything out in that 14 hour time period, i can't stop when i get tired. Is there anything that can be done to make the sleeper birth time more flexable? I think this would help the drivers to get the rest they need when they are tired, and not force them to continue to run within that 14 hour time period.
Thank You
James Heiser


Kevin S. Moorer - Comments 01/02/2008 PUBLIC SUBMISSIONS
General Comment:
General Comment:I understand the intention is to make the highways as safe as possible. We have alot of people that I am sure have never driven a truck making policy that effects our livelihood. I appreciate your efforts. Please leave the 11 hour drive time and restart the way it is. With the new tractors being so much improved, I don't believe fatigue is a problem. If you want to help us, please reconsider the 14 hour clock. Not having the ability to stop the 14 hour clock encourages drivers to drive when they are tired.

Thank you for the opportunity to comment.
Kevin Moore


Richard - Comments 02/15/2008 PUBLIC SUBMISSIONS
General Comment:
I would like to take the time to make a comment on the present rules for drivers of commercial vehicles. I am a 15yr veteran over the road trucker. I like the rule in the ways where it allows me another hour of driving, and that I can regain hours to drive by resting for 34hrs..

The problem lies in the rest period, where you have to take the ten straight hours, well you can take 8 then 2, but if you are going to take 8 you might as well take the 10 and be late for delivery or be tired while driving..

The present rule doesnt allow for the rest period to broken up in a manner where a delay that ends up being used as a partial rest break doesnt count for anything.

I recently went to unload my trailer then was called early to load my trailer, there was 4hrs between unloading and loading, then there was 4 hours at the loading facility, I drove a total of 3 hrs, for the whole day and was on duty for 3.75 hrs for the whole day, but when i got to fuel later that evening I had reached my 14hrs and couldnt drive after this.

THis is not right I had rest I felt fine, and well a piece of paper told me to go to sleep so I laid down and couldnt sleep tossing and turning, when time was up for my break I was feeling sleepy so I went and took a shower. I started my day even though I had not rested hardly at all, I have a living to make, and a piece of paper doesnt determine if I need sleep or not or how much at one time.. My goal everyday is to survive to go home to my FAMILY, when it is time for time off. I wish someone really take a look at the rights we are denied here, we pay taxes for everything on this highway there for giving us the rights to use them, to travel on vacation or to earn a living.

I think if the rules would remain the same except makeing nessacary changes to sleeper berth to accomodate shorter rest periods. Removing the 70 hour cap would greatly increase safety on the highway, cause drivers can only drive 11 hours now so they are alreay capped not only that they wont stress themselves out with the daily calculations to see if they can work or if they are going to be stuck out on the road instead of at home...

Thank you for the opportunity to comment on this issue. Have a great day, and please take into consideration that truckers are people with rights too.


Michael A. D'Amico

General Comment:
The current proposed rulemaking eliminates a feature of previous rules that greatly enhanced safety by reducing driver fatique. I'm referring to the ability to stop the 14 hour clock in order to take a short break in the middle of one's driving day. The ability to stop and take a nap for a couple of hours has a great beneficial effect on not only the driver but the public at large. By eliminating this feature, the currently proposed rule "forces" drivers to continue on even though they could benefit from a short break.

Please reconsider and put this feature back in the rules.


D & G Transport, Inc.

Our company appreciates the current hours of service regulations with the exception that a driver is more or less forced to work 14 hours without a break. With the previous laws they were able to take a break or nap and it did not count against their on-duty time. We would suggest that drivers be allowed to take a break or nap during their work day and not have it count against their on-duty time. This makes a much safer driver. We like the 11 hours driving and 14 hours on-duty. We really like the 34-hour restart, which encourages us to get our drivers home to spend time with their families.


Robert E. Gresham - Comments 01/23/2008 PUBLIC SUBMISSIONS
General Comment:
Please, give us drivers the chance to take a break for a nap to refresh us and make us more alert WITHOUT that nap counting against our on-duty time. We should be able to stop and rest when we are tired & sleepy without it counting against us. Right now you have way too many tired drivers because of the current HOS rules. We would all be safer if we could rest when tired and then continue to drive alert and awake instead of just pushing it too far because if we stop to rest; we've wasted on-duty time.

Thanks for your consideration.


Vaugh Mitchell - Comment 01/03/2008 PUBLIC SUBMISSIONS
General Comment:
The current driver regulations are good except they need to add the old split berth regs. the people makeing the regs leave no room for real world job related activities. if a driver is held at a shipper or rec. he should be able to sleep without being penalized by not being able to continue working . you are forceing drivers to run all there driving time together to make any money and in doing so are adding to driver fatigue.V Mitchell Commercial driver


Cynthia E. Wilde - Comments 03/03/2008 PUBLIC SUBMISSIONS
General Comment:
FMCSA-2004-19608
The hours of service as they stand currently have created a host of problems for the driver. First, they 14 hour rule, has made it impossible to take a break when tired, or during peak traffic times, forcing many of us to push through and drive tired and/or falsify our logs. This is unsafe and illegal. I am 54 years old, have been driving since 1973, and while the need for updated regulation has been there. I believe that not having the ability to split sleeper-birth time has created a hazard. The 34 hour portion has been a benefit, if used properly. Some trucking companies have used it as a "time-off" period, so that they run you out of hours (too hard) and then shut you down for "34" to reset. Given to the driver's discretion it is a more useful tool.


Lee J. Kirkpatrick - Comment 01/02/2008 PUBLIC SUBMISSIONS
General Comment:
I would like to comment on the sleeper berth provision of the hours of service. I feel as though without being able to split the time you must be in the sleeper that we are forced to drive longer than we normally would. For instance, if you are coming up on a major city at rush hour and could stop the clock you could take a few hour nap until rush hour was over. This would allow you to miss the heavy traffic, putting yourself and the motoring public at less risk of accidents, and still have hours to make your delivery in a safe and timely manner. Also, if you encounter bad weather or illness you must keep driving in order to have enough hours to make your delivery. I would also like to see shippers & receivers have a time limit to load and unload. the way it is now they can hold a truck as long as they want and we still have to abide by the rules and get stuck in the middle with brokers and dispatchers mad at us. Thank you for taking my comments.


Anonymous - Comments 01/07/2008 PUBLIC SUBMISSIONS
General Comment:
I have driven since 1994 so i have driven under the old rules and the new ones. I personaly like the rules that frist came out 11 driving 10 off but you could split your sleep time. which made it easyer driving in the north east . I drive mainly a north east regional and having the flex abilty to shut down for 3-4 hrs to avoid rush hrs is missed. under the old 10 and 8 i would unld in the am but a lot of times you wouldnt get reload till the after noon so i woud take that miday nap then get my load drivetill early pm then finish my sleep time then get up in early am to make the next am delivery and do iall over again with this 14 hr clock and no split you either have to hide time or get stuck taking 2 days to do a 500 mi run which is not very profitable thancks for your time.


Steve Pollman - Comments 02/11/2008 PUBLIC SUBMISSIONS
General Comment:
I am a single truck company . The non split sleeper berth isn`t a very good idea as only the driver knows when he or she needs rest or meals. Letting someone else do this for us isn`t anything but completely wrong. The 11 hour driving or the34 hour restart isn`t all bad, but we need something changed on the rest and meals!


James D. Lee - Comments 01/07/2008 PUBLIC SUBMISSIONS
General Comment:
As a truck driver w/ 3 1/2 million miles of experience I would like to submit my opinion on the hours of service regulations. The 14 hour rule imposes some very detrimental effects on highway safety for many drivers trying to get their duties completed in each workday and the lack of provision to allow a driver to use a split sleeper berth option only compounds this problem. Without the split sleeper option coupled with the 14 hour rule, many drivers are needing to drive into congested areas. into adverse weather conditions, or simply driving when a 2, 3, or 4 hour nap could allow the driver a refreshment of alertness and allow said driver to continue the trip at a time more suitable for safety and less congestion or possibly better weather and/or highway conditions. By simply reinstating the split sleeper option and eliminating the 14 hour restriction, drivers could once again have the option of using their judgement to manage their trips and workday to utilize their time more efficiently and safely. Many hours and gallons of fuel could be saved by avoiding travel during times of congestion in many of out nation's metropolitan areas.


James K. McKee, Jr. - Comments 02/11/2008 PUBLIC SUBMISSIONS
General Comment:
I have been a professional truck driver for 20+ years now. I believe the 11 hour rule is adequate. The 34 hour restart rule is probably the best thing to come out of the new rules! The rule encourages a long break and I think promotes a rested and safer driver. I think the 14 hour rule needs some work though. As a driver I sometimes get tired during the day. At these times I might want to stop and take a nap to refresh myself, under the old rule I could due this without taking away from my driving time. Under the new rule I lose this time so I am compelled to keep driving even though it would be safer to rest. This makes no sense. These times for me usually fall at about the same time as traffic is the most congested (rush hour). If drivers could pull over and stop during the times, by stopping the clock, the roads would not only be safer they would be less congested at times when traffic is at its peak! This sounds like common sense, something I think our culture is lacking today. I'm not out to hurt anyone, or myself. I just want to be able to make a living and enjoy life. Be safe!


Walter M. Short - Comments 02/20/2008 PUBLIC SUBMISSIONS
General Comment:
We need to be able to stop the 14hr clock with rest periods like we used to be able to do, most of us rarely sleep for more than 5 hrs at a time to begin with.
Without more flexible HOS rules solo drivers are being deeply hurt financially, we can barely make ends meet as it is with these vile fuel prices and the slowing economy.
Most of us drivers are older responsible adults and we don't need crippling rules forced upon us or to be treated like children, I suggest the powers that make up these rules go out on the road with us for a month and see what it's like before passing all these laws.


John E. Scarbrough, Sr. - Comments 02/26/2008 PUBLIC SUBMISSIONS
General Comment:
Please consider professional driver's experiences and public safety when considering the HOS regulations. As a professional driver, I submit it is safer for everyone if I am allowed to take a nap as needed without getting into the 11 hour driving time. Since you changed this rule I have been more tired and less productive. If we could still split the sleeper berth time it would let us be fresher and more alert.

It would also allow us to stop and take a nap, or a shower and meal to avoid rush hour traffic. This is the most dangerous time to drive anything,and the slowest. We should not be penalised by having to hold to an arbritary time period. The important thing is supposed to be SAFETY. Everyone is safer if I am well rested.

My body does not sleep on demand, as I am sure yours does not. When I am sleepy is when I should sleep, not when I am out of hours. My body does not sleep all at once, then stay alert and drive all day, especially in bad weather. To comply with the rules as they are currently written, I must either take a pay cut or drive sleepy. Which do you want me to do? You need me to work all I can to pay the taxes you want to spend, so I guess you want me to drive tired and be stupid.

Please bring back the split sleeper berth provision. Please do not change the 34 hour restart, as I am home every weekend and this is necessary to refresh myself. (The company may try to make me stay out longer if the restart was not allowed.) Please allow the 14 hour and 11 hour clocks to stop for a rest period to let us get proper rest when our body needs it. Please do not change any other provisions.


Jerry M. Smith - Comments 02/25/2008 PUBLIC SUBMISSIONS
General Comment:
The hours of service are good BUT the 8-2 sleeper berth needs to go back the way it was before. I drive a deicaded route and it was alot easier to sleep 5and 5 or 6and 4 and total of 10 hrs off. Myself and alot of other drivers cannot do a 8and 2 spilt. It makes me more tired and if I have to pull off for 8 hr break, I am not tired and this is very un safe. All drivers are different!! The way it was before,we can pull off,take a nap without going against the 14 hour rule. Stopping the clock while taking a nap or rest will not make us feel like we have to break the law to get there. There are alot if drivers now breaking the law to get there because when they take a break there time is tooken away from them. Need to go back the way ut was so drivers will not be breaking the law\
Thanks


John T. Randall - Comments 01/03/2008 PUBLIC SUBMISSIONS
General Comment:
Split sleeper berth is essential as it gives drivers a chance to rest when they are tired, also to avoid traffic rush hours and still provide for a full days earnings/ work. The 14 hr rule needs to be eliminated or extended. 34 hr restart should be left as is as that is more than adequate.


Rick Kimmick - Comment 02/19/2008 PUBLIC SUBMISSIONS
General Comment:
I run the Safety/Compliance department for a 30 truck company. I have seen an increase in productivity and a much better safety record with the current HOS Regulations. The only changes I see that need made are to allow the split sleeper berth to stop the 14 hour clock for BOTH splits. as it stands, it is a punishment for a driver to stop in the middle of the day to take a 2 hour break/nap.


Laura McGee - Comments 02/19/2008 PUBLIC SUBMISSIONS
General Comment:
I wish to address the 14 hour clock that once started can not be stopped. There is a desperate need for drivers to be able to stop the clock. What the government has done is force drivers into thier trucks. The drivers now eat while driving, look at their maps, urinate, call for, and write directions, fight through after dinner sleepy, and anything else they have a need to do with out stopping the truck. So what the Suits have done is put drivers on the highway, with 80,000# pounds and the one who controls this giant, is sleepy or distracted...please remember this next time you are driving with your family. If the driver is able to stop the clock, he can eat and lay down for a nap, and take care of any other business. If a driver could stop the clock it would ease truck congestion at rush hour in the metroplexes...as most experienced drivers will take a break, during this time. It is less tiring on a driver, and less wear and tear on the truck, when they can avoid high traffic volume, plus less of a chance of becoming involved with someone, who does not get that a 80,000# truck does not handle like a 5,000# car.


Robert V. Harsell - Comments 03/03/2008 PUBLIC SUBMISSIONS
General Comment:
The 2003 rules weren't bad, once understood. At first, before I understood them, I was afraid that the new rules would shut me down.

The more I find out about what happened between then and now, the more I think that maybe the feds are not entirely to blame for the dangerous business of drivers being forced to choose between safety on the road or food on the table.

Public Citizen and two other groups convinced the court to throw out the 2003 rules. Unless I understand it wrong, the court gave the FMCSA until October 1st, 2005 to rewrite the rules.

Maybe the people at the FMCSA were at their wits end by that time and just pulled anything out of the hat to satisfy the court order.

I watched a video of John Hill, Senator Lautenberg, and Joan Claybrook of Public Citizen. Senator Lautenberg and Joan Claybrook were taking turns being sarcastic or stupid. John Hill responded respectfully.

October 1st, 2005 was the day the HOS rules really went bad. If it weren't for Public Citizen and the other groups, the 2003 rules would have stood as they were originally written.

I'd like to know what happened behind the scenes, if anything, that inspired the feds to eliminate split time.

Does anybody know?


Diane E. Dike - Comment 02/19/2008 PUBLIC SUBMISSIONS
General Comment:
I like the Hours of Service as it stands right now, 70 hr work week, 11 driving, 10 hours in the sleeper 14 hrs total work for the day. But I miss the minimum 2 hrs of rest where it stops the clock then it starts back. I miss my nap during the day and not so rushed, I feel better when I have it.


Eric W. Marfull - Comment 02/19/2008 PUBLIC SUBMISSIONS
General Comment:
The 14 hour day and 34 hour restart are sufficent. If a person can't get enough rest in 10 hours and be completely rested after 34 hours some time management issues the problem. I feel that the 10 hour sleeper berth should be able to be split. Not everybody needs the same amount of sleep and when to be told when to sleep.


Michael P. Neal - Comments 01/24/2008 PUBLIC SUBMISSIONS

General Comment:
I feel that the 11 hour drive time and the 34 hour restart should stay in affect. I also feel that drivers should be able to stop the 14 hour clock this would greatly help in scheduling reducing lost time during congestion. I read and article on landlinenow.com that the National Surface Transportation Policy and Revenue Study Commission understands the usefulness of stopping the 14 hour clock, and understands the there needs to be attention brought to shippers and recievers. The 11 hour, 34 hour, and stopping the 14 hour clock are very helpful.


Bobby C. McCrary - Comments 01/11/2008 PUBLIC SUBMISSIONS
General Comment:
Please do not force truckers to drive while sleepy. The new rules do not allow you to stop the 14 hour clock when splitting the sleeper birth into 2 segments. This causes truckers to drive while sleepy because in certain instances you can't take a 2-3 hr nap and make your delivery on time because your 14hr clock would run out. No 2 people are the same about sleep requirements and no person is the same day to day. So please consider this when making your new rules. I think the other rules are fine. I have no problem with the 10 hr break, 11 hr drive time, or the 34 hr restart, but the new 14 hr rule has forced me personally on several occasions to drive while not at 100 percent.


Comment Info: =================
Ervin T. Freeland - Comments 02/20/2008 PUBLIC SUBMISSIONS
General Comment:
My comment on the Hours of Service is that a driver should be able to split there sleeper time and break periods without interfering with our working hours.


Comment Info: =================
Umknown Commentor 02/19/2008 PUBLIC SUBMISSIONS
General Comment:
I am a driver in in a 7 to 8 state region from my terminal in Illinios a the 11 hour driving rule has help me get to my delivery and pick up points in one day instead of doing it in two days. the 10 hour sleeper rule has not affected me in anyway other than getting more free time to relax or sleep. the fourteen hour clock has been a real pain in that I can not legally stop the clock to take a fifteen minute break or a sit down lunch to get away from the raod for a bit, or if I may feel sick or have a headache and take some asprin and sleep it off. If I get stuck at a shipper or reciever four a period of time the clock will push me to have to force my self to speed or drive a full 11 hours the next day when I diddn't need to. I feel this part of the regulations are the must unsafe of the driving regulations


Daryl F. Gabbard - Comment 02/19/2008 PUBLIC SUBMISSIONS
General Comment:
The hours of service for the most part are fine, except for the 14 hour clock. We need to be able to stop and start the clock in some way to help with traffic, which means less trucks in municipal areas during rush hours. It will also help with driver fategue when we can stop and take a nap or rest. As it stands now if we get tired we have to keep pushing because the clock doesn't stop and we have deadlines for delivery or pick up. That is the only thing that I would like to see changed, the 11 hour drive time is ok and the 34 hour restart is working very well in my opinion.


Steven Kessler - Comments 02/11/2008 PUBLIC SUBMISSIONS
General Comment:
I have been a professional truck driver for 9 years now. I believe the 11 hour rule is adequate. The 34 hour restart rule is probably the best thing to come out of the new rules! The rule encourages a long break and I think promotes a rested and safer driver. I think the 14 hour rule needs some work though. As a driver I sometimes get tired during the day. At these times I might want to stop and take a nap to refresh myself, under the old rule I could due this without taking away from my driving time. Under the new rule I lose this time so I am compelled to keep driving even though it would be safer to rest. This makes no sense. These times for me usually fall at about the same time as traffic is the most congested (rush hour). If drivers could pull over and stop during the times , by stopping the clock, the roads would not only be safer they would be less congested at times when traffic is at its peak! This sounds like common sense, something I think our culture is lacking today. I'm not out to hurt anyone, or myself. I just want to be able to make a living and enjoy life. Be safe!


Kenneth G. Campbell - Comments 01/15/2008 PUBLIC SUBMISSIONS
General Comment:
concerning the HOS rules, the one thing that i feel should be reinstated is the ability to take a rest period during the day to extend the 14hrs rule. as it is now, a driver is forced to complete all work within these 14hrs, however, i feel it that during times of high volume traffic a driver should be able to take a few hours break to avoid this situation (if at all possible) then continue on their run. also, i know from experience that sometimes during the day a person can become fatigued. a few hours sleep break can make all the difference. this will make a driver alert and safer. after all, itn't safety what is important here? i would hope more drivers will comment on these HOS rules. these are the people who are doing the job and know from experience what will work best. it's sad to think that special interest groups have so much influence here but have never been a driver.
thank you

ken campbell 14yrs class a driver

Homer E. Reed - Comments 01/07/2008 PUBLIC SUBMISSIONS
General Comment:
The hours of service are good now, excepte for the 14 hour clock, Too many drivers are pushing theirselves, not taking breaks. We are required to operate like a machine, A office worker is allowed a break in the morining , a lunch bread, and a break in the afternoon, But not a truck driver.


Trudi F. Robertson - Comments 02/11/2008 PUBLIC SUBMISSIONS
General Comment:
My husband is a driver and due to the new HOS he has had to drive tired. He can no longer stop when traffic is bad and take a nap without it counting against him. I think these HOS do not help the driving public but make the streets more dangerous. If the 14 hour clock would stop when a driver stops to nap for a few hours during peak traffic hours the whole country would be safer. I know that I would feel safer on the road with these trucker who are now driving tired.


David M. Colestock - Comments 02/25/2008 PUBLIC SUBMISSIONS
General Comment:
I feel that the hours of service do need a change, I would like to be able to split my hours . It it much safer to be able to take a break half way into ones day if needed such as a 4-5 hour sleeper birth then continue to finish my eleven{11} hour drive. also taking a off duty break for meal not included in the 14 hour day. Working 14 hours a day is enough for anyone.
Thank you for this oppertunity
David Colestock


Chester M. Daniels

General Comment:
DEAR FMCSA, FAILURE TO ALLOW SPLIT SLEEPER BERTH MANDATES THAT THE DRIVER CONTINUE WHETHER DROWSY OR NOT. THE 14 CONTINOUS HOURS RULE IS CONTRARY TO SPLIT SLEEPER BERTH RULES FROM PAST YEARS.. THERE IS NOT ONE SHRED OF EVIDENCE THAT SUPPORTS TERMINATION OF THAT RULE. IN 40 YEARS, I HAVE USED THAT AFTERNOON NAP TO TERMINATE MY DROWSY CONDITIONS. THE 34HR RESTART IS GREAT. AFTER I REACH MY WEST COAST DESTINATION, I ENJOY A COUPLE DAUS OF. AFTER THAT I START TO TIRE, NOT REJUVINATE. CARRIERS HAVE REDUCED RATES BELOW THE COST OF OPERATIONS FOR TH OWNER OPERATOR. ANOTHER STRESS FOR THE DRIVER TO DEAL WITH. COME GO WITH ME, EXPERIENCE THIS FOR YOURSELF THEN YOU'LL HAVE REAL FACTS TO LEGISLATE FROM, NOT JUST THE "STUDY, RESEARCH, SOMEONE TOLD YOU" WITH ALL DUE RESPECT, NO ONE IN DC HAS ANY IDEAL OF THE REAL WORLD OUT HERE. I PAID $200,000.00 FOR MY RIG AND I WOULD LIKE TO MAKE ENOUGH MONEY TO PAY FOR IT BEFORE I FALL ASLEEP AT THE WHEEL AND WRECK IT.


Patrick J. Wiley - Comments 02/27/2008 PUBLIC SUBMISSIONS
General Comment:
I am an owner/operator, and have driven under both hos. old and new. I like the present hos. The 10 hr break alows more time for delivery schedules, too where shippers can not figure driving time plus an 8 hr break(under old hos rule) to where you must fuel. eat, shower & get rest in the 8 hrs. The 10 hrs alows for these things plus too insure that i get the rest i need. The optional 34 hr restart is great, as it alows me time off, plus being able to get back on the road to make money. In my opinion, the only thing missing that would make this better and more adaptable to different schedules would be the split sleeper birth that stops the 14 hr rule. Under the present hos, i am forced to drive when i'm tired and during traffic rush hr periods when it would be better for me to rest then leave on my delivery. Also i feel it would help to free up parking spots, as trucks wouldn't have to occupy spots for the whole 10 hrs. If you are truly after the safety aspect of commercial traffic, please consider putting that provision back in. thank you


Donny E. Yates - Comments 02/28/2008 PUBLIC SUBMISSIONS
General Comment:
The 14 clock should stop at short rest periods and off-duty time instead of 8 consecutive hours.


Clarence Burton - Comments 03/03/2008 PUBLIC SUBMISSIONS
General Comment:
They HOS are fine except for the sleeper birth provision. We need a split sleeper birth like the original with a minimum of 2 hours would be just great. The 34 hour restart is ok and the 11/14 is fine too. Thank you


Donald S. Powell - Comments 02/20/2008 PUBLIC SUBMISSIONS
General Comment:
Drivers need more lattitude in being able to move into and out of cities with higher traffic,in order too make their deliveries in a safe and leagle manor.


Gene Butterly - Comments 02/20/2008 PUBLIC SUBMISSIONS
General Comment:
Who else wants be as exhausted as I am?

This 14 hour rule is NOT safe. There is no provision for sleeper berth time and there has to be sleeper berth time in order to maintain safety.

I have been driving a big rig for 23 years in a row and now I find myself fighting exhaustion just keep within my 14 hour rule.

My most recent. Making drops in Indiana during the day and then, by the 14 consecutive hour rule, had to fight sleep through wintry conditions to get back. If I would have stopped and jumped in the bunk for a few hours it would have been MUCH safer as I would have been rested, alert and the winter cold front would have passed. But, the 14 hour rule makes this impossible to be safe ...it is anything but safety.

Even on dry road conditions with light traffic why should we have to ignore our body telling us to take a break. The 14 hour/no sleeper berth provision forces me and many others to make unsafe decisions just to keep our log book in order.

For public safety the 24 rule with 10 hours driving and 5 hours off duty within 24 hours should have been left alone. The stats on all the wrecks have little to with our log books but rather unqualified drivers. There have been too, too many restrictions placed on the industry and the reals truckers are getting out. This is leaving a huge vacuum for unqualified rookies. We were all rookies at one time but most of us spoke and understand the English vocabulary, read a map and got along with one an other.

I sincerely hope this post finds the right person so we can get our once proud of trucking industry back to a safe and normal mode of operation.


Thank you for your time,
Gene Butterly
Ohio, USA


Anonymous

General Comment:
the 11 hour rule and the 34 hour restart should remain in the hos. you need to add some type of split sleeper berth allowance so the drivers can rest when they need to and not be punished for it by losing income.


John H. Payne - Comments 02/11/2008 PUBLIC SUBMISSIONS
General Comment:
As an OTR driver, it will be important for all concerned in the rule making process to understand, drivers will always have to find ways around any regulations enacted until common sense rules are put in place. We every day are "required" to perform work without pay, since most of us get paid "by the mile". If we have to wait 4-6-10 or more hours to load or unload, then have apointments for additional stops, we have to CHEAT. Sleep comes second to earnings and if you want meaningful changes, put requirements into the HOS rules that at minimum allow drivers to stop their clocks with split sleeper periods or off duty periods which allow them to nap while waiting for hours to unload or load, or require carriers to "pay" drivers on duty at loading or unloading facilities waiting to load or unload.


Mark A. Murphy - Comments 02/20/2008 PUBLIC SUBMISSIONS
General Comment:
Today I speek out. I do not understand why rule changes where alowed in the first place. Courts and the General motering public have truly no ideal how or why this industry works. Its between the FMCSA and the industry, and should stay that way. The 11hrs driving 10 sleeper and 34 restart are ok, but the 14hr max does nothing but force me to drive when a nice nap would serve all better. Please toss the 14hr rule and give us the split sleeper option back. Thanks M Murphy


Vicky A. Bergan Dietz - Comments 02/20/2008 PUBLIC SUBMISSIONS
the concern for the hours of service for Truck drivers seems to be getting out of hand. There are too many people trying to take control of our working lives that have not the first clue on how our trucking industry works, they are for one, not taking into consideration on how some portions of what they are fighting against could in the end require there to be thousands of more trucks on the highways that will not be safe drivers because of inexperience, etc. and which will drive up the diesel prices even more. The drivers need to be able to pull over (Thus the split sleeper rule) when they feel tired and not have to worry about getting into trouble with their logs. The drivers also need to be alowed to stop the clock and log of duty or whatever when they are waiting to get loaded or unloaded, I for one have seen first hand what it is like when pulling up to a dock somewhere. The shippers or recievers seem to like to take their time loading, etc. so the driver sits there for hours sometimes while his or here hours are ticking away, which is extreming unfair. My Husband is a long-haul driver, and I can see the stress he is put under because of all this stuff, while I sit home with small children waiting for him to return so we can share a few hours together as a family. these people who are trying to regulate our lives all need to get into a truck for one week and ride to see what things the truck drivers face out there on the road, they would be amazed and ashamed because they are trying to make truck drivers out to be some sort of a criminal for doing there job. The shippers and recievers need to have some sort of rule put into place to get on the ball when the trucks come in for delivery or pickup, perhaps a big fine for them would be some incentive to quit being so lazy and ornry and get the drivers on their way. As far as the 34 hour restart, I am in total agreement with this rule, My husband gets to spend some time with us at home so he can watch his children grow up and take part in thier lives. The drivers need to have some more flexibility in when they can stop and rest, because nobodys sleep schedule is the same. And forcing the drivers to change their schedule like that just to please the "public citizen group" is where the dangers start to arise. You people out there, stop and take a look at what you are doing to our harding working people in our country. Like the saying goes, "If you got it, a truck most likely brought it". Thank you,


Anonymous
General Comment:
in your review of the hos rules i can only hope that you will continue to allow the 11 hour drive time and the 34 hour restart. you should also include a provision for the split sleeper berth. this will help in curbing the driver fatigue issue. thank you.


David R. Harmon - Comment 01/02/2008 PUBLIC SUBMISSIONS
General Comment:
I thank you for taking the stand on the Hours of Service. I support the hours of services a proposed with one exception.

This exception is to the 14 hour clock. We need to be able to stop this clock to allow for a safer operations.

Example:
I have had a bad night, unable to sleep. Due to the 10 hour rule I cant drive until the 10 hour clock runs out. Now it has ran out and i begin to drive, about 2 hours down the road i get very tired, and begin to nod off.

However due to the 14 hour clock rule. if i stop to rest I may have to wait until tomarrow to get my load to the destination. Where if I could stop and rest for 2 or 3 hours and be able to stop the 14 hour clock, I would be a safer driver and be able to get my load were it was to go just a hour or two later than normal.


Lisa D. Goodpaster - Comments 02/20/2008 PUBLIC SUBMISSIONS
General Comment:
The hours of service should be changed to get rid of the 14 hour rule. We should be able to split our sleeper berth time as we see fit without having to worry about getting our work done in a 14 hour straight period. No one works on a regular basis 14 hours straight. This has been more exhausting on us to do this. And if we run as a team it really messes us up because if one driver takes a 10 hour break as required what are they supposed to do for 4 more hours until the other driver uses up their 14 hour period. This part is stupid. The 11 hour, 10 hour parts are fine but get rid of the 14 hour part. Because as I said none one works 14 hours straight all the time and that is what you are forcing us to do.


Lisa D. Goodpaster - Comments 02/20/2008 PUBLIC SUBMISSIONS
General Comment:
The hours of service should be changed to get rid of the 14 hour rule. We should be able to split our sleeper berth time as we see fit without having to worry about getting our work done in a 14 hour straight period. No one works on a regular basis 14 hours straight. This has been more exhausting on us to do this. And if we run as a team it really messes us up because if one driver takes a 10 hour break as required what are they supposed to do for 4 more hours until the other driver uses up their 14 hour period. This part is stupid. The 11 hour, 10 hour parts are fine but get rid of the 14 hour part. Because as I said none one works 14 hours straight all the time and that is what you are forcing us to do.


Robert L. Olson - Comments 02/15/2008 PUBLIC SUBMISSIONS
General Comment:
I am a truck driver for a LTL company in the washington state area. I like the 34 hr restart. It allows for an easy recap and you dont have to worry about short hours on a monday due to a long monday the previous week. It also allows for a real rest meaning that your company can't call and pressure you to work when you are on your break.

The 11 hour rule is a good rule, I dont use it too often unless of real bad weather or some unforseen problems. The old rule allowed 2 hours in this instance, but this one wont allow abuse of the rule.

I do wish we could stop the clock on the 14 hours. this would allow us to take a nap or long lunch and then pick up where we left off.

I am a teamster and yes I like the new style. its easier to understand and administer.


Anonymous

General Comment:
the hos rules need to keep or include the 11 hour driving, the 34 hour restart, and also the split sleeper berth allowance. the split sleeper berth rule allows the driver to to take control of when he or she sleeps, not some one in an office hundreds of miles away who has no idea of the situation at hand! the majority of shippers and receivers in the country do not care how long they hold you up or that all the time you spent waiting at their facility counts against you. the 14 hour clock did not solve the problem of wasted time for the drivers or drivers being forced to drive tired. i hope that in the new rules you will consider the drivers who have to live by these rules. thank you.


The Honorable Christopher Bond - Comments
General Comment:
The hours of service have NOT helped the trucker at all! They have made it so hard for them to take care of themselves. They no longer have time to take a daily shower, get out to walk around the truck to get some exercise. Their health has been compromised. They do not get the rest they need. Before the new hours of service, they were able to stop to take a nap if needed. You didn't take into fact that not everyone has the option to a drop and hook delivery. Some have to wait hours at plants to get loaded, this cuts into their day where they can't make their deliveries on time because they have to stop. The truck stops are overflowing at night. This is dangerous with the fumes of the trucks running. The FMCSA has to much power and they have seen to it that the rights of the truckers have been taken away. They didn't give the public the chance to comment before they closed the date for said comments. Not all truckers have access to the internet. Please listen to what the truckers need, not special interest groups.


Stephen A. West - Comments 09/28/2005 PUBLIC SUBMISSIONS
General Comment:
As a Diabetic the present HOS Rules and the new HOS Rules causes many problems.
Without the provisions to stop the 14 hour clock and the requirement put on me as a dirver to pick up and deliver on time I am having to skip meals or eat junk food available at the fuel desk. I can eat better when the many hours, 6 to 10 hours a day, sitting waiting to load or unload can stop the clock, and still allow me to drive my 11 hours. I can use the that time to prepare food I carry in the truck. I do that now, but as the time counts against my 14 hours and when I do get on the road it is drive as many of the 11 hours as you can without stopping for anything.

In effect you drive till you are so tired you have to stop because your are falling asleep at the wheel. You still try to press on to make your scheduled delivery or pick up as there are still some of the 11 or 14 hours left. You then grab something to eat, do paperwork, shower, which counts against your 14 hours, then get some sleep. At this point there is no 10 hours to rest as you have to get back on the road in order to make your schedule.

It is not necessarily the carriers/brokers setting the impossible schedules. Its the shippers and recievers that make you sit 4 or more hours at their facility. Best example of a receiver cutting into dirvers hours is Wal-Mart Distribution Centers. You have to arrive 1 hour before your appointment time in order to be checked in on time according to their record keeping records. Then they allow themselves 2 hours to unload your load, which they take 1 hour and 58 minutes of it if you have 1 pallet to deliver or 26 to deliver. They then take up to 30 minutes to get you checked out and your signed paperwork back to the driver. You then can reconnect to your trailer and depart their facility. Example would be: Appt time 0800, you arrive 0700, check in at gate, Drop your trailer at assigned door by 0715, wait in line at their receiving window up to 45 minutes to turn in your paperwork.

The time stamped at that time is considered your arrival time. They unload 1 hour and 45 minutes, it is now 0945. The Dock worker turns in the paperwork back to the clerk, They consider the paperwork is availble at the office at this time, their clock stops. The clerk processes the paperwork for the driver and notifies the dirver it is ready, now 1015, You get the paperwork, rehook to your trailer and chck out of the gate, now about 1045. In Walmarts eyes you were there a total of 1 hour and 45 minutes when in real life it was 3 hrs and 45 minutes.

This is only 1 of many examples of how shippers and receivers tell time. If we log the 3.75 hrs as on duty thats off your 14 hrs and are still expected to drive 11 hrs to get to your next stop, and the shipper/receiver clock takes over again. Where do you find legal time to eat, rest, do paperwork use the restroom and not get tired along the road? You still need to be on time on top of it all.

The best solution I can see is that everyone needs to be required to use the same clock. You are shorting the drivers clock and corporations are using the clock in other ways to expand their day and not pay driver detention and giving themselves an expanded day to do the same job.


Mike Truver - Comments 09/29/2005 PUBLIC SUBMISSIONS
General Comment:
We have tried the 10 and 10 and this is not a good scenario for Teams at all, at 5:30 this morning after 5 hours of driving since midnight I had to pull over and wake up my wife, which used to work-out perfectly, and this being the last week that We can do this LEGALLY, I will not have that option so, I will have to next week as this same picture plays-out, drive sleepy for 5 more hours or not deliver Our Customers goods on the schedule that a Team should be able to comfortably deliver it, effectively putting the TEAM part of the equation at question from here on out. The OLD-NEW-HOS that We have been using for the last year and might I say, They were working just fine, until someone behind a desk with a degree majoring in "the arts" or something else that has nothing to do with what THEIR job pertains to decided to change for Our so-called Health???????? Well, FMCSA has major health-and-fatigue issues ahead of them now!!!!!!!! This Newest circus-of-hours they have signed Us up for is going to cause MAJOR-FATIGUE and Health issues. Maybe everyone driving team should split-up and run single, this would put double the trucks on the road and then FMCSA-PATT-CRASH and All of their money-under-the-table buddies would like dealing with 1/3 or more trucks on the road!!?? WAKE UP PEOPLE IN FMCSA!!!! The old hours of service for TEAMS were working fine for the last 28 years I've been out here, You are going to have alot of Fatigue-related problems if You don't make provisions for the Teams to keep the split 5 and 5, You made provisions for one sector, why not make an ammendment or provision for the teams.


Walls Trucking - Comments 10/03/2005 PUBLIC SUBMISSIONS
With the new hours of service you are forcing me and other team driver who have been working on the 5 hours on 5 hours off for 15 years or more to drive tired. We have driven this way so long that we can't sleep more than 5 hours at a time and struggle to stay awake on the road for more than 5 or 6 hours. We also think it is wrong that if we get out of bed to go into the truck stop to us the restroom we have to start our 10 hour break all over again. This is crazy who in this country gets up in the middle of the night and has to go back to bed for another 10 hours.If this is supposed to be in the name of safety you need to look again because you have put alot of team and other drivers very tired behind the wheel of these trucks.


Martin J. Fields - Comments 10/03/2005 PUBLIC SUBMISSIONS
I DISAGREE WITH THE NEW HOS RULE AS OF 10/01/05. SHIPPERS AND RECEIVERS TAKE ADVANTAGE OF DRIVERS TIME LOADING OR UNLOADING. DRIVERS MAY BE OUT OF HRS. WHEN BUSINESS IS DONE AND HAVE NO PLACE TO GO. SOME PLACES ARE UNSAFE OR NOT ALLOW PARKING OR IN THE NORTHEAST VERY LIMITED PLACES TO PARK FOR REST. BY TAKING AWAY THE ABILITY TO SPLIT LOGS YOU ARE PUTTING DRIVERS AT JEOPARDY BY FORCING THEM TO DRIVE HARDER TO TAKE CARE OF BUSINESS AND FIND A SAFE PLACE TO GET REST.


Martin J. Fields - Comments 10/03/2005 PUBLIC SUBMISSIONS
THE INABILITY TO SPLIT LOGS AT LEAST A TWO HR MINIMUM PUTS DRIVERS AT THE MERCY OF SHIPPERS AND RECEIVERS WHO TAKE UNFAIR ADVANTAGE OF DRIVERS TIME ANYWAY, AND OUR NEW 14 HRS WITHOUT THE ABILITY TO STOP THE CLOCK PUTS DRIVERS AT AN UNFAIR DISADVANTAGE. PERSONALLY I USE THE TWO HR MINIMUM TO STOP THE CLOCK TO GET TO A SAFE PLACE TO SLEEP AND SHOWER WHEN A CUSTOMER USES UP MY TIME, THEN I WILL TAKE MY FULL 10 HRS. TO REST AND DO PERSONAL THINGS,AFTER I HAVE MANAGED TO GET TO A SAFE PLACE. I WAS IN TOTAL AGREEMENT WITH THE RULES BEFORE 10/01/05 AND FOUND THEM VERY PRAGMATIC IN THE TRUCKING HORSERACE. BUT BY HAVING 14 HRS WITHOUT THE ABILITY FOR COMPROMISE WILL PUT MORE PRESSURE ON DRIVERS TO RUSH TO GET THE JOB DONE. REMEMBER, THAT MOST OF US ARE PAID BY THE MILE AND TRYING TO MAKE A DECENT LIVING. WE ARE RESPONSIBLE ENOUGH TO KNOW WHEN TO REST, BUT WITH THE UNFAIR RESTRAINTS THAT WE ARE UNDER MAKES IT VERY DIFFICULT TO DO THE RIGHT THING. PLEASE RECONSIDER THE RULING OF 10/01/05 AND RETURN TO THE RULES PRIOR TO 10/01/05. PERSONALLY I AM THE FATHER OF SIX CHILDREN AND LUCKY ENOUGH TO HAVE A STAY AT HOME MOM FOR THEM. I DO NOT WANT THE PRESSURES OF HAVING TO RUSH EVEN HARDER NOW TO BEAT THE CLOCK TO TAKE CARE OF MT FAMILY.


William J. Hudgens - Comments 10/03/2005 PUBLIC SUBMISSIONS
General Comment:
I ask that you do not do away with the sleeper berth exception. It is very hard to stay in a sleeper berth while a truck is moving. If one driver has to stay in the sleeper berth for 10 hours, the other one cannot go to sleep for 10 hours. If one only has to rest for five hours then he only has to stay up for five hours.

I have driven commercially for over 20 years. The last 8 have been as a team driver. I have had no preventable accidents while driving as a team driver. Splitting our rest has worked to our advantage.

Most drivers I have talked to are very concerned about having to drive for such an extended period of time after trying to sleep in a moving sleeper berth. We need this option. Please reconsider. If any change is needed I would say let the drivers choose how they want set their driving and rest as long as the times are nearly equal.
Thanks
Will Hudgens


Amanda Wheeler - Comments 10/03/2005 PUBLIC SUBMISSIONS
General Comment:
The new HOS regulations are could be dangerous for some drivers/ routes. For example leaving headquarters at 6pm and returning the next day at 6pm. This shift is much easier on the drivers if they split the drive each way. They are well rested when they start and each person only has to drive 5 hours during the night. Each helps unload the product and then splits the drive home. Making this run 3 times per week gives them plenty of time to rest at home. It only makes sense to not require these drivers to drive 10 hours at a time if they prefer to split it. Mandating one driver do the entire departure and the other the entire return just does not make sense. Some truckers would like some balance in their lives and do not drive 7 days a week. Please reconsider the individual situations of the truckers lives. When you go on a trip with someone else do you ever drive 10 hours at a time. Many highways are dark, snow covered, and monotonous. Truckers will fall asleep behind the wheel with this new law. Please reconsider.
A. F. Wheeler RN


Alexa L. Hudgins - Comments 10/03/2005 PUBLIC SUBMISSIONS
General Comment:
Have been team driving with my husband since 1992 and have tried to split hours all different ways. The safest way we have been able to drive is 5 on and 5 off. I personally have back problems and even at home I don't sleep but 4-5 hours at a stretch. Ten hours driving at a time is a long tiring drive and we feel that it will wear more drivers out quicker and make the roads less safe. Considering the load/unload situation, it will force more drivers to run illegally just to try to make a living. We feel this ruling is just like an accident waiting to happen, and it really doesn't take the whole picture into consideration.


Comment Info: =================
Rodney E. Carr, Sr. - Comments 10/03/2005 PUBLIC SUBMISSIONS
General Comment:
The new rule on the sleeper berth split makes no sense what so ever all you are doing is forcing drivers to operate unsafely the old rule worked fine,the only thing needed was drivers being able to log 2 hrs offduty to do personal business ie (shower,eat,do laundry etc.)With the old rule if a driver started out his/her day and was tired they could take a 2hr nap and stop the clock then get up and finish their legal driving time. Now they can not do this so where is the safety in this rule change? The ATA is dead wrong in their support of this rule and so are you.Maybe it is about time the rules are made by truckdrivers and NOT POLITICANS!


Arne U. Meberg - Comments 10/03/2005 PUBLIC SUBMISSIONS
General Comment:
The rule requiring ten hours straight in the sleeper, and keeping the fourteen hour clock definitely had no driver input from irregular route carriers, let alone team drivers. Unless shippers and recievers get you in and out immediately (11/2 to 2 hours),eat, shower, restroom stops, then drive eleven hours, that fourteen hours disappears awfully fast. Now add in that a team to get in seventy hours a week, has to load and unload on demand. In four years my wife and I have learned to adjust our sleeper and on-duty time to fit most scenarios. But to do this we need to be able to split sleeper time into 5 hour increments. When the truck is rolling this is more like 5 1/2 hour increments. When we get home time or a thirty-four reset, that 5 hour shift allows one of us to sleep the last five hour home, then the other one sleeps the first five out. With ten hours of sleep at home works out nicely. Even with eight and two hour segments when we are home we have to stay on schedule, or one of us gets severely deprived of rest. Therefore we would have forego more family functions, than we get to now. I respectfully would like to request that the doctor with the eight hour reguirement test his theory in a truck going sixty-five across Arkansas on I-40. Or better yet put his bed on 1/2 inch out of round casters and have his assistants roll him around his lab for ten hours with varying speeds and turns, keep him up fourteen hours than ten in that bed, check him out after a week, bet he won't remember his own name. The reson I would want it done in his lab is so won't get in everybodys way out on the road.


Anonymous - Comments 10/03/2005 PUBLIC SUBMISSIONS
General Comment:
i fully agree with the recomandation for hours of service reccommended by OOIDA reguarding split breaks and being able to stop the 14 hour clock. It only makes sense to be able stop the clock while tending to personal things such as eating, showering, etc. Taking care of these things are not consifered work, if they are then every one in the work force should be required to tend to these activities while at work and being paid, while still required to weet all of the same production requirements, but without working past their regularly scheduled work hours.


Joshua Truck LLC - Comments 10/03/2005 PUBLIC SUBMISSIONS
General Comment:
The new rules for truck driver hours of service ignores the team in regards to sleeper berth provisions almost entirely. The economic benefit of having driver teams is virtuially negated by this new rule. In addition, you have institutionalized a requirement that makes it necessary that teams will have to cheat to stay alive economically. DOT is already bragging about how many tickets they will write. Thanks for handicapping a fine pfofession. ATA has for years reduced truck drivers to the modern equivalent of serfdom, do not listen to them. They are "big business" not the American truck driver. I salute you for selecting only that evidence that supports your pre-conceived notions about sleep requirements. Next time I want an industry killed, I'll call you.


Janet L. Purdy - Comments 10/03/2005 PUBLIC SUBMISSIONS
General Comment:
My husband and I run team hauling government explosives and we believe that being forced to run 8/10 hours at a time will be very dangerous. We currently run 5 and 5 and find that to be the best way. Neither one of us gets overly tired (or sore) from too much time in seat or bed. I ask that you reconsider this, especially for team drivers.


Anonymous - Comments 10/03/2005 PUBLIC SUBMISSIONS
General Comment:
the new hours of servive rules will cause more accients drivers will drive tired with out the split sleeper we need split sleeper


Joe L. Hagen - Comments 10/03/2005 PUBLIC SUBMISSIONS
General Comment:
To whom it may concern,
I have been driving team since 1971 (34years). All this time we have been training ourself's to drive 4 to 6 hrs. and instantly sleep 4 to 5 hrs. That is a system that will work safely for everybody. Now, our "smart" people in the DOT, that have never even seen the inside of a truck, decide that we have to drive 10hrs. and then sleep 10hrs., where as the second is not possible, I don't believe anybody can sleep 10hrs., especially, after pushing oneself to drive 10hrs., which I consider very fatiguing and unsafe for most drivers that have been driving in a team operation for years under the existing rules. It has been determind, in the past, that a fatigued driver is as much of a danger, as a driver under the influence, but under the latest rule a driver will sleep app. 5hrs. then sit around, because he is not allowed to drive yet, for another 5hrs., then he is ready to lay down, but now he has to drive for 10hrs. "BRILLIANT"
Regards
JLH


Paul Biener - Comments 10/03/2005 PUBLIC SUBMISSIONS
General Comment:
Regarding the new Hours of Service for professional drivers:
The kindest way to say this is, the new hours of service rules are a danger to everyone on the road and it is the direct fault of each elected official that either voted for it or failed to oppose it.. The HOS regulations, as they were, were indeed working. Of all fatigue related crashes only a small percentage were caused by professional drivers, the other crashes were caused by individuals in passenger vehicles.

The new HOS rules will force drivers to remain behind the wheel longer without a break and, in my opinion, increase the fatigue related crashes attributable to professional drivers. When was the last time you saw a co-worker nodding off at their desk shortly after lunch?

The professional driver associations are urging drivers to file suit for fair treatment, and accurate representation, in government. Additionally each organization is collecting petitions, counseling drivers to report accidents as directly caused by the new HOS and forming a class action suit for damages from the hostile work environment created by this legislation. Oh, and I almost forgot, 78% of the nations goods are moved by truck, that is until we get sick of your _____ and park our trucks!

And the most brain-dead thing of all:
The new hours of service excludes some fuel haulers, compressed gas containers and broadly exempts agricultural trucks regardless of the cargo. Why would some of the most dangerous cargo on the road be ignored if "safety" is of such importance?

Reality check time.


Scott E. Denzik - Comments 10/03/2005 PUBLIC SUBMISSIONS

The Way I See It Is That Now You must stay on duty for your 11hr drive period or your 14hr on duty time before time spent in sleeper berth sometimes you must be able to split time say you are at a customers place and you got there in 5hrs and it will be 5 or 6hrs before your appt. now that you are unable to split sleep time the 14hr clock does not stop so you just lost 5 to 6hrs to your 14hr when you could have made it to destenation of reload within your 11hr drive and within your 14hr on duty so i see more of my fellow truck drivers loosing there lifes and posibly inocent by standers becouse inorder to make a living in this feild you will need to stay on duty for a complete 14hrs a day some people like myself just pull over and sleep anytime i fill the need and will still do the same if your tired your tired also the oter problem is were do you plan for all these trucks to sit for a 10hr period becuse most rest areas have signs stating 4hr max stay and by law we will not be able to move so i just think that some other plan of action should have be put in effect it's not like they didn't have enough time to think this over thank you.


Charles E. Malcom, Jr. - Comments 10/05/2005 PUBLIC SUBMISSIONS
The latest revision to the HOS rules are no worse or better than the original rule. The main problem with all of these rules is and has been the 14 hour rule. Previously I could spend all day driving my 500-600 miles. Taking what naps I felt necessary and avoiding high traffic or rush hour situations as needed. With the advent of the 14 hr rule I am forced to drive when I don't feel my best or in situations that are much more stressful than I would normally submit myself to.

Now after having adjusted as well as possible to the "new rules", they're changing again. When will someone do a study of this industry from some other vantage point besides a scientists research on human behaviors. Bring those same scientists out into my world, living on the road for 3-6 weeks or more at a time. Dealing with the everyday mundane aspects of this job along with the not so mundane. Then let them tell me when and for how long I need to rest. My circadian clock was promptly removed by the military back in 1976 and I haven't been able to find it since. My health is outstanding and will remain so as long as I continue to work this system the way we always have. Ignore the scientists, drive when I feel most alert and rest when I feel the need. The paperwork to support the hours of service regulations is easily documented...later.


Deborah Hudler - Comments 10/03/2005 PUBLIC SUBMISSIONS
IT WOULD APPEAR THE NEW HOS DOES NOT TAKE INTO ACCOUNT THE TEAM DRIVER. AFTER A TEAM HAS HAD TIME OFF IT WOULD BE NEAR IMPOSSIBLE FOR ONE TO SLEEP THE FIRST 10 HOURS OF A TRIP.IT ALSO DOES NOT ALLOW FOR TEAMS THAT HAULS SECURITY (CONSTANT SURVALLIANCE)LOADS,ONE DRIVER MUST ALWAYS BE WITHIN 25 FT OF VEHICLE,AWAKE,NOT IN SLEEPER. HOW WOULD THE DRIVER BE ABLE TO GO INTO A TRUCKSTOP FOR FOOD, FUEL, OTHER NESSASSARY THINGS WITHOUT THE SECOND DRIVER GETTING UP TO WATCH THE LOAD. THEN HIS OR HER 10 HOURS IN SLEEPER IS DISRUPTED.AT THE 2003 HOS MOST OF THESE CAN BE DONE EVERY 5 HOURS AND THEN SWITCH DRIVING. THIS GIVES BOTH DRIVERS FAR MORE SLEEP.


Carol Edwards - Comments 10/03/2005 PUBLIC SUBMISSIONS
General Comment:
As a company with mostly team drivers, ranging from 5 to 25 years of experience, forcing teams to change driving hours from what they are comfortable with to driving 10 straight hours is the most dangerous decision you could have made. I myself drove for 10 years and, I can tell you from first hand experience forcing a driver to drive straight through the night is most dangerous. Being able to split up the nights keeps drivers from falling asleep at the wheel. Everyone has a different sleep pattern. Put yourselves in the shoes of these drivers. Stop and think like a person and not a scientific machine, and ask yourself, would you be able to drive 10 straight hours day or night, from your current sleeping all night and only working during the day.

You can not expect truck drivers to work on a schedule of 9 to 5 like the general population. All truck drivers are a rare breed of people. It takes a special type of person to be a truck driver and a special kind of person to be the spouse of a truck driver. Not everyone can fill either of those positions. Our company is a very safe company in the current hours of service rules. We are owner/operators with owner/operator teams. We have no accidents among our drivers, we all follow the rules, drive safe, and look out for the other drivers on the road. So look at it this way, would you be willing to only make money while you were in your car rolling down the road, instead of the hourly pay that you receive whether sitting behind the desk or whatever your job may be? I think not. So trying to force truck drivers to follow rules that should not apply to them is like trying to force the general public to follow the same kind of rules that a truck driver works by. All rules do not fit every occupation. If a truck driver was getting an hourly wage, life would be much simpler for everyone, but as we know life does not work that way. If you continue on this same route of rules you will see more serious avoidable accidents on the road not less. So I'm challenging you to spend a month or two,team driving on the road and, then tell us it is a safer more productive situation. You can not know what it is like out there unless you have been there. There is not one driver out there that wants to be in an unsafe situation.
Thank You
Carol Edwards
Owner/Operator/sec./treasurer
Brookhaven Transportation, Inc.


Jana E. Huolt - Comments 10/03/2005 PUBLIC SUBMISSIONS

how safe is it for team drivers to drive for 10 hours, then try to sleep in a moving truck for 10 hours, what with stopping at scales etc.It worked just fine for us at 5 hours driving and 5-6 hours sleeper. Myself(lady driver) is not comfortable driving for 10 hours and I feel it will be more dangerous because I will be exhausted at the end of the driving shift.After 5 hours sleeper, I couldn't get anymore rest with the vehicle moving.Please reconsider for teams.


Cindy L. Armstrong - Comments 10/03/2005 PUBLIC SUBMISSIONS

This in in behalf to the new HOS I am a team driver and from the time I started driving I have used the split sleeper berth of 5 drive and 5 sleeper now that I have to try and start driving at least 8hrs at a time I feel that I may have to give up driving. I know I perosnally feel unsafe and very fatiguied after about 6hrs and I am real worried about what may happen if I am forced to driver longer. I personally do not want to kill someone and I feel that is possible if I have to drive for a at least 8hrs at a time. I know many team drivers who are in the same situation. My husband and I drive as a team and I don't really want him to go back to solo driving because I can't do it. I would be worried all the time about him being to tired and getting fatigued.

I don't think that this is far to the team drivers out there to make them do something that they feel unsafe doing. I have alway heard that you want the drivers to be safe well the hours that you have inposed on us this time you will probley see more accidents from it instead of less.

I feel you need to look at the drivers safety instead of at the people who know nothing about what goes on out here and sit behind a desk and think they know what is good for us well I really feel this time they are way off track and it could be one of them that is killed because a team driver is being forced to drive past the time they feel safe driving.
Thank you for your time
Cindy Armstrong
OOIDA Member and Team Driver


Martin J. Fields - Comments 10/03/2005 PUBLIC SUBMISSIONS
I HAVE MADE TWO COMMENTS NOW ON THE DISAGREEMENT OF NEW RULE AS OF 10/01/05. TO GIVE AN EXAMPLE WHY RULE OF HOS SHOULD BE BACK TO PRIOR 10/01/05:I AM DUE TO BE IN N.J. BY 0700 10/03 I WOULD LIKE TO HAVE LEFT AT 1100 10/02 AND ARRIVED AT 0400 TO CATCH A NAP FOR THREE TO FOUR HRS, BUT NOW THAT THE CLOCK CAN'T BE STOPPED I MUST LEAVE AT 0200 AND DRIVE STRAIGHT THRU UNLOAD AND GET ANOTHER LOAD BEFORE MY TIME RUNS OUT AT 1600 NO REST FOR THE WEARY, THANX FOR THE RED EYE TREATMENT, BUT A NAP AT 0400 WOULD HAVE BEEN NICE IF I COULD AFFORD IT, BUT MUST KEEP ROLLING TO BEAT THE CLOCK!!!!!!!!!!!!!!!!!!!!!


Anonymous - Comments 10/03/2005 PUBLIC SUBMISSIONS
General Comment:
i don't understand all the rig a maroll. i've been an owner operator for 35 yrs. the old rules were just fine. you get a few people that drink and drive or just plain don't pay attention to the driving and we (trucking industrie) have to suffer. the new rules were we took ten off and could stop the 14 hr. clock with two or more hours in the bunk was working just fine. the 34 hr. restart is a blessing. why don't you people that don't have first hand knowledge of the trucking business just go away. all your doing is making it harder for honest people to make a living. if "madd" and a few other orginizations would look at the real facts they would see that around 97 percent of the truck accidents are caused by people in cars that talk on the cell phon, put there makeup on, eat there lunch or read. why don't you start cleaning up the general public? keep up what your doing by regulating us out of business and you will soon find no food in the store, gas at the pumps or medicine in the hospitals. remember one thing...everything you come in contact with has mover by truck at one point in it's journy to the market. with out trucks america stops moving. i think we should all shut down until you people cpme to your senses!!


Richard J. Cooper - Comments 10/03/2005 PUBLIC SUBMISSIONS
General Comment:
after 20 years in retail and 5 years driving a truck,hos should be the way it was,11 hrs driving,14 total unless a break of 2 hrs or more. the way it is now basicaly breaks during the day are outlawed.among other thing not considered either. this new hos also pretty much puts the normal driver as a moron. If you want or need more information on our industry or positions i will respond without favortism.


Phillip S. Stodgell - Comments 10/03/2005 PUBLIC SUBMISSIONS
General Comment:
I am a overthe road team driver who has driven team for 28years. I am in agreement with the petitions submitted by OOIDA, especially the on pertaining to the inability so split sleeper time as in the past. This change will lead to much more fatique.

2293 Ed E. Dean - Comments 10/03/2005 PUBLIC SUBMISSIONS
General Comment
I have seen the goverment do some stupid things but these new hours of service takes the cake.Instead of leaving early and get to a shipper or receiver and go to the sleeper and GET REST now driver leave just in time and run like crazy to get all we can in 14 hours. There is no way to stop the clock for safety or health. Why don't you people at FMCSA come in work 10 hours and get paid for 8 hours. We have seen what a mess FEMA can make now FMCSA is living up to goverment standards. How many people have to die or have ther health ruined to make FMCSA happy ?


Will W. Caruthers - Comments 10/03/2005 PUBLIC SUBMISSIONS
Why are you folks so hung up on this 14 hour limit? There can't actually be reputable science backing this up. If you say there is, then I'll ask you if you drive long haul. When it didn't matter how long it took to drive my 10 hrs (pre 1/1/04 rules)I was not in a hurry. I rested, stopped, and was generally far more relaxed. When the 14 hr limit went into effect I was under far more pressure, and found myself driving tired far more often. I learned to use the sleeper berth split to rest, but now I can't even use that without endangering my drive time and schedule. Are you trying to kill me?

Okay, got that off my chest. Whew! I'll get down to the meat of the issue. As a seven year plus driver, I feel I can offer an informed opinion. So, for what it's worth, here goes. I don't mind the 10 hour rest requirement. I don't care if the drive time is 11 or 10 (Though of course I prefer 11.). I LOVE the 34 hour restart (Most common-sense regulation to come down the pike in a long time. Y'all deserve kudos for that one.). I feel the 14 hr limit is unreasonable, as I'm gonna get that full 11 hr drive time in even if I have to splash ice water on my face with both windows down while singing the Battle Hymn of the Republic at the top of my lungs. I support my family by driving, and I am not going to be cheated out of drive time, and thereby out of $$$. I am NOT ALONE. The one saving grace was that as long as I could stop for at least two hours I could rest and not have it count against my time limit. Now, you've taken this away. Oh, it isn't really gone, of course. I just have to take 8 hours off now. But what if my schedule only allows for an extra three hours or so? Under the old rules (pre 10/1/05) I could catch a nap and be bright-eyed and bushy-tailed. Under the new ones I'm gonna keep going. I'll be driving completely legally, and possibly very tired. Isn't that what you folks are trying to avoid? This change does not further that goal, but rather places it further away.

Okay, so I should call my dispatch and say, "Sorry, I'm too tired to drive but by taking the 8 off the law now mandates I will miss my delivery and even though I know my own body and a couple of hours of downtime is all I really need I have to take the full 8, and thus miss my delivery." Great. So do you guys hire drivers? 'Cause I'm gonna need a job to go to after I lose this one. No company is going to stand for that for very long. And I won't either. You're asking me to take a cut in pay, and no matter how long I boil it I have not been able to get the kids to eat shoe leather and wood. They prefer food. That costs $$$.

So, to sum up, I think you guys really need to step back and take a breather and ask yourself what this 14 hr time limit accomplishes. If you really think about it, you know I'm right. If you must keep it, then at least allow us an avenue to rest without counting it against us. Why make a disincentive to rest when your purpose is to reduce driver fatigue? The answer, and the core problem, is that you guys are losing sight of the fact that it is ultimately the driver that will decide when he or she is tired. You will never be able to make a one-size-fits-all law that if followed to the letter will make everyone a safe and rested driver. We are all different. So, you have to instead provide us the tools to modify our driving to fit our needs and trust, just a tiny tiny bit, that we care about being safe drivers too. Most of us out here are not young, and we have families. If you give us a choice, most of us will take the rest and be safe. And those who won't aren't very likely to follow any law you make anyway, right? ;-)
Thank you for your attention. And all the best to you and yours.
Will Caruthers


Samuel L. Schuff - Comments 10/03/2005 PUBLIC SUBMISSIONS
General Comment:
we need to have ther ability to nap, or otherwise rest in the middle of the day without using up our 14 hour duty period. i usually run irregular routes. i like to start at 0700. as it is now(new regs), i must stop at 2100. howevewr, under the old regs, i could stop in the middle of my day, sleep for 2 hours, and continue on until 2300. much better. you are going to cause MORE TIRED DRIVERS, because once the clock starts, it doesn't stop. therefore, if i am tired, i must push on, because 2100 (or whatever time the 14 hours ends) is coming, and i can't stop it.


Ralph H. Brainard - Comments 10/04/2005 PUBLIC SUBMISSIONS
General Comments:
The HOS that went into effect on 10/1/05 will only essentially force me to drive longer and possibly more fatigued than I have in the past with the split sleeper options.


Douglas M. Fabish - Comments 10/04/2005 PUBLIC SUBMISSIONS

The new hours of service will just continue the tradition of cheating on log books because, in all practicality, they are unworkable. There are not enough parking spaces, they don't take into account human behavior, and they are just downright dumb.

Pretend I'm 23 years old and last night I met the love of my life. You are t elling me that I dare not stop for a nap after I have been up all night because that would violate your law. Think about it. Remember how you behaved when you were 23? Do you think that legislation is going to change human behavior?

I don't mean to be offensive but you folks make it so painfully obvious that you are completely out of touch with the realities truckers face.


2298 Michael W. Martin - Comments 10/04/2005 PUBLIC SUBMISSIONS
I really cant understand making teams stay in the sleeper fot 10 hours. My wife and I are team drivers and this is not going to work for us at all. The reason is if I drive 10 hours and go to the sleeper birth how in the world am I going to sleep for 10 hours while the truck is going down the rough roads we have today? The 5 and 5 works geat for us, it provides us with more sleep than we need(1/2 of 24 hours.The thing that i wory about is if I drive 10 say from 10pm untill 8am and try to sleep I am only going to get say 4 or 5 hours of sleep and then will role around in the sleeper for the rest of my break. Therefor when it is my time to drive I will be tired and therefore unsafe to be on the highway, Where as if you break 5 and five you are assured of getting at least 4 hours of good sleep and will be rested when it is your turn to drive,making all of us safer on our highways

Thank you for allowing me my comment.


Dena Espinoza - Comments 10/04/2005 PUBLIC SUBMISSIONS
The new hours of service are no where as good as the previous ones. WHy do you want to creat more welfare families. that is what you are doing. Why can you not put limitations on how long a person in a car can drive. Truckers are professional drivers who are trained to drive long hours cars are just idiots who cut them off and cause the accidents. SOrry but this burns me up If it were not for these dedicated men and women you would not eat or drink. Think about it are you ready to give up your t-bone steak and filet migon. That may happen and I hope it does I really hope the teamsters fight hard and win. Even if it means they shut everyone down for a couple of days boy that would hurt and I am already for It at least I will have food here. The old rule is one that should have stayed in fact I see nothing wrong with letting a driver drive 12 hours a day with 3 hours on duty for loading and unloading.What is the difference between that and some idiot in a hurry to start vacation and driving 20 hours to the beach, or working 12 hours and driving 2 hours home and going out to eat and driving more. YOu know I am right the people in cars are far more dangerous than those in the big rigs at least you do not see but what maybe one in a hundred drunk truckers if that but how many drunks so you see in cars and that makes them even more lethal than trucks. Truckers are a vital part of our economy and if you slow them down then we are hurting even more for the cost will go even higher and those who make under 10 an hour will end up on welfare. How about you guys on capital hill getting smart and let the truckers do their job, can the pat and crash trouble makers, and get on with life. MAN LET THEM DRIVE!!!!!! Our country is already hurting why hurt it any more. why create more welfare families, why not put restrictions on four wheelers make them carry a log book too. Pull them for being overweight. I have seen a lot of overstuffed cars on the highway.


Kelly J. Pering - Comments 10/04/2005 PUBLIC SUBMISSIONS
I fully agree with the responses to the Petition that have been filed by OOIDA and other organizations in regards to the HOS revisions regarding the mandatory eight hour requirement for team drivers. My husband and I team drive and this is the most ludicrous implementation of unnecessary regulation to the industry I have ever seen. This is completely over the top telling OTR drivers that they must stay in an enclosed and small space for their own good. Not only is this not good for morale of the drivers and business, it is also unhealthy due to constraint of movement and can cause additional blood flow restriction for drivers, as well as, unintentional additional weight gain. This is the most dangerously unhealthy requirement I have seen institutionalized in the industry and should be thrown out of the HOS quicker than it was adopted.


Laci Mulder - Comments 10/05/2005 PUBLIC SUBMISSIONS
I must say these new Hours-of-Service rules are absolutely insane and obsurd! Has it gone so far that you lack common sense now? How can you possibly expect anyone to drive for 11 hrs straight and not get drowsy. By taking out the option of the split sleeper berth, you are forcing drivers to continue to drive even if they become sleepy! Now how insane and obsurd is that? There are many many times that the option comes in handy --- too many to mention but most of all - safety! Isn't that the number 1 issue here? Safety! Or am I mistaken? You seem to be wandering farther and farther from taking safety and health into consideration. Is it now just an economic or political issue! Come on people. Get back on track. The safety of the drivers (America's backbone and provider) and the safety of the others on the roads needs to be the number 1 issue here. Give back the split sleeper option and stop trying to please the public citizen groups who've never even sat in a big truck. They can't possibly understand what it's like unless they've been there. It's truly a matter of safety here. I can already picture the amount of deaths that WILL happen if this doesn't change and I personally, don't want to have to see it. People shouldn't have to die before others wake up. I don't want sleepy drivers barreling down the interstates with 80,000 in the box. Let 'em take a nap and still have their 14 hrs to play with. God bless! Laci (a proud & loving trucker's wife)


Anne M. Horn - Comments 10/05/2005 PUBLIC SUBMISSIONS

We as a company are extremely concerned with the lack of concern for the safety and smooth running for our team operations. There seems to be a lack of real life testing in the new rules. Also, the problem with parking required to accompany this new ruling has not been taken into consideration. For our business of expedited specialty freight we require team operations. The new ruling WILL preclude most team operations. We have many safe teams that run 5/5 as a rule. Few teams can operate safely for continued miles that are required under the new ruling.


Phillip S. Stodgell - Comments 10/05/2005 PUBLIC SUBMISSIONS
General Comment
I am again commenting on the fscma's lack of action or responce in the hos regulation pertaining to team operation and the split sleeper birth provisions. You are doing these drivers a disservice besides creating an un safe situation. Indirectly you are forcing drivers to drive when their tired or you will cause them to falisy their logs to be able to do their jabs as expected as the have in the past. You have createted a situation which is not acceptable or workable and refuse to even publicly defend your rule. Apparently you are unable to do so or you would. AS I have done before I have incouraged you to respond or call me for input.
Ihope this time you can do so.

thank you


David R. Scism - Comments 10/05/2005 PUBLIC SUBMISSIONS
General Comment:
To dot ruling
MY name is David. Ive been a truck driver for 12 years. what is safe about pushing drivers to drive and not giving them the oppion of taking a break or sleeper break. The new rule wants me as a truck drive to drive 11 hours and any breaks i take, takes away from my 14 hour day. When did truck drive loose so much respect that we have to be treated like robots. Last I heared we are the back bone of this great country. I would like to say I still have some freadom as a truck drive but, I done feel that way anymore. Please take into consederation that we would like to remain captains of our ship and decide when we are tired and be able to rest without it counting agianst are ablity to make a living. If trucking compies start offering hourly pay this new ruling might work.We are payed by the mile and I dont see that changing.
I feel that if truck drivers wages go down because of the new ruling that some drivers will choose to get off the road, that in turn; would force cost up and a shift in the economy.

There is so much more problems involved in the new hrs of service ruling. Take into concideration of asking exspenced drivers how they would like to see changes made.Go out with a drive and learn first hand what is like to be on the road. Most of all get to know us.

Sencerely,

Trucker Dave


Donna Sleasman - Comments 10/05/2005 PUBLIC SUBMISSIONS
I am very concerned with the new provisions of the HOS in the way that they relate to drivers as adults that know when they need rest and when they can contine to drive. I am quite sure no one is standing in the emergency room asking the Doctors and nurses there to be sure and make out a log, because they do not have the common sense to know when they are tired. I have been driving for 23 years and these new requlations have caused me more stress than I can discribe. The original HOS were in effect for many years, and I can understand why they required so much sleep time. The difference in the trucks they drove and the ones we drive today are night and day. I can sit in my air ride seat with my air conditioning blasting and listening to all the latest tunes, sit my cruise control and move my steering wheel every 30 seconds or so to correct my course, my truck does not have the old fashioned armstrong power steering (if you have strong arms you have power steering) My truck drives smoother and easier than my F-350 pick-up truck.

You always hear about how a sleepy truck driver caused an accident so we need laws to keep these bad people off the road but I will say that I cannot see where our drunk driving laws are keeping drunks off the road. I also know that logbooks are a joke, the only real reason that we will never eliminate them is that they generate so much revenue for state in logbook violations. If a law enforcement officer wants to write a logbook ticket he will find some violation to charge you with and you have little recourse in the matter.

We are adults who know what we are doing and I will do nothing to jeopardize my life or the $200,000.00 I have invested in my rig, I know when I need to sleep and when I can drive. There have been times when I wake up in the morning and start driving and 2 hours later I am sleepy and you know what I do? I stop and take a nap maybe 1 hour or 4 hours when I am no longer sleepy I continue to drive. But by the same respect I have awoken on a morning and started driving and 18 hours later I am still driving because I am still alert and awake enough to continue. So in my humble opinion I think we need to treat everyone like adults and let us do our jobs. We know our limits and we don't need Big Brother telling us how to do our jobs. Thanks for your consideration in this matter.

Donna Sleasman


Thomas M. Kinsey - Comments 10/05/2005 PUBLIC SUBMISSIONS
under your revised hos rules that went in effect oct,1,2005 i have worked a week under these rules and i;m am so much more tired i;m use to starting early in the am and stopping mid day to nood taking a 2 to 4 hour nap and cant do this now on the 14 hour rule if i stop for 1 hour lunch a 15 min pretrip 15 fuel 30 minute load/unload 2/15minute break that is 2 1/2 hours of my 14 hours day where is my nap time if i'm go drive 11 hours please reconsider your sleeper birth and put us a nap time in that will extend my 14 hourd if i stop to take a nap it will make the roads much safer and me healther tant driving so long without and nap break
thanks thomas kinsey


Shelley Froehlich - Comments 10/05/2005 PUBLIC SUBMISSIONS

I am writing to comment on the new hours of service regulation. It is my understanding that the purpose of the hours of service is to insure that truck drivers get adequate rest. The new regulations that took effect on Oct 1st do not increase a drivers quality rest time but, in fact, do the opposite. By not allowing the second sleeper berth time to stop the 14 hour clock, drivers will be forced to drive more hours without taking a break in order to maximise their allowable on duty time. This will lead to more driver fatique not less. Also, by not stopping the 14 hour clock with a break of 2 hours or more, a drivers available working hours will change each day. In other words, a driver starts his day Monday at 6 AM. He is done at 8 PM. He takes an 8 hour break and is allowed to start work on Tuesday at 4 AM. He can work until 6 PM and must take his 8 hour break until 2 AM. The rest periods change each day which is not condusive to quality rest. With shippers and receivers requiring on time delivers, drivers will have to maximise their available hours by working as soon as they are able to.

My husband and I drive as a team and the elimination of the sleeper berth provision will mean we have to drive 10 hours at a time. This is does not promote rested, alert and safe drivers.
Thank you for your attention to my concerns.


Peter Lapsansky - Comments 10/06/2005 PUBLIC SUBMISSIONS
HOS:

1.There is nobody on The world who believe drivers will be in sleeper berth 8 consecutive hours,if this break come in day time.
Why Ya doin law,whhich is wrong at the begining.What the matter if I watch TV at truck stop(save fuel,EPA,no idle)or will idle truck and watch tv in truck. This game with sleeper berth is in every direction going to dead end road,its enough any of duty 8 consecutive hrs,plus 2 hrs in 11 hrs period.You guys withraw this game in previous rules,and that opend this game.

2.Im one of the lucky guys(NJ)I sleep only 2 times in a week out,and I could use this break at home,what is lot better as sleeping in idling truck.Again EPA,fuel price,economy against uncontroled sleeper berth time.You guys are not gonna tell me sleep in sleeper berth while parking truck at backyard.

3.What I think,there is important recognize driving in nite and days.I dont drive nites,but I start 4:00,going to Pittsburg=350 mls.My first sleeping break is 6-7.Its just going once a day that one need to sleep.Trust me.If I do this,I can drive untill 22:00 without feeling asleep.Drivers who drive in nites got worse,so for em is good new rules.

My final answer is:If driver work less than 3 hours beetwen 22:00 and 6:00 old rules was good.For this OTR long haul drivers new rules are OK as well. Generally:new rules hurt teams.They will drive tired.This is not win of PATT,its simple loss.They pushed this guys drive consecutive 8 hours(until codriver got break). I think Yo have to put more science and physician opinion about quality of sleep rather than vox populi.This is professional job and vox populi must be in 2nd line.#1 science.And forget forewer about making diference beetwen sleeper berth and not sleeper berth.Wrong way.Guys got TVs,PCs,play stations in trucks.There is no power(except biological clock)to press them sleep.Only they idle truck for nothing.They can do the same at truck stop without idle.Watch TV.And another pro is(ask scientist,physicians).Truck driver is lonely job.One likes just see people,spent some words,talk about job and whatever.But if ones biological clock says sleep,most drivers stop closest area and sleep.Who didnt will not.I do every time.When my eye muscles start shaking Im going to sleeper berth.This is always personal issue only.One knows daed line one doesnt.Im awfull sorry for victims of accidents,but Im sure PATT(and followers)are not gonna help.This guys are simple against everything,thats kind of insane.Thousands of people dying yearly by shot guns and there are still no gun control regulations.Trucks are brining bussines,goods...guns?Bad words...its not neccesery in 21.centutury.

However:If Im at yours place,I will do everything thru science and phycicians who can says about sleep and when starts danger.I tell ya,first 3 hours after sleep are critical to fell aslep if starts b4 6:00.And who drives over nite:Will never get quality rest in day time!!!Go to club,party and go sleep 4:00.How ya will feel.And still one dont have 80000 pounds and thousands in value and existence in hands.Until one do not get quality sleeping time over nite.One over nite driving srew up whole biological clock and sleeper berth do not help get it back.New rules simply pushing drivers drive over nite nonstop.Or will lie. From other barrel:Finally guys get something into theirs heads.I see more states allow drivers sleep at exit ramps without police bother em.Its better let em sleep as roling on the roads.I dont like it,but 2-3 hrs in nite time,when at truck stops is not parking space.

And last barrel:Penn guys lost case when trucker recorded,what he thought unsafe,police inspection at shoulder.This guys are crazy.If they dont like theirs life its ok.Just start police car,get 100mph and drive it straight into a wall.But why they going to make troubles to others I have no clue.They do inspections:I-78,80 just past toll after cross bridge from NJ.If I use right lane thru toll I just touch theirs backs.I bsolutely feel no safe.No one likes his name in newspaper about kill trooper.Also they do it at toll I-76 exit 71(I-70),and on I-76(Penna Trpk)at places marked as Emergency parking only.In westbound I-80 there is a scale(mm about 150-200)but this guys bother drivers at rest area.Does it other states?I know NY.In Maryland this bothering get iceberg.I was tired as hell.Midnite.Pulled into a closed scale.Sleeper berth in my eyes.One hour inspection.Virginia is nothing special,but after they stopped bothering truckers at rest areas,they simply got culture.Plenty scales,open 24 hours,but culture.There is a time for federal gov make some standard.I really dont care about check me out(got 2004 truck,hauling max 54900 pounds)but safety first.Get troopers out of shoulders doing inspection.


Robert A. Oimoen - Comments 10/06/2005 PUBLIC SUBMISSIONS
General Comment:
I am writting in regard to the hos changes that became effictive 10/1/05. I dont understand why you would do away with the split sleeper berth logging. I myself frequently need to rest for 3 or 4 hours in the afternoon before continuing on my journey. It helps me to be more alert. Now this time is lost to me forever because my 14 hour clock does not stop. So now I have to drive when I am tired so I dont lose the time, not very safe is it. No professional driver should be punished in such a way for stopping and getting some rest. I am betting this will result in many more accidents on the highway, and their are already too many memorials along the highways now, what with the states raising the speed limits all the time. Why dont we try and make the highways safer instead of more dangerous. Repeal these changes before some innocent people gat killed by a tired truck driver who cant affort to stop and get some rest. The law should be changed back to 10 hours of driving and an 8 hour break with a split. It worked rather well I think for over 60 years. Please give me some feedback on this and tell me who in the world dreamed this up, they must want to see memorials along the highway.


Jan M. Thornton - Comments 10/06/2005 PUBLIC SUBMISSIONS

General Comment:
My husband & I have run team (48 states) since 1997.We've run 5 hrs on, 5 hrs off and successfully so (no tickets, no accidents, no out-of service, no claims, etc.) New HOS removes our flexibility in keeping our truck running safely on the nation's highways. The person who was on their "off" 5 almost always ended up with more than just 5 since the driver saw to fuel, personal needs, etc. Should the driver become fatigued, adjusting the driving schedule could be legally done to accomodate personal need. Also, our freight is usually military which requires that at least one of us be alert & in the driver seat or within 25' of the visible truck at all times. Couple this with the requirement to only be stopped for brief periods and you can easily see how the new law is restricting flexibility and creating an unsafe situation during long distance travel with high security freight.
Jan Thornton


Denison Phelps - Comments 10/11/2005 PUBLIC SUBMISSIONS
In regards to the new hours of service regulations, it accomplishes two positive changes. More need for COMPETENT officers, and more revenue can be generated. The negatives are too numerous to mention.

Other than retrain entire trucking fleets, (which FMCSA does nothing to educate, but plenty to chastise) what good has come out of these regulations? Maybe when a few more people die, and PATT runs out of money, FMCSA will write some rules that make sense. Until then driver's will just have to figure out these new regulations, and how best to get around them. Denison F. Phelps Jr. Mesa, Arizona


Lenny J. Kovacich - Comments 10/11/2005 PUBLIC SUBMISSIONS

Ms. Sandberg,

I am writing today regarding the new Hours Of Service Rule effective October 1. This is a bad way to resolve the problem the trucking industry faces.

This rule creates a situation where the driver is not able to take a break when they feel the need. The driver is forced to continue on due to the fact the 14 hour clock will not stop. You must understand that a certain amount of work needs to be accomplished every day. There are concerns about weather, accidents and other sorts of delays that cannot be anticipated. The 10 hour break forces drivers to arrive very early at their first stop each day to amass enough time to move on after the delivery is completed.

More and more companies are not allowing trucks on their property more than one hour before their appointment. This means that the driver must start their day and immediately wait and “burn up” a substantial amount of time at the beginning of their day. This has a horrible effect on the amount of miles traveled each day. The productivity of this driver is limited substantially. Time at a dock although lengthy usually is poor sleep time, but the ability to stop the clock helps so that the driver doesn’t feel chained to the wheel until his 14 hours are up.

A certain amount of independence is necessary to perform this job. Most drivers do not need some one looking over their shoulder to be sure their job is done. That is why this rule demanding they sleep when they are not tired and drive when they may be is so bad. I hate to see this rule implemented because it is contrary to the reason it was put in place. This rule will create more tired over stressed drivers than the old rule.

The men and women that deliver the goods all around this country look at safety as a very important part of their jobs. This rule is counter productive to safety. I hope that through further analysis the split sleeper provision will and should be restored to give the men and women the flexibility to do their job as safely as possible with their rest intact and the safety of all who travel our highways utmost in their minds.


Gene Cavar - Comments 10/11/2005 PUBLIC SUBMISSIONS
concerning the new hos reg, it is a big mistake. After trying it for a week,I am almost ready to look for a different occupation. I did like to drive truck, but am starting to hate it. Iam stressed out to the point of not wanting to drive. Here are a few of the probelms.
it forces us to drive during rush hour to deliveries. before,if I had a 5-6 am del in la, i would get there at 2-3 am, and sleep for a while before my del. now i am forced to wait, and fight rush hour traffic geting to my del, which causes a far greater chance of being in an accident it also causes me a lot more stress. another probelm is trying to be at a place you can stop in 14 hours. is not possible to do, much of the time. what is it we're supposed to do? if anything we needed more control over our time, rather than none. this having to stop for 8 hours to stop the 14 hrs is a joke. do u think u can make me sleep just because i have to say i,m in the sleeper? if we,re stopped geting loaded or unloaded for 4 or five hours, now we,ll have to stay for 8 hours, and end up driving way more tired than if we had just been able to go. i already know from doing it. the persons that came up with the new rule should have to be out here trying it. it,s just not gona work. about half of us will be looking for other jobs.
GENE CAVAR
maybe soon to be an X truck driver


James M. Bland - Comments 10/11/2005 PUBLIC SUBMISSIONS


i would like to comment on the 8 and 2 rule as an over the road driver with a great driving record. i would like to ask someone from the board to come and ride with a trucker see how we operate and perform. this is the only way you will ever ba able to make decisions for us not by some research some college kid who has never even been in a truck wrote. the rule does not stop the 14 hour clock for the second 2 hours and no provisions for team drivers. i personally like to be able to stop and take a nap in the after noon but now i can't since i have to watch that 14 hour rule. one traffic jam or traffic accident and my load is late and i am serching for a job. i don't in any way think you have a vendetta against truck drivers i just think you are getting wrong and unrelating info from your advisers. so please come out and ride with us get to know us (i would like to personally invite you to ride with me) and we together can make rules that make sense and save alot of time and monies in the court systems.

Thank you for your time

sincerly
James M. Bland II
driver for Keen Transport(PDQ Division)


Timothy D. Guillaume - Comments 10/11/2005 PUBLIC SUBMISSIONS

Hours of Service
I am sure it comes to no surprise to find that someone is screaming about the changes in the Hours of Service Rules for truckers. It is amazing to me that it seems we must test the rules out first (see how many wrecks they can have) before we decide if the “revised” rules are sufficient. There are many factors in the business to affect a trucker’s day. Truckers are preached to regarding how, when, where, and what they will be regulated on. Truckers are told that AWARENESS is number one in the industry. With the changes in HOS rules and growing industries (over the past years) putting more trucks on the highway, why do we not raise the AWARENESS to the public?

Problems with “revised” HOS rules that were put into effect 10/10/2005:

Teams will be forced to drive 10 and 10 instead of 5 and 5 – Solo Drivers forced to keep driving Forcing drivers to drive in order to keep freight moving without the possibility of a much needed rest break (for fear of breaking the law) is UNACCEPTABLE.

Here is where the awareness comes in. I KNOW that most people even in offices of a trucking company or a shipping/receiving department DO NOT KNOW OR DO NOT UNDERSTAND how the HOS rules work nor do they comprehend how the HOS RULES can and will affect the ability to move freight efficiently. Therefore; the responsibility falls on the driver(s) to log how it can most benefit them to get the job done.

If we keep the HOS rules in effect, why can we not regulate these shipping/receiving departments to keep drivers on schedule? We have a choice:

A) We can continue to put peoples’ lives at risk by strictly regulating and not giving drivers flexibility in their rest/driving or

B) We can continue to keep things in an uproar because these mega-companies have the power of the almighty dollar.


May the best choice be made.
Timothy D Guillaume
T&W Services, Inc.


Mark J. Nash - Comments 10/11/2005 PUBLIC SUBMISSIONS


Upon completion of my first week of the new HRS rules I have discovered that in order to keep compliant this new rule now forces me to continue driving when I am tired. Not stopping the 14 hr. clock (with a break other than 8 hrs.)forces an individual to keep driving when tired in order to maintain schedules and on time deliveries. I have tried your new rules and they have made doing my job and supporting my family very difficult. Please consider at least making a change to make the 2 hr break stop the 14 hr. clock.


Randall R. Stohlman - Comments 10/11/2005 PUBLIC SUBMISSIONS


In the new rule on hours of service and off duty / sleeper birth time and the start of a drivers 14 hrs. The new rule is that for sleeper time to come off the 14 hrs of duty it must be 8 consective hrs in the sleeper. What if one has to get out of the sleeper to use the restroom after 4 or 5 hrs of getting bounced around. If one gets out of the sleeper at a rest area or truck stop does that break the sleeper time? Also, sleeper team starts Monday morning at 4 am after having Sat and Sun off, does both drivers 14 hrs start at 4 am ? Does the second driver have to get in the sleeper for 8 consective hrs to keep his 14 hrs from starting or does his 14 hrs start when he comes on duty to drive? If a man and wife team get a motel room for 10 or more hrs off duty then start at 4am does one of them have to stay in the sleeper for another 8 hrs to keep from starting the 14 hr period. If after 10 hrs off duty one goes in the sleeper for 4 hrs then starts to drive do they only have 10 hrs left of duty time? If one has a large walk-in sleeper it is easier to spend 8 consecetive hrs in it than in a cab-over with a small sleeper or in a small coffin sleeper. I know the intent of the new rule is to get drivers to get the rest they need to be safe but most drivers can't stand to be in a sleeper for 8 hrs with out a break getting out. Many drivers have spent many years driving 4 on and 4 off and it will take time to retrain themselves. Many drivers do not sleep 8 hrs in a row at home when off duty. Thank you


Gary J. Davis - Comments 10/11/2005 PUBLIC SUBMISSIONS

I disagree 100% with the changes that became effictive Oct 1,2005. I have quit my company in response to the new rules concerning the non split rule. I see it as unproductive and unsafe to my career of 12 years and will be looking for another profession. I have been a safe courteous driver,never an accident in a commercial vehicle and i have no traffic violations. On the first dispatch under this new rule i took an 8 hour break from 1:oo am and finished an off duty of 2 additional hours. I was late on my delivery of 16:30 the same evening because I was forced to shut down for the minimum of 8 hrs and had to reset my 14 hour clock to run again. If i were to continue to drive i would not abide by the new 14 hour rule and would not be driving for J.B. Hunt where the drivers movements are recorded. I suspect other drivers will find alternate ways to drive safe,take breaks and be on time with their deliveries.

If i am forced to "punch" a time clock and drive 11 hrs straight when tired because of losing time not allowed off duty for a few hrs rest,then i'll give up my career in trucking and punch a time clock at home and go home after an 8 hr shift somewhere. I've enjoyed driving but it's over now,new rule,thanks but no thanks.



David E. Gaskins - Comments 10/11/2005 PUBLIC SUBMISSIONS
Greetings Director Sandberg,

I am an Owner-Operator, currently leased to one of the five largest carriers in the nation. I have over 15 years of local and long-haul driving experience, and have been CMV Driver/Trainer a for well over two years now, with that same carrier.

In regards to the Revised HOS Rules that went into affect on October 1, of this year, I personally think that when the FMCSA was reviewing the HOS rules, no thought was ever given to CMV Student Drivers.

I have personally had a hand in training over 40 students, and almost each one of them has told me that they have only received about 10 hours of actual driving time before they were issued their CDL, so therefore they have virtually no practical experience when they step into the cab of my truck. Now, I don't know if you, or anyone else in the FMCSA has ever driven a CMV before, but I can remember my first time behind the wheel of a truck, and I can honestly say that I was very intimidated, and even a little frightened. Consequently, I only drove for a short periods of time for quite a while until I gained enough experience and confidence in my driving abilities to safely drive a CMV down the road, much the same way as many of my Students.

Even though I am a Driver/Trainer, and I have Students with me, we still have a responsibility to our customers to deliver their freight on time. Trucks move America, and trucking moves our economy.

Under the HOS Rules that went into effect on January 4th of 2004, if one of my Students wanted to drive for a short period of time, it was not a problem, because I could begin driving and usually still deliver the freight on time.

Under the new HOS Rules, the fourteen hour clock begins as soon as the Driver inspects the truck before staring the trip for the day. Now, my Student wants to stop driving and I have to take over, by the time I stop, his fourteen hour clock has expired, and he will be out of available driving hours for the day. Now, we have to shut down and wait until one of us has accumulated ten hours of off duty or sleeper berth time to complete our rest period and only then may we legally proceed.

If the Student does not wish to stop, then he is forced to drive for at least nine hours, while I accumulate ten hours of off duty or sleeper berth time to complete my rest break. This is a dangerous trend. May new drivers have never driven that long or that far in a single day, an being so nervous behind the wheel also tends to place a lot of stress on a person, which can lead to fatigue.

If the Student chooses to stop, then he is shorted on his training hours for the day, and the load will probably be delivered late. Late loads slow down the chain of supply to retailers, which can cause prices to rise, and slow down our economy. If he chooses to drive a nine or ten hour shift, like many do, then he may get tired, and we all know what comes next.

My carrier requires each student to complete 275 hours of behind the wheel experience before they will be granted permission to take a road test, and be promoted to a qualified driver status. In most cases it takes an average of eight to ten weeks to gain the required hours necessary to "graduate." If Students can only drive short periods each day, that just prolongs the training program. Now, that might seem to mean much to the FMCSA, but most of these Students are not being paid very well during training, so they may have financial problems. If they have a family at home they are trying to support, the problem is magnified. So, the pressure placed on these individuals to complete the process as quickly as possible is great. They are already “pushing” themselves, why make it even more difficult for them?

Even if a Student, Driver/Trainer, or Team Driver actually does accumulate ten hours in the sleeper, that does not necessarily means he get a full ten hours of rest. It can be difficult to sleep in a truck as it bounces down the road. Trucks do not ride like a Cadillac or a Mercedes Benz. They bounce, shake and vibrate quite a bit. One ride in a sleeper down Interstate 94 from Detroit to Chicago, and you’ll understand exactly what I mean.

There are times when I simply cannot sleep. Then there are other times when I will sleep a full ten hour shift. I’m sure the FMCSA is fully aware of the demands placed upon CMV Operators, by shippers and consignees.

As I Trainer, I am up and down continually during my break helping my Students solve problems, so again, I don’t get much sleep sometimes. There are occasions where I have become overstressed from driving in poor conditions or extremely heavy traffic, such as the recent mass evacuation of Houston, Texas in September of 2005 and when I genuinely needed a nap after driving seven hours in unimaginable traffic. Other times, like everyone else, I occasionally get sick, and need a short break. After I awake I feel much better and I am safer on the road. During my career as a tow truck driver in Southern California, I never got much sleep at night, because I was busy running calls, but I discovered that short naps helped me stay alert throughout the day.

I do not think that the FMCSA took any of these instances into account when they were drafting the Revised HOS Rules. They have virtually eliminated rest breaks by not allowing drivers to stop the fourteen hour clock with a break of two hours or more. Yes, I understand we are allowed to take a break of eight hours, but why would I take a break for eight hours, when I can take a ten hour break, and gain back a full eleven hour driving shift? It’s simply not practical to do that.

So, tell me again, how do these new HOS Rules help us? How do they make drivers safer? How does it help the economy? How does it help trucking companies to retain drivers?

I suggest a set of HOS Rules that work in the real world. I would be more than happy to take along a representative of the FMCSA on a week long trip so that they may experience what actually goes on out on the road, so the FMCSA can draft a set of rules that make sense. I understand that not everyone will be pleased with the outcome, but as long as the rules are fair and reasonable, I think most drivers would be more willing to abide by them.

I do not see how this Revision of the HOS Rules help anyone, and I support the exemption put forth by the Owner Operator/Independent Driver’s Association, for team drivers.


Arne H. Lindgren - Comments 10/11/2005 PUBLIC SUBMISSIONS

I have been driving for 20 years, 16 out of those years in sleeper-team operations with two major US carriers. It came as a chock to me to find out on Oct 4th that the split sleeper berth provision had been eliminated on Oct 1st! Me and tens of thousands of other team drivers have been very safely and successfully splitting our driving time for years and years, and been able to stay alert behind the wheel by doing so. I feel like FMCSA is COMPLETELY ignoring the concept of sleeper team driving. The whole idea with the concept is to be able to run a team around the clock without allowing each driver to get too fatigued and worn down. With the original rules, we had a choice. We could run between 4 and 5 hours on and off, or we could run 8 on an 8 off, or for those that wanted to, they could even do 10 hours on and off. Then the rules changed a couple of years ago and we could do between 5 and 5.5 hours on and off, or between 10 and 11 hours driving on and off. Now, to my surprise you are FORCING us with your cookie-cutter approach to run AT LEAST 10 hour shifts. How would you people in FMCSA feel if you were forced by law to work 10-hour shifts before you could get any rest, then having to get your sleep in the sleeper berth of a truck bouncing down the rough interstates of this country?

It's impossible to sleep for 10 hours in a moving truck, you only sleep if you are tired, then you just have to lay there for the rest of the 10 hours until your partner is done with his 10 hour shift. FMCSA is really shooting itself in the foot this time. With this new law change a dangerous unsafe situation has been created. Team-drivers who have been used to driving and sleeping 5-hour shifts safely for years will be forced to drive fatigued for 10 hour shifts. I fear that deadly accidents can occur because of the new law. The basic problem is that FMCSA has no real understanding of the concept. To live and sleep in a truck in a sleeper team operation is not at all the same as when someone sleeps in a parked truck or at home in bed. A sleeper team works a very fine-tuned and efficient operation, that can take months to get to work just right between two dedicated drivers.
Arne Lindgren


Daniel R. Cope - Comments 10/11/2005 PUBLIC SUBMISSIONS

The new hours of service rules change has had an adverse effect on my team runs. We do multiple drops throughout a 4-5 day period each week. This rule forces drivers to be behind the wheel when he/she does not belong there. Forcing 10 hour shifts is not a way to assure proper rest. I've been in the transportation field for 26 years, with 10 of those as a driver. I understand that rested drivers are the top priority. This is simply a bad regulation that will not accomplish getting that rest for the drivers. Dan Cope


Greg S. Malson - Comments 10/11/2005 PUBLIC SUBMISSIONS

I think the "new" revised hours of service do not address the issue of drivers health. They currently will entice a driver to drive even if he/she feels the need to to rest for brief period. If left to thier own devices, drivers would rest when needed. The threat of not "getting the job done" by carriers and shippers will prevail over the basic needs of drivers. Trucking is not a 9-5 job, and should not be treated as one. The burden should be shifted to the shippers/carriers/receivers to assure scheduling in a consistant manner with drivers health and needs. I myself prefer driving at night, and try to arrange my day to accomplish my desires. If I am to comply with the new revisions, it forces me to drive at a time when I would prefer to be resting or tending to personal needs. I feel that a 14 hour work day is fair considering it is 6 hours more than office workers are required to work. I feel that drivers should have a full 14 hours, in any increment that they want, in a 24 hour period. As long as they do not log more than 14 hours in a consecutive 24 hour period. The 8 hours sleeper, and 2 off duty should also be allowed in any manner. this is how most drivers operate anyway. The only thing is that drivers log it the way the rules mandate that they do, but are driving and taking the breaks and naps when it suits them. If driving "Utopia" did exist, we would not deal with contruction backups, or rush hour traffic or things of this nature. Why should a driver be forced to deal with things like that when he could take a couple hours break, and then finish his 14 hour cycle? Maybe the folks making these rules should quit looking at studies and test subjects, and come out in the real world with real drivers. It is an open invintation.


Lonnie G. Bow - Comments 10/11/2005 PUBLIC SUBMISSIONS

due to the new hours of service rules there are alot owneroperators that will be going out of buisness!all those new rules are for one thing."money" you know it! "it is nothing about safty"if a driver can't stop the clock to get a couble hours of rest he will go till his 11 hours is up. this will make him more dangers on the road.


Gary R. Pierce - Comments 10/11/2005 PUBLIC SUBMISSIONS

I am a truck driver operating under the HOS regulations. I have a suggestion concerning hours of service and requirements. I have driven for close to fifteen years and deal daily with the regulations.I understand the desire to improve safety on the roadway and share that desire. I think however, that sometimes there is a rush to fix a problem because there is overwhelming criticism coming from certain groups who seem to have a public ear via the all consuming media attention on terrible news that we see on television each day. The end result may serve to quiet this attention for a while, but never for long because the source of the problem is not addressed.

The vast majority of time that truck drivers have to try to exceed the rules or go around them is because of inefficient shippers who do not seem to have a reason to get your truck loaded and get you on your way to delivery and receivers who do not give enough flexible time for delivery. Often it does not depend on when a shipper decides to get you away from his dock as to when a receiver tells you to get his freight there. They very seldom care what is required to get their freight there as long as you do so. If you are late for whatever reason then they might unload you or decide to make you sit because you were "late".

It seems to me that since the driver is the one responsible for getting there safely as well as promptly, it is the driver who should determine what time that would be instead of people whose only interest is getting the freight on their dock. Until this problem is addressed, you will continue to have tired drivers on the road trying to keep their job and feed their families. The people helping you try to set reasonable regulations should not be special interest groups who know nothing about trucking yet seem to know how to tell everyone else how to do their job.

I don't personally know one driver who wants to drive while they are worn out. The problem is always someone who wants their product asap or sooner and put the burden on the driverto get it there regardless of the situation, yet it is the driver who assumes all the risk and liability if something goes wrong or gets checked somewhere along the line and gets fined a whole weeks paycheck or more, trying to do what they want and demand. It seems to me that there ought to be a recourse for drivers to get something done about customers who make unreasonable demands on them, yet have no one to answer to. That all falls at the feet of the driver.


Alice A. Fairchild - Comments 10/13/2005 PUBLIC SUBMISSIONS

The new HOS revision is a huge mistake. The 2003 rules were working fine. Instead of screwing up something that works, you should work on justifying the 2003 rules. In addition, was any of the sleep research actually conducted in a truck? You try sleeping in a running/moving truck. Also at age 37 I have never slept more than 7 hours in my life. Telling myself and other drivers they must spend 8 hrs in a sleeper berth the size a broom closet is outrageous. I am an adult. I know when to go to bed and I have enough sense to park if I am tired or sleepy. Leave the 2003 rules as they were originally released, justify them to the court and let us do our jobs


Gene Cavar - Comments 10/13/2005 PUBLIC SUBMISSIONS

Regarding the HOS regulation taking effect October 1, FMCSA has finally came up with a rule that is not possible. Drivers need more control of our time rather than none. I know where I can be in ten hours. This new rule forces us to drive during peak times of traffic. Before Oct. 1, we could go into the cities before or after the traffic jam, now we have no choice but to fight heavy traffic, which will be causing many more accidents.

People who think that an hour to two of sleep does no good, is a fool, ask the State Patrol in any state. This new regulation will make many drivers look for another job. The people that thought up the idea that we have to stop for eight hours to stop our 14 hours, need to come out here and try it. I have and it just won't work. I have never felt so much stress since this regulation was implemented. Gene Cavar


\ Anonymous - Comments 10/13/2005 PUBLIC SUBMISSIONS

Your going to have to change this law in the very near future,and while I know that the authorities are understanding, this law needs to be right the first time. Its a dangerous job and the last thing that needs to go into effect is confusion. and youll be creating more on top of that. Every one is different and you cant lump them all in the same constraints. The old way wasn't good enough and youll be changing this new one too. Driver's arn't represented because there going up and down the road. And the poster children for the drivers dont have problems driving. You need to be in touch with the average driver on down


Lance E. Fontanne - Comments 10/13/2005 PUBLIC SUBMISSIONS

I would hope the old sleeper berth split break rules are reinstated for drivers. I have been a driver for 34 years, and I have always ran a split break because it reduces fatigue. All the new hours of service regulations in the last year or so have only INCREASED fatigue for the driver. Too much time behind the wheel at one time. I prefer to drive 5 hours, sleep 5 hours, then drive 5 hours again. With the increased traffic congestion all over the country, I believe this is necessary to retain the old sleeper berth split-break rules. Also it enables me to avoid big city rush hour traffic when I can split the break as the old rules enabled a driver to do. I further believe it was a mistake to add the 11th hour of driving; that increases fatigue and has a detrimental effect on safety also. I do agree with the 34 hour restart provision though.


Anonymous - Comments 10/13/2005 PUBLIC SUBMISSIONS

This amendment takes all the flexibility out of a driver's schedule.If I arrive at a receiver at 2 A.M. and they don't receive till 7 A.M. I have 5 hours to deal with,I like most people am tired[body clock]and ready for a nap.But if I show this as time on the clock I lose that much for the rest of my day. There's an awful lot of freight moved after dark and a lot of drivers in the same predicament that I just described.Why not let us decide when to rest?And adjust our schedule to avoid traffic[like Chicago]I could see splits of 6hrs and 4hrs to get some quality sleep but 8 just becomes hard to work with in regional operations.
Thanks for your consideration


Anonymous - Comments 10/13/2005 PUBLIC SUBMISSIONS

with regards to the docket # FMCSA-2004-19608, I wish to express my concern for all teamdrivers having to follow the new legislation. Being the spouse of a veteran 35 year, accident free, 1 million mile + truck driver I am concerned for his safety and health. ALso the safety and health of his driving partner for the last 25 years. They have always followed the letter of the law concerning legal logging of their time. Rest is almost a joke when 10 hours of sleeperberth is required. Have you locked yourself in a closet for 10 hours and then had that closet rocked, rolled, bumped, jerked, slammed to a stop and been sleeping thru all of it! I don't think so or you would recognize the ignorance of even thinking this is possible. Also, have you been in a vehicle when the person driving is not feeling well, usually you can stop or take over the driving. With truck drivers under this new ruling will not allow for any deviations for this problem. The scheduled time for the delivery of the load had just been jeopardized and so has the employment of the team who cannot make the appointed and expected delivery. PLEASE MAKE EVERY EFFORT TO REVIEW THIS LEGISLATION AND USE STATISTICS THAT ARE FROM THE PEOPLE EMPLOYED IN THE PROFESSION-- NO A FACT FINDING COMPANY WITH NO TRUE EXPOSURE TO THE SITUATION. THANK YOU S For many other reasons,too numuerous to continue,


Janice Schuette - Comments 10/14/2005 PUBLIC SUBMISSIONS

You have succeeded in making the trucking industry more dangerous by changing HOS AGAIN. Now your rules affect team drivers. You have not taken in MANY problems that could develop with this. We realize that none of you have over the road knowledge about trucking. Whatever looks good on PAPER is what you'll go with. Even if you say that you have talked to truckers about HOS, you would not have come up with this latest plan.

The 34 hour restart is nice. It does however allow company drivers to have less time at home and more time behind the wheel. Usually when a driver needs a 34 restart,,,,,,they are NO WHERE near home. This allows for more fatigue to set in. There are SO MANY things that you folks have not taken into account.
Sincerely, Janice Schuette


Donald H. Harris - Comments 10/17/2005 PUBLIC SUBMISSIONS

To Whom it may concern;
This is in response to the recent changes in the hours of service rules to be effective on October first, 2005.

The change of teams not being able to split sleeper berth time had to have been implemented by people who had no clue as to what is going on out on the road.

By making it mandatory to take 8 consecutive hours in the sleeper berth you have also made it in reality that one driver has to drive consecutively for 8 hours. There are tens of thousands of trucks that are driven by teams and the teams have worked out the best system to drive safely and get the consistent miles that the trucking companies require. Team driving is required by companies that handle time sensitive freight and the only reason to have a truck driven by a team is so that it will be driven (for the majority of the time) around the clock.

It is my opinion that this change will be the most unsafe rule to ever be put into effect and will cause untold numbers of accidents for teams that try to drive compliant and satisfy the company that they drive for.

Let me give one realistic scenario ---
A team comes off of their days off and starts a new week at 0800 hours.
Driver “A” starts to log on duty driving.
Driver “B” logs sleeper berth time (even though he is not tired or sleepy)
Approximately 8 hours later the drivers switch positions.
1600 hours
Driver “B” starts to log on duty driving.
Driver “A” starts to log sleeper berth time (a little tired but not yet sleepy)
Driver “A” has gotten sleepy and fallen to sleep at 2200 hours.
Approximately 8 hours later the drivers switch positions.
0000 hours.
Driver “A” now has taken the wheel with less than 2 hours of sleep and by the new rule will be required to drive until 0800 hours.

This new rule does not take into consideration that every team is made up of different types of people with different skills and capacities.

Some drive better after dark, some do not feel as comfortable after dark, or fog or ice or snow or city traffic or mountains and so on and so on.

The point is that different people who drive as a team should be able to decide which system works best for them to be safe and meet the requirements of the companies that they drive for.

Rules written should be for the purpose of making the roads safer and I hope that was the intention with this new rule but it does not make them safer. It make the roads a much more dangerous place to be now. You will have trucks driven by tired and sleepy drivers that have no choice but to drive 8 consecutive hours or pull over and sleep. The truck can not now be driven by the other driver until his/her 8 consecutive hours in the sleeper berth.

I want to be respectful to your positions, but you need to get real and see the situation out on the road like it really is. I would be very interested if any teams were surveyed about their driving systems that they have worked out and what works best for them to be rested and safe and keep the consistent miles that their companies require.

The older rules worked the best with the ability to split sleeper berth and 8 hours in the sleeper was required. That gave drivers several choices to work what was best for them. Split 4 and 4, split 5 and 5, split 8 and 8 or split 10 and 10. The next rule was almost as good. Split 5 and 5 split 8 and 8 or split 10 and 10. There was several choices and a decision could be made to what works best and safest. This has been removed and now the DOT has put into effect a one plan system that all teams have to go by.

May the Lord watch over us until some people there decide to believe most drivers want to be compliant and safe and put rules that reflect that belief.

Thank you for taking the time to read my complaint and suggestions.

Don Harris


Brian C. Charles - Comments 10/17/2005 PUBLIC SUBMISSIONS

I just wanted to give some feedback on the new hours of service changes. It may seem that the changes are very small but if you really take the time run some different senerios it really brings out some problems. For instance if I start driving after my ten hour break and for what ever reason get fatiged and want to lay down after say five hours of driving I'll stop and sleep for two hours or so under the old rules it would stop the fourteen hour clock but now it just cuts into my driving time I have no choice but to keep driving so I can get my full eleven hours in. I don't see how you see this as a safe situation I know its not safe but drivers like me who run regional northeast and midwest (1000 mile radius) are forced to keep going under these new rules or stop for eight whole hours to stop the clock. The least and best thing you could do is make the other two hours stop the clock this would allow drivers to take a break and still drive eleven hours. I enjoy driving truck but some of these rules are really making it a hassle,I would like to here your veiws on this as well if you can respond that would be great!
Thanks for taking the time to read my opinion and I'll look forward to hearing from you.

Brian Charles


Wendy A. Perkins - Comments 10/17/2005 PUBLIC SUBMISSIONS

If the FMCA was so concerned about Hwy safty, All the thousands of Mexican Trucks and drivers would not be allowed on our hwys. until they could speak and read English, And,until they have valid liciencing and legal trucks. Your more concerned ,that we work 14 hrs a day with no breaks than the the real safty issues of the hwys. Why is it, that all of you making laws for this industry,yet none of you have and ounce of experience in the trucking industry. If some part of this industry pays you all enough money, you will make a ruling on anything they want. What qualifications do any of you have ,to make laws on something you know nothing about.

I cant get a job unless Im qualified, cant drive a truck unless Im qualified. Then why can you??????? Several times now I have tried to communicate to several trucks to let them know either there was something falling off there truck, or they were putting other trucks in danger by the way they they were driving, and to no avail,,,,, they didnt speak English

I have not much faith in your system of rule making, your not concerned about the safty on the roads, you, and the states are concerned about revenue, how much will this ruling generate in revenue.

Why dont you try your own rulings. Work 14 hrs. they go into your bedroom and sleep for 10 hrs.. Do this for a month, wheather its day or nite.

All of you should have to be in a truck and on the road for 6 wks, then maybe you will get the jest of your rule's. None of you have a clue about whats going on in the real world.


Christopher J. Piette - Comments 10/18/2005 PUBLIC SUBMISSIONS

The recent changes in the hours of service for long-haul commercial motor vehicles, while put together with the best of intentions, do just the opposite of their intended goals. In fact, these new rules will routinely place drivers in situations where they must choose between running legally and safely. They have removed the flexibility that allowed drivers to run safely, and in fact promote driver fatigue, falsification of logs, and are basically impractical for any real world situations.

While the new rules are obviously designed to promote safety and health among drivers, they actually do just the opposite. The safety of all drivers on the road not only comes in the form of long-haul drivers getting enough rest in one stretch of time, but also from the flexibility of being able to find a safe location to get more rest if needed. Under the current rules, if a driver is going to a particular location on a feasible deadline, he or she can find a suitable location and get some rest if needed and still meet their deadline. The current split log regulations allow for the judgment of the driver to know if they should get some rest, not the various studies that say when they are due for rest. In addition, when drivers to have the opportunity to rest for anything less than eight hours, it penalizes them against their fourteen-hour clock.

For example: A driver has to make a five-hour run. He or she has five and a half hours of driving time and six hours within their fourteen-hour clock. This obviously can be done legally. If that driver gets tired somewhere within this run, they can stop and rest for several hours and still reach their destination within a reasonable period of time. However, under the new provision, this driver cannot sleep for more than one hour and still be able to complete the run without running into the end of his or her fourteen-hours. Therefore, this driver must choose to miss the deadline, or drive while tired, and when his or her judgment says that the driver should get some rest. Even if this load has a very reasonable deadline, the chances of making it are now slim. It simply cannot be done legally.

And for that reason, these types of situations promote falsification of logs in order to be safe on the road and still meet deadlines. This puts companies like Gully Transportation at a disadvantage to those companies who routinely run illegally. It is our company policy to run legally and safely, and situations such as this make it impossible to follow company policy and make these sorts of runs. Therefore, this new set of rules puts companies that obey the law at a distinct disadvantage to companies that do not when freight deadlines are difficult to meet. If everyone was on a level playing field, shippers and carriers could work together to set realistic deadlines. However with these rules, companies who run legally simply do not get the freight, and companies with questionable practices do.

What the new hours of service rules amount to is a breakdown in practical application to real world situations. They do not allow drivers to utilize rest when they have the opportunity to rest, and penalizes them if their judgment says they need to get some rest. In addition, they promote unsafe driving situations such as fatigue in order to avoid being penalized against their fourteen-hour clocks. For drivers, time is money, and a missed deadline may result in missing their next run or if repeated, loss of their job. The new hours of service rules pose an unfair question to drivers to run legally or safely. And it is unfair to put carriers who obey the law at a disadvantage in obtaining freight to those who pay not attention to the law. Therefore these new rules clearly defeat themselves in all practical application and promote disregard for the law among carriers and drivers.


Barbara M. Whitfield - Comments 10/19/2005 PUBLIC SUBMISSIONS

The new rules of service will not work for team drivers. Not only is it not feasable to drive in accordance to the new rules, it is dangerous to the driver and all those around him. We have always driven five hours and then slept five hours. We are rested and alert when driving. Driving eight hours will cause fatigue and the driver will not be as alert as he sould be. I am unsure how to log the new hours of service, prehaps you can give me some guidelines. The information given to the driver is hard to understand and very brief in nature. We try to comply by all the rules but I am having a difficult time complying with these new rules. In my opinion, they were written with little knowledge of trucking on a first-hand basis.
Thank you.


Manuel A. Romero - Comments 10/20/2005 PUBLIC SUBMISSIONS

it is true most coments i have been reading to be stopped for 10 hours will cause that drivers stay in the truck sleep 4-6 hours wake up by the noise of another truck arriving to the rest area with a refer on or some kids with the radio all the way up or a thunder. stay in the truck or outside walking or watching tv then drive again without chance to stop to get more sleep when feels like he need it in a period of 24 hours. it is almost imposible to sleep 8 or 10 hours probably if all people on the freways were force to stop at the same time, but even in the confort of most peoples house, acording to recent studies most people only sleep an average of 6 to 7 hours a day, drivers with all the outside noise wil not sleep more than 5 hours continusly and that will give an average of 30 to 40 hours of sleep per week thats risky. thanks


2372
Frank Smith - Comments 10/21/2005 PUBLIC SUBMISSIONS

HOS TIME FOR DRVRS TO DRIVE AND WORK ARE COMPLEICATED WITH OUT SPLIT SLEEPER SOMETIMES WE HAVE TO WAIT TO DEL.OR P/U LD AND IT MAY BE 6-7HRS BEFORE WE GET TO START ROLLIING THIS AFFECTS TIME OF DRIVING TO MEET APPMNT TIMES AND THESE TIMES OR PERIODS OF WAITING ARE SPENT IN THE SLEEPER WHERE WE GET RESTED BEFORE GETTING OUT ON THE OPEN ROAD. ALSO AS A TEAM SOMETIMES WE ENCOUNTER SITUATIONS BAD WEATHER ECT. THAT CAUSE US TO GET TIRED.THIS IS A DANGEROUS TIME AND IT IS NEEDED TO STOP AND GET A COUPLE HOURS OF REST SO AS TO BE ALERT BUT WITH THE NEWS HOURS ALL THE TIME EXCEPT 8 HRS AND 10 HRS COUNTS AGAINST THE 14 HR CLOCK. FRANK SMITH TRK DRVR


Robert D. Coles - Comments 10/24/2005 PUBLIC SUBMISSIONS

I would like to know if you asked any truck drivers, ie flat bed, reefer, teamster, coal, dry van, etc., for their input as to the new FMCSA rules before you implemented the changes to the rules of operation. It seems to me that you have hired a bunch of electricians to fix the plumbing problem.

The problem does not exist with the way the rules were, the problem exists in other areas. If IF you want to know how to fix the problem of driver fatigue, ask an experienced driver. I may, and I think I can be of great help to solving the problems of driver fatigue, illegal over run on hours and maybe, maybe, on some other problems that have not been addressed as of this date, as far I know.
With the utmost of respect
Robert (Bob) D. Coles




Rick - Comments 10/26/2005 PUBLIC SUBMISSIONS

Thanks to the new HOS regulations, you've succeeded in making me an unsafe truck driver and a unhealthy one at the same time. Nice work!

I often need every minute of the 11/14 hours to legally log my trip. Because the two hour break will no longer "stop the (14 hr) clock", I must either eat and drive at the same time (unsafe), or wait until I've completed my trip to eat, and then go right to bed on a full stomach. (unhealthy).

For the most part, I approve of the new reg's, but due to the nature of my trips, I often get stuck waiting to get loaded/unloaded, or spend several hours idle between deliveries. I use the time to get some rest. But with the new (Oct 2005) law, it doesn't count and I run out of hours even though I'm still wide awake and unable to lay down for an additional 10 hours.

Why don't you get rid of the lawyers, politicians and special interest groups that know nothing of the practical side of the industry, and start listening to some actual truck drivers and HELP some real truck drives?


cc: patt@patt.org


Ronald Moore - Comments 10/27/2005 PUBLIC SUBMISSIONS


To Whom it may Concern;

Currently in Dallas Tx. having driven here from Birmingham. On my way here I was almost ran into by driver who per my conversation with him was trying to drive 11 hrs. straight through, something he's not really accustomed to since HOS changes. He had dosed off, ran off into median and back on road toward me, luckily he recovered and apologized and I told him to pull it over and he did.

Your new Hours of service are causing many drivers to push it too much whereby they're trying to drive 11 straight hrs since they can no longer split sleeper berth in to 5&5/or however they used to and first break has to be 8 hours. I know already per a girlfriend that accidents are already up since Oct. 1 and I see driver's pushing it because they no longer have that flexibility with off duty/sleeper berth hours. Many drivers, such as myself have been functioning on old split log system as we are used to sleeping for 4-5 hrs. driving 5-5.5 hrs. sleep for 4-5 hrs and continue. This is a formal complaint that you are putting everyone's lives on the highways at risk as it will cause drivers such as the one who almost hit me to push it too far and kill someone. I've told my sister and girlfriend and attorney by email that if I get injured or killed as a result of your really stupid changes that your dept. should be held responsible. I've had 1 near miss already with a sleepy driver pushin it to get his 11. Driver's are figuring that if they have to take 8 their 1st break they'd might as well do the 10 off and not have to worrying about refiguring the 14 hour limit. Stupid move folks and the blood on the highways will be the proof, I'm sure, over the Holiday season coming up. Already reports of an increase of 25% in accidents since Oct.1st. Better fix it before it gets really bad. Thanks.

Sincerey,
Ronald Moore


Edward J. Bushman - Comments 10/27/2005 PUBLIC SUBMISSIONS

Argument Against the New Hours of Service

To properly understand the health issues and attempt to legislate sleep, one must understand how or what makes a driver tick. Like the rest of the business world, drivers go to work each day for the paycheck. Over the Road drivers are paid by the mile; thus they desire to drive as many miles a day to maximize daily pay. If a driver has 11 hours to drive each day he will do everything possible to drive those 11 hours. Most loads have strict delivery appointments or deadlines to meet; thus, a driver has to maximize his/her driving time.

While the intentions of the FMCSA are good, their new Hours of Service rules are not. While the new rules were intended to insure that there are fewer fatigued or sleep deprived drivers on the road, they will dramatically increase driver fatigue. This will lead to more fatigue related accidents and deaths. The following are a couple of the reasons this will happen.

•Drivers are being forced to continue driving while sick or tired.
While the 8 hours of sleep is a great recommendation, the rules assume that no one ever gets sick and that everyone’s bodies work exactly the same. They dictate that there are no other variables involved in the sleep/fatigue issue. They stipulate that you can only split your sleeper berth in 2 segments, one segment for 2 hours and one for 8 hours or more, while the 14 hr clock continues to run during the 2 hr allotment. If a driver were to go more than 2 hrs, he is cutting into his driving time, thus reducing his pay. This does not allow the drivers any flexibility to listen to their bodies needs and act accordingly. If a driver is sick or not feeling well he no longer has the option to lie down and rest for while or until he feels better. Instead he will continue to drive even when sick or tired so that he may make the miles or get to the destination on time.

•Team operations are being forced to drive for 8 hours straight.
The majority of team operations operate on a 5 hour driving and a 5 hour sleeper berth rotation. This works well so that a driver may have peak alertness while driving maximum miles. With the new rules, a driver will have to drive at least 8 hrs straight with out a break while the other driver accumulates his required 8 hrs in the sleeper. Do you expect your office personnel to sit at their desks for 8 hours straight without a reasonable break? Could you do it and still be effective? I don’t think so, and neither can the drivers. Can you sit or sleep on your bed for 8 straight hours and do so, on command? With the flexibility of the old Hours of Service rules, drivers were able to listen to their bodies and follow a schedule or routine that is dictated by their individual needs. Thus they were able to facilitate maximum rest and health.

The new Hours of Service rules increase the potential for driver fatigue and thus increase the risk of accident, injury or death both the driver and the general population. By removing the ability to adjust their schedule according to real issues such as sickness etc, you have eliminated the ability for drivers to get the rest necessary to drive alert and safely.

On these premises, I implore you to reverse the recent changes to the hours of service relating to sleeper berth time. Allow drivers to break up sleeper berth time to segments that are greater than 2 hours which total to at least 10 hours in a 24 hr period. Allow sleeper/berth time to stop the 14 hour clock. By doing so, you will find drivers more willing to get the sleep thy need while allowing them to earn a fair living. This will; in turn, reduce driver fatigue and assist in maintaining safer roads.


Joe Gomes - Comments 10/27/2005 PUBLIC SUBMISSIONS


The Sleeper Berth Provision of the HOS Regulations that became effective 10/1/05 is unsafe. Our sleeper drivers have to a man complained about fatigue using the new rule. Staying in the sleeper berth and resting for eight hours is almost impossible. The environement is not the smae as being in a bed in your home. Please review the provision of the regulations and make the road safer for all people who use them.


Anonymous - Comments 10/28/2005 PUBLIC SUBMISSIONS

Help!!! This 14 hour clock is killing us. I get dispatched at 2pm, get out gate 3pm, drive 2hrs, get out gate 6pm, drive 1 hr, get out gate 8pm, drive 7.75 hrs to last stop. No time to stop for restroom, coffee,strech legs, power nap, dont have time to slow up for road work etc. By 2am my eyes are glassy my legs cramping, ineed to stop, walk,get coffee or take a power nap. I have freight for 25 customers who depend on me to get load to dock in time to be delivered that day. this is one of many examples. Give me a break and let me deliver my load safely without breaking the law to be safe


Yellow Freight - Comments 10/31/2005 PUBLIC SUBMISSIONS

In response to your invitation to give you feedback concerning the new 10 hours of service, I would like to say that I am against it.

In my 25 years of experience it is more likely that while driving a straight 10 hours I would find it very tiring. Therefore the chances of having an accedent would increase. Also as I am human and can get a cold or alergy attach while on the road, it would be difficult to do my 10 at one stretch.

If you let the sleeper drivers like myself continue to split the 10 hours it would be a whole lot safer and healthier.

I work for Yellow Freight out of Kansas City and 70 to 80% of the other drivers feel the same as I do!!

Thank you for this opportunity to comment on this regulation.


Steve B. Nowak - Comments 10/31/2005 PUBLIC SUBMISSIONS
Another change contained in the new rule requires truckers who use sleeper-berths to rest for eight hours in a row, and take another two consecutive hours off duty before resetting their daily driving schedule. Studies show that drivers are less likely to be fatigued if they take a single eight hour block of rest than if they break their rest into smaller periods of time as they were allowed under the previous rule.
-------------------------------------------------------------------------------------------------------------------------------
I am a semi driver for United Parcel Service and would like to voice my strong opposition to the new sleeper team h.o.s. ruling. I only fill in occasionally on sleeper team runs for vacation coverage but having talked to the approximate 15 sleeper teams based in Wisconsin, they are all totally against this new ruling. have they done any study to show how safe a driver is driving for 10 sraight hours with out stopping because that is how our teams run,{that's the purpose of running team}it is a struggle. it is about impossible to sleep 8 or 9 hours in a truck moving down the road. with the old rules where you could break it up, drive 5, then sleep 5, you always got more then enough sleep in a 24 hour period. I will give you just one scenario, you are home for the weekend, on the normal routine with your family, get up at 7:00 a.m. Monday, see the kids off to school, kiss the wife goodbye as she goes off to work, but now here's the problem. my sleeper team run is not scheduled to start till 4:00 p.m. and it is my turn to drive the first leg of the trip. sure, I can try to rest before I start work but I am not tired, only been up since 7:00 a.m.. so now I start work at 4:00 p.m. and I have to drive till 2:00a.m., this is CRAZY. start work at four and only having to drive till nine is pretty much a piece of cake. most drivers I talked to can' t sleep much more then 4 or 5 hours in the sleeper, then just sit there and twiddle there thumbs waiting for the 10 hours to be up and then drive again, and yes, your awake for 15 to 16 hours by the time you are done driving your 10 hour leg. does this sound like safety??

I would really like to see a survey done to the approx. 500 U.P.S. sleeper teams [ I am not sure of the total but it is alot] and see how they feel about this new h.o.s. ruling. I am pretty sure the response would not be to favorable. has there been a study on number of sleeper teams involved in crashes where they think these new rulings are going make highways safer?
thank you from a U.P.S. driver
STEVE NOWAK


Gaylen E. Storkel - Comments 11/01/2005 PUBLIC SUBMISSIONS
November 1, 2005

Docket Clerk
Room PL-401
400 7th Street, SW
Washington, DC 20590-0001 To Whom It May Concern:
My wife and I drive as a team on a dedicated run between Seattle, WA and Dallas, TX and return, once a week. After one month of operating under the new hours of service regulations I have reached the opinion that the new sleeper birth provision is both unsafe and unhealthy to the driver behind the wheel, the driver confined to the sleeper and every other person on the highway.

The new hours of service rules regarding sleeper birth provisions have done nothing to enhance safety for truck drivers or others on the highway in my opinion it has had the opposite effect. We now are forced to drive for 10 to 11 hours at a stretch. The first 5 hours you are fairly fresh but the last 5 to 6 hours you are tired and fidgety and certainly not as alert as you were the first 5. For years we have been able to drive for 5 hours and rest for 5 hours. After 5 hours in the sleeper I can get up and drive another 5 hours feeling refreshed. When I am forced to spend10 hours in the sleeper I am able to sleep for about 4 or 5 hours and then read or watch TV for the remainder of my confinement to the sleeper birth. When I start driving again I do not feel refreshed and ready to drive for 10 hours.

As for the studies that were conducted to support new hours of service I would urge new studies be done under actual truck driving conditions. Make the subjects attempt to get 8 hours of quality sleep in a sleeper with the truck moving down the highway, going through cities, stopping for traffic lights and traffic, etc.

I would strongly urge you to reconsider the sleeper birth provision and revise it to include a reasonable and safe split birth provision as previously allowed. I further support OOIDA’s petition to revise both the split sleeper birth and that any break greater than 2 hours should not count against the 14 hour rule.
Thank you for your consideration.
Gaylen E. Storkel


Claud V. & Lyla L. DeVerger - Comments 11/02/2005 PUBLIC SUBMISSIONS
General Comment:
I would like to comment about the new hours of service for truckers. I cannot believe that whoever makes these laws has a clue as to what goes on in the lives of a truck driver. My wife & I are a team & we find that these new hours of service are not healthy, antiproductive, and very unsafe to the truck driver as well as the general public. I suggest to the people that make these new laws, that they take off their tie, white shirt, and their suit coat and put on some work clothes & come out here with the truck drivers for at least a month. While you are out here with us, I want you to get up with us & go to the sleeper at the same time that we go to the sleeper.

In reality, we want to see how much sleep you really get bouncing around going down the road. We're not talking about how much time you log in the sleeper, we're talking about real actual sleep. We know for a fact, since I've been doing this for 40 years, that your quality of sleep is not good, therefore you are not going to get 8 straight hours of sleep, by no means. We were driving 5 hours on & 5 hours off & actually got more quality sleep than we do with the new law. We feel that the new law is definitely not good! At the very least, we should have the option of working 5 on & 5 off. There are endless scenarios that we could talk about in the trucking industry hours of service, but we feel that the 5 on & 5 off is the best case scenario, or at least to have it as an option. Again, this is better for our health, better for productivity & better for safety as a team. Going to the sleeper with the truck stopped is the best quality sleep that you can get in a truck - hands down - compared to trying to sleep while going down the road for days on end. As it stands right now, we find ourselves going out of service so we can stop & get quality sleep & rest & with that said, there goes our productivity. Because of the new hours of service, we now have a "For Sale" sign on our truck because we feel that we cannot safely operate or meet our obligations with the new hours of service laws. We talk to teams every day that agree with us totally. We would like to receive comments back from you.
Sincerely,
Claud V. DeVerger and Lyla L. DeVerger (Husband & Wife Team)


Thomas D. Dean - Comments 11/07/2005 PUBLIC SUBMISSIONS
General Comment:
i dont see how anyone can make a rule on the trucking industry when they dont operate a truck. that goes for the hours of service double . whey do they think we are robots?


General Comment:
Timothy P. DeRycke - Comments 11/08/2005 PUBLIC SUBMISSIONS
I would like to comment on the new HOS as it relates to "TEAMS".
I have been a Team driver for a few years now and can't for the life of me understand how these new rules can possibly improve the health and certainly not the safety of the driver or the motoring public.. We used to drive 5 on 5 off as a vast majority of teams did. I understand the argument that for health reasons a driver should receive 7 to 8 consistant hours of sleep but I fear that you "RULE MAKERS" have no first hand experiance sleeping in a truck as it's going down the highways in this country. Most people could not sleep 7 or 8 hours while the truck is moving. The rough roads, the vibration of the truck, the noise level of the truck and the other vehicles around you, the braking and accelerating over and over again, every time the driver behind the wheel needs to stop to use a rest area you can't help to wake up. And how about the rest area use? There isn't a "HEALTHY" driver on the road that can spend 7 to 8 hours trying to sleep in the sleeper with out having to use a rest room ATLEAST once. It's not like sleeping in your bed at home or even like sleeping in the truck when it's not moving like a solo driver. Try falling back to sleep after you've gotten out of the sleeper, dressed and walked outdoors in the cold weather all the way to a restroom and back, undressed and try to sleep again... Did any of them health professionals try doing this for a week? Driving as a "TEAM" is nothing like running as a solo driver and for that reason we must have our own HOS rules. Rules that make sense and take into consideration what the sleeping driver goes through while the truck travels down the highway at 60-70 mph.

Under the old rules when a driver would spend 5 hours in the sleeper and 5 hours in the drivers seat, in my opinion you have a happy and rested driver that is not a danger to the motoring public. I have tried a couple differant variations of splitting the sleeper berth time with my co-driver under the new rules and we have found that neither of us can sleep for more than 6 hours with out needing the use of restroom facilities. And then we usually can't fall back to sleep o nce we get back in the truck. I think this also explains the growing number of urine bottles along side the road. Drivers trying to sleep are not leaving the truck, they are using these bottles.. Have any of the rule makers ever tried to sleep in a truck as it rolls down the road for 8 hours??? How about these people that are so concerned about drivres health???

Teams are not the same as solo drivers and we need our own rules, ones that make sense. I am without a doubt not as safe on the road today as I was before the HOS changed and I am certain that if you cared to find out that most other Team drivers would agree with me... Watch and see how many more accidents are reported with team drivers in the coming months, ecspecially at night, that is if they even track accidents solo versus Team.

We as many Teams have decided to, run 10 on 10 off because it makes the most amount of sense. 8 then 2 later is wasteful and idiotic. So Now IF I'm fortunate enough to get 6 good hours of good roads and quiet traffic conditions and we don't have to deliver or pick up at a Shipper before I have to use the rest room then that would only mean I'd be up 14 or so hours, 10 of which I'd be driving. Unfortunately I drive the night shift. I ask your health professionals to drive 10 hours after sleeping for 6 in a truck while it's moving, picking up freight, delivering freight, going through road construction, up and down mountains, crossing the border into Canada...
Get a clue people... Don't make rules you yourselves couldn't handle.
Abandon the new HOS rules or atleast as they pertain to TEAMS!

The other option which is mine is to refuse to run team anymore. If enough of the teams in this country gave up on Teaming like myself we would have a serious problem moving important cargo such as Produce from the west to the east coast in a timely manner. It's very hard to find teams as any company will tell you and the new HOS are going to make it impossible to get people to do it...
Do the right thing realize your mistake and fix it SOON!

This is an edit and an addition to the above post. Solo drivers face difficulties in equal proportion to team drivers with the present HOS rule. Our difficulties are distinct, as are those of the team drivers. We need to be able to split our bunk as badly as do the team drivers. We ALL need the return of the split sleeper berth provision.


Anonymous - Comments 11/09/2005 PUBLIC SUBMISSIONS
I would like to thank the powers that be for the new HOS. For the first time in six years, I now find myself and my codriver behind the wheel after thirty hours with out any sleep and no choice but keep running! With the old HOS. we were {never} more than five hours from getting sleep. The reason we split the sleeper bearth was for health ie. pore blood flow in the leggs,blood clots. sleep, teams don't run on a nine to five schedule. Trying to sleep when the truck is bumping the dock, on rough roads stopping for fuel is not conductive for sleeping. My wife and I did,nt decide to split the sleeper bearth lightly! we tried many ways before deciding to split the sleeper bearth that is what works for us for many others it different but the point I am trying to make is every time we can't sleep when it's are sleep time we find we are behind the wheel and still driving after thirty hours

This an edit and addition to the above post. Solo drivers also find themselves forced to drive sleepy for seemingly unending stretches because of the inflexibility of the present HOS rule.


Dawn - Comments 11/09/2005 PUBLIC SUBMISSIONS
The new hours of service rules promote driver fatigue, not safety. By not allowing split sleeper time without it counting towards on duty time, a driver must continue to drive tired, when we used to be able to pull over aqnd take a nap for 4 hrs. Now, knowing that the 4hrs counts towards our on duty time, and cuts into available driving hours, we are forced to drive on. There was nothing wrong with the old rules, and actually 11 hours driving is TOO MUCH! 10 driving is plenty. 10 off is fine, if we could split it into 5/5, 6/4. Please reconsider these new rules as they are UNSAFE. Thank you.
From a tired trucker....forced to drive on.

This is an edit and an addition to the above comment: Split time should mean that blocks as small as 2 hours may be used to stop a clock. Blocks of time as small as 2 hours should count toward a full break when added to another block of time totalling 8, or 10, however that shall be decided. If blocks of time, two hours or greater, are not included as valid bunk time, the net result to the driver is the loss of that time in productivity. Inasmuch as 2 hour blocks of timely sleep breaks are invaluable, safety-wise, the loss of any productivity related to those sleep breaks is unacceptable. Such a loss of productivity, a penalty implicit to the present rule, is the nagging reality which causes drivers to forgo needed sleep breaks.


David L. Rake - Comments 11/09/2005 PUBLIC SUBMISSIONS
I strongly oppose the revised hours of service regs effective 1 oct, 2005. Removing 2 hour split sleeper provision that is not counted against 14 hr rule, forces a driver to remain driving for an unreasonable continous length of time without break for meals, showers, personal business, a nap or stop for completion of setting/rising sun for visual safety reasons. This only causes fatigue and promotes a driver to remain seated for extended lengths of time which is dangerous for cardiac/circulatory health reasons. Please allow the 2 hour sleeper berth/off duty provision to extend the 14 hour rule. Previous HOS regs were tolerable, even reasonable, but it has now become an unpleasant endurance contest each day. Taken most of the pleasure out of my job these days.


Nancy J. Ritchie - Comments 11/09/2005 PUBLIC SUBMISSIONS
I strongly disagree with the new Hours of Service Regulations for commercial truck drivers. There is no flexibility. For most drivers I know, the driving time is too long, expecially in the winter when driving conditions are significantly more dangerous. As far as the extended rest periods go, after driving 8-10 hours we are exhausted and although we sleep well, being awake for two hours or more before resuming driving only makes the end of our shifts farther away. It also means that team drivers often drive 8-10 hour shifts during the hours that your study says are most dangerous. It also means that drivers will be driving under hazardous road conditions for longer periods which will increase our levels of fatigue. We cannot always just pull over and take a nap. For one thing there are fewer places to park (since many parking areas are closed off)and it is often more unsafe to take an exit that is not properly treated. If we can park when we are too tired to drive, neither driver can drive until the 10 hour off duty time has been satisfied.
I also think your study involving 80 drivers was a bit ridiculous. Why not do a study involving a percentage of drivers from many companies. The way we drive is largly influenced by the way the companies we drive for operate and whether or not it is a team or solo operation. I also want to know if in 2002 truck related accidents were at the lowest level since 1975, why were the regulations changed and why they were changed again? Has anyone ever heard the expression "If it ain't broke, don't fix it?" Do you think by changing our driving and sleep times from flexible to 5 hours sleeping and 5 hours driving and then to 10 hours driving and 10 hours sleeping that we are safer? Has anyone done a study on how all this changing around affects our safety? I still do not agree that 34 hours off duty is sufficient. When drivers finally do get home, we have very little time to rest. If we live alone, there is much to be done at home and if we have families we need quality time with them. However, as long as trucking companies have so few regulations as to how drivers as employees are treated, we drivers have to work far more hours and be away from home far longer than we should. When I tried to find out about employment laws and regulations about truck drivers in my home state, I was told that there were none. We can work up to 60-70 hours a week - no overtime. We can lose full time status for driving one mile short of the monthly requirements and therefor lose insurance, vacation and take a pay cut. We don't get sick pay and if we become ill while on the road, we have to drive anyway to get home. If we are injured while on the road, the company can claim that it happened while off duty and not pay for medical bills and make us work under light duty status to recive workmen's comp.
If the Department of transportations wants to make drivers safer, they must give us FLEXIBLE driving/sleep time and make laws that will protect drivers in a way that is at least comprable to every other employee in the country.
Nancy Ritchie


Kim Yow Satterwhite - Comments 11/14/2005 PUBLIC SUBMISSIONS
PLEASE,PLEASE LISTEN.....TO THE TRUCKERS...There was nothing wrong with the hours before. Dont do this. You are making even more dangerous on road now more than ever. 5 on and 5 off was perfect. Now I have to push myself to try to get 10 and it has been really hard. I team with my husband. We did great on the 5/5, now he has fallen asleep at the wheel. Ive push so hard that Im all over the road. YOU HAVE MADE A BIG MISTAKE. I THINK THAT WHEN A TRUCKER DOES FALL ASLEEP AT THE WHEEL BECAUSE OF THESE NEW RULES THAT ITS THE MAIN ONE WHO CAUSED THIS, ON THE OTHER SIDE OF THE ROAD WITH A BIG TRUCK HEADING TOWARDS THEM, BECAUSE THEY HAD TO PUSH THEMSELVES SO HARD TO DO THE NEW RULE JUST SO THEY CAN MAKE A LIVING. UNFORTUNATELY SOMEONE IS GOING TO GET HURT OR KILLED. I REALLY JUST DONT UNDERSTAND WHY YOU KEEP CHANING THINGS THAT ARE GOING SO WELL. VERY FRUSTATED WITH THE GOVERMENT. I BEG YOU PLEASE CHANGE THE RULES BACK........

This is an edit and addition to the above post: Five/five is great for teams. It’s the way they have done it for so many years. If the full flexibility of split bunk time is returned as it stood before October, 2005, then teams could continue to do 5/5 or similar. For solos, a mandated 5/5 is only marginally safer than 8/2. Here’s why: Many times, a driver has plenty of log book time available to complete the run and get rest. However, sleepiness shows up and a break is called for. The type of sleepiness we’re talking about here needs only an hour or two of sleep. If a driver knows that the clock only stops when five hours in the bunk has been logged, the driver will forgo that very necessary 2 hour break, for economic reasons that are very real. This is why we need the return of the original split sleeper berth provision.


\ Donald D. Diamond - Comments 11/14/2005 PUBLIC SUBMISSIONS
Concerning the eight hour sleeper rule in the latest revisions. This is causing me to drive when I should be resting as I don,t have time to stop for a full eight hours and still fulfill my obligations to my customers while if i could stop for one or two hours to eat or take a nap I would be more rested and able to fulfill my responsabilaties. I have been driving OTR for 10 Yrs and feel I am a better judge of when I should make use of the old two hour break rule than those outside of our industry
Thank you Donald D Diamond


Anonymous - Comments 11/15/2005 PUBLIC SUBMISSIONS
The new more restrictive rules that we received in August of 2005 are unrealistic and will not work. The 14 hour rule is unfair makes me skip breaks and meals and feel under pressure all day. I know when I need to rest by how I feel and not being able to split the sleeper birth time to fit my needs rather than a bureaucrat's idea of what is ideal is ridiculous. I doubt that anyone in the FMCSA care what drivers think as the rules that you are making seem to include input from everyone but drivers, I therefore intend to sell my truck and quit driving long haul. FMCSA has got us to the point that we can not even back into a dock during an 8 hour break without worries of a law suite if one is latter involved in an accident. I wish someone could tell me why we are implementing these over the top rules when only 5% of the current accidents are related to fatigue? I would also guess that of that 5% most of them were violating the old rules anyway, so why are we making life so difficult for the people who try to comply?


Jerry B. McBain - Comments 11/15/2005 PUBLIC SUBMISSIONS
I am a driver/owner operator, and wish to express the need for revision of the current proposal for hours of service. The split/sleeper berth time should NOT be revised from the 2003 methods adopted 1-1-2004. Team drivers cannot safely operate on 8 hour shifts safely. Thanks for your consideration.


Darlene L. Wisdom - Comments 11/21/2005 PUBLIC SUBMISSIONS
Regarding the new HOS split sleeper berth provisions. We are a husband/wife team operation and have been teaming for 5 1/2 years. We have always driven a 5 on 5 off schedule. Since the new HOS took effect on Oct 1, 2005 we have been forced to run a 10 hr schedule. We have tried splitting to a 2/8 but ist is impractical. A majority of our loads are "just-in-time" or time critical loads which do not allow for us to shut down excessivley. If we split unde the new hours the truck has to shut down as the other driver is required to be in the sleeper for 8 hrs minimum and can't be driving during the other drivers 2 hr break or they mess up their 8 hr break. Under the new rules, we are more tired running a 10/10 shift. Also, we find that our bodies are more stressed by sitting behind the wheel for longer periods of time. Our back muscles are cramping more, our leg muscles are always tired and we are not resting well with the 10 hours in the sleeper berth. When running a 5 on 5 off schedule we felt more rested and our bodfies didn't feel so tired and stressed. With the winter months coming up we will be forced to run in snow and ice for periods of 8 to 10 hrs straight. Under the old rule we could drive for 5 hrs and then take our break for 5 hours. This would allow our eyes, mind and bodies a break from the stress of driving on ice and snow, not so with the new rules. It doesn't appear that the sleep studies used to support the new sleeper berth provisions are relevant to the trucking industry. While they might be okay to show sleep patterns in a controlled environment, in real life they just don't equate to the trucking industry.The trucking industry is NOT a 9 to 5 job and never will be. The FMCSA has just taken away one of the few ways we can be flexible with our rest and sleep patterns and still be safe. We now have a ridged set of rules for a job that has a constantly changing schedule. We feel we are less safe under the new rules. Also, we are seeing more and more trucks parked on the on/off ramps so they can get in their breaks or they are at the end of their 14 hr duty day. They are now parked on these ramps for 8 to 10 hrs instead of 2 to 5. This is a very unsafe practice. We request the FMCSA give serious consideration to OOIDA's challenge concerning the split sleeper berth provisions. These two changes would make the trucking industry a safer and healthier place to work.

This is an edit and addition to the above comment: The physiological difficulties described in the comment apply to solo drivers as well as team drivers. The present HOS rule in question here places solo drivers in the same predicament as a team driver, by being forced, economically, to remain in the driver’s seat for inordinate periods.


Anonymous - Comments 11/23/2005 PUBLIC SUBMISSIONS
These 'hours of service' just are not going to work for me. I've tried to comply and have, but the world in general was more endangered than it needed to be. It's insane for me to force myself to drive when I KNOW I'm too tired, but napping will make delivery illegal. The only way to force your body to sleep is through medication and MAYBE meditation. I've tried the meditation and it just won't work for me. And I am not referring to illegal drugs, but many over the counter medications and alcohol. I've had one alcoholic beverage in two and a half years, so that's not a solution for me. Not only is unnecessary drug use not good for you, an additional problem to using medication is that I'm sleeping in a truck that has $600 of fuel and who knows how many dollars of product in the back of the trailer. This can be big dollars and I do not want to be too sound asleep. Napping is really the ONLY practical solution. And then there is forcing our bodies to drive without proper sleep. I've been driving for two and a half years. I had never had to drink coffee until recently. Caffeine is a very common drug in 'corporate America,' but out 'on the road' I'd never needed it. If I was sleepy, I would nap. I'm two steps from my bed! A two hour siesta and I'm good to go. A four hour nap, even better. I spent a fair portion at the beginning of this new career 'team driving,' so I was used to split sleeping. I now use an alarm clock to wake-up and that was never necessary before. There are so many reasons that split sleeper time is a good idea. Fog, snow, ice, accidents, construction and 'rush hour' traffic causing road blockage to name just a few. I am sure you are aware of the work of Jim Horne, PhD, director of the sleep research laboratory and Loughborough University in England. I have searched and find no evidence that split sleep time effects me adversely. Experience tells me that it is best for the world in general for me to nap. After 5 hours sitting in the drivers seat I am ready to be prone. Why, when the solution is so easy are we making this so difficult? This is the third set of rules since I have been driving. When I first started, compliance took little or no effort. The second set of rules required some thinking and proper planning to insure the load arrived on time legally. But this third set has me trying to force my body to do what it is just refusing to do. Enough already. I need this fixed quick. Just another thought. I assume these whole rules changes are to save lives. If this is the case, why do people who drive around other people still use the old rules? I mean, I have valuable cargo, but their cargo is priceless.


Robert L. Hedgcock - Comments 11/25/2005 PUBLIC SUBMISSIONS
I find the new h.o.s do not help at all with the 14 hour clock. On my run I may spend two hours or more at each stop getting freight and I jump into the sleeper immediately while this happens.Now I have to hammer it between stops to make sure I can fit into 14 hours! I usually get to take 12 hours off between runs so lack of sleep is just not an issue with me.Why on earth do we all have to drive like crazed lunatics to fit the day in now? Please go back to the old 10 hours drive ,8 hours off rules and leave us alone ,unless you have a better thought out plan to offer.This one is just plain unsafe !.


Craig M. Bachman - Comments 11/25/2005 PUBLIC SUBMISSIONS
AS WE ALL KNOW THE PROBLEM WITH HOS IS THAT YOU PEOPLE FORGOT THE INDIVIDUALS HAVE DIFFERENT STAMINAS IN DRIVING AS WITH ALL JOBS,GAMES,AND ANY COMPETITIVE SPORT.YET YOU TRY TO GROUP US INTO 1.YOU NEED TO START WITH DRIVING SCHOOLS, SHIPPERS,RECEIVERS.ALL RECEIVERS,SHIPPERS,DOT,AND COMPANIES ALWAYS LOOK TO THE DRIVER FOR CHANGES SUCH AS FUEL GOES UP CUT BACK THE TRUCK,HOS CUT BACK THE HOURS,ALL THE WHILE SHIPPERS,RECEIVERS AND COMPANIES KEEP DISPATCHES THE SAME AND WE AS THE DRIVERS PAY THE PRICE. CLEAN UP YOUR BACKYARD BEFORE YOU GET IN MINE.YOU ALL THINK THAT WHEN WE DRIVERS GET FINES YOUR ARE DOING YOUR JOB, WHEN INFACT YOU ARE COLLECTING REVENUE AND THAT IS YOUR MAIN GOAL.LETS ALL GET REAL AS I CAN SEE THIS AS WELL AS YOU AND DEEP DOWN INSIDE YOU KNOW IM RIGHT, PLEASE STOP THIS AND MAKE SENSE INSTEAD OF MORE LAWS/RULES.MORE DETAILS TO FOLLOW


Anonymous - Comments 11/25/2005 PUBLIC SUBMISSIONS
i am very upset with the removal of the split sleeper for teams. my husband and i run dod security shipments. we cannot leave the truck unattended at anytime when it is loaded.we have to run longer we cant just stop and take a nap. try starting your shift at 10pm you have to drive till 8am that is the hardest time to have to drive. we have started the new rules oct. 1 and we are totally like vegetables when we get done driving 10 hrs. you have to break the rules to eat, load, unload arrive at bases. we are under your rules and dod rules to haul these shipments. we cannot stop for longer that 2 hrs. and we must be on base for anytime that we have till delivery. you both have to be awake to get on the base. we have to go thru security checks to get on base. your one size fits all approach to trucking is unrealistic. if we have to continue to drive 10 hr shifts we will be forced to give this line of work up. we have been driving for 11 yrs. and this is the worst rules ever. if i have a wreck because of being forced to drive long shifts i will be suing you. your rules are forcing us to drive unsafe and there is no way to log it legal. just because a log book says its time to drive does not mean you are able to. the split sleeper rules gave you the flexability to drive safe and not fatigued. my mind is always on safety when i get in the truck. a logbook cannot dictate safety. everytime i drive the truck i take a chance on losing everything i ever worked for. so dont think i dont care about safety. you have done nothing but make it impossible to do my job safely and legal.

This is an edit and an addition to the above comment: The arguments in the comment apply equally for solo drivers.



Anonymous - Comments 11/28/2005 PUBLIC SUBMISSIONS
Research needs to be done on Sleeper berth reg's . We currently operate on a rotating shift of 5.5 hours driving, 5.5 hours sleeping, and 3 hours to intergrate with odnd (on duty not driving) business. This process allows a team to almost double the effort of a single driver. I belive maintaining the previous rules not only allows drivers to be more productive, but also allows them to regulate their living functions (bathroom breaks, nourishment, etc.)

It is unrealistic to expect a driver to stay in a sleeper berth for more than 5.5 hours and maintain any level of comfort, taking into consideration rough roads, heavy stop and go traffic,and inexpensive mattresses. I would hope that the opinions of the drivers would weigh heavily in the implementation of these or any future rules.



David M. Cyr - Comments 11/28/2005 PUBLIC SUBMISSIONS
The new HOS regulations have several severe problems for me-If I want to pull over and take a nap I really can't because it doesn't stop the 14hr clock and If I want to pull over for bad traffic or weather I really can't without taking the hit on my 14 hours which is a hit on my pay. I need to make so much to support my family but want and need to do it safely and legally. It would be nice if safety was really promoted instead of the situation we have now.
Thankyou
David M. Cyr



Michael R. Hildebrand - Comments 11/28/2005 PUBLIC SUBMISSIONS
In regards to the lattest Hos change. Have any of you peaple that make these rules ever slept in a moving truck? It is apparent to me that none of you have or you would realize this new rule about the sleeper birt time for teams is doing more harm than good. I have been a team driver for about ten years and since the new sleeper birth change I have drove more hours tired than ever before Sleeping in a moving truck is not like sleeping in your bed at home. We get woke up many different ways and it is hard to go back to sleep if at all Recently I was running my usual run and I was in the sleeper when a car passed my team partner and cut him off and he was forced to lock up the brakes to avoid hitting this car and I was thrown out of bed. I had only been sleeping for 4 hours and after this happened I couldnt get back to sleep so when it was my turn to drive I was already up for 6 hours and then had to drive my ten hours plus make two stops for a total 4 hours of unloading and reloading time. I was a wake a total of 20 hours that day. I dont feel that at the end off my driving that I was opperating the truck very safe but i was running by the rules that you people that have never had to do this made and I feel that I was putting my saftey as well a others on the line . This a bad way to run. I thougth the FMSCA was about doing things to make it safer for the drivers and every one eles. I have talked to alot of drivers and we all feel the same . My company has lost some drivers because of the new hours and I think they are going to loose more. They have hired some new graduates from a truck driving school but alot of us refuse to team with them. I am not going to risk my life running ten hour shifts with a new driver that dosent have any idea off what he is doing or isnt use to sleeping in a moving truck . Running team is hard enough but you seem to think because of some study done by people thet have never had to sleep in a moving truck. I THINK YOU HAVE MADE A HUGE MISTAKE AND I HOPE NOBODY GETS KILLED BECAUSE OF IT BUT I AM AFRAID IT WILL HAPPEN. I hope you take my letter serious because there are peoples lives at stake and this no joke. Mike hildebrand.


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David G. Swanson - Comments 12/01/2005 PUBLIC SUBMISSIONS
I am commenting on the new HOS rules, the problem with them is we can't stop and take breaks as we see fit. Under the old rules many otr drivers would shut down during rush hour so they wouldn't have to deal with traffic. We would use this time to eat, sleep, or take showers. We can no longer do that. In case the FMCSA hasn't noticed truck accidents have increased since they originally changed the HOS rules and the accident rate had been steadily decreasing before the changes. We aren't perfect, accidents do happen, but most drivers are very safety consious.



Wiiliam G. Echols - Comments 12/08/2005 PUBLIC SUBMISSIONS
I have been driving long haul for the past 15 years, with 8 years as a solo driver and the last 7 years with my wife as a team. We have have found, as have a lot of other teams we have spoken to, that splitting the sleeper birth in 5 hour shifts best suited our comfort and safety needs. We feel that the new hours of service seem to be directed more towards the concerns for solo drivers because the new 10 hour sleeper birth-off duty requirement to reset the 14 hour rule does not take in the fact that it now requires that team drivers must now run 10 hour shifts with no exceptions or flexibility.

This is an edit and an addition to the above comment: Under the new sleeper berth requirement, solo drivers must also run 10 or 11 hour shifts with no exceptions or flexibility. The new hours of service do not reflect the concerns of solo drivers any more than they reflect the concerns of team drivers.



John Anderson - Comments 12/12/2005 PUBLIC SUBMISSIONS
FMCSA's efforts to improve highway safety are a must given the ever increasing volume of traffic. No one can justly be against improving safety. The major problem with the application of any scientific or statistical theories and the validity of the theories themselves is...that the unerlying ASSUMPTIONS be met.

The theory that drivers would be more alert if on a 24hr cycle assumes a consistent and continuous start and end to the cylce. In order to make the theory work, the 14hr rule is not allowed to be extended. Unfortunately, trying to force this assumption to be true is fruitless and Dangerous. Too many things such as delays, breakdowns, limited appointment times, shipper and receiver hours of operations, traffic jams, etc. that continual modify the 24 hour cycle from day to day.

The worst part of trying to force drivers onto the 24 hr cycle by not extending the 14 hr day by any breaks is that the driver's earnings (primary motivation) is put at great odds with safety. How? Out of 14 hrs, the driver can only drive 11 hrs. Thus only 14-11=3 hrs remain to be freely spent/wasted before it eats into the 11 hrs of driving time (revenue time, get home time, delivery appointment time, get next load in time time, etc). A shipper or receiver can easily use up this time.

Will a typical driver who lost his free time getting loaded stop to rest if it will cause them to be late? Will they stop for a needed nap if it will cause them to run out of hours only a 1-2 hrs from the house and be shut down for 10 hrs at that? Will they stop to get some nutrition at the expense of missing an appointment?

Drivers should have an economic insentive towards safety not away from it. The previous HOS rule that the break must be a minimum of 2 hours to be extended was pretty fair and logical. Yes, a little more complicated, but such is the price of flexibility. The benefit was an incentive towards safety! The Name of the Game.

A double standard exists with these rule makings too. Driving DUI is illeagal. Driving privilages are revoked on paper but not physically restricted. Can someone convicted of DUI still legally purchase intoxicants. Sure! Why then can't a driver who is not under the influence of fatigue not earn a living in the land of the free? When stopped at DOT stations or on the road, drivers do to have any fatigue test they can take. A field fatigue test is what is really needed to be fair.

Now we see that USPS is exempt from the new HOS rules and wants contracted drivers to be expempt also. Passenger carrying motor vehicles are not subject to the new HOS. Safety obviously is not the goal with the new HOS. Are these restrictions a government attempt to forcable Unionise the trucking industry?

As a team driver, I feel that the mandatory 8 hour period in a sleeper berth will adversely affect my proficiency as a driver. I am used to a shorter driving period, and being forced to drive the extra hours would cause ecessive exhaustion. Also, in my opinion, you are eliminating the need for team drivers by relagating us to the same hours as a single driver. An exception to this rule for team drivers would be much more beneficial in the long term, and enhance the safety performance of the team method of driving. As an example, the five hours of driving, the driver in the sleeper berth is actually there longer than the five hours, as that driver also occupies the berth during the on duty drivers rest stops, fueling and other non driving activities. Mandatory 10 hours in the berth would acutlly be longer for the same reasons as stated above. If the off duty driver were to occupy the passenger seat after 10 hours in the berth, that driver would be considered "on duty-not driving" and would be counted toward the 14 hour on duty time. Again, undermining the purpose of the team drivier.

This is an edit and an addition to the above comment: An exception to the rule for teams implies that the HOS rule in dispute here is somehow more tolerable for solo drivers. This is far from true.



Anonymous - Comments 12/23/2005 PUBLIC SUBMISSIONS
My husband and I have been a team contractor operation since the 1980's. We have always logged either 4 hours or 5 hours of driving with the same amount of sleeper berth time. This way has given us more than ample rest and our safety record is excellent. Now with the new hours of service, I understand to make the most of our hours, we will have to be on duty or drive for a continuous 10 hours. There is no way that this is safer than the old hours of service. I do not feel that I can safely drive 10 hours straight but it looks like this is what I am forced to do. Please reconsider the new HOS and make a safer program. Thank you for your time.



Anonymous - Comments 01/03/2006 PUBLIC SUBMISSIONS
I would like to comment on any sleeper berth proposal set forth by the FMCSA. As for safer driving it would be, from my experience as a driver, to allow the split sleeper. (5/5 minimum) Many drivers are pushing those eleven allowable hrs tired, resulting in less care on the road. The limitation of the 14 hr day adds to the resulting push. Very few Peopleare prone to ten hrs of vitual inactivity and are more tired whe they start the 14 hr day.



Shaun M. Chamers - Comments 01/03/2006 PUBLIC SUBMISSIONS
I think that the new split sleeper-birth provision is not safe and places unsafe presure on driver.The old provision allowed for some flexability and thus kept fatigued drivers from forcing themselves to drive when they should have taken a nap!!!!!



Shannon C. Glenn-Phy - Comments 01/09/2006 PUBLIC SUBMISSIONS
Re: HOS - RE: TEAMS,
I feel this is an injustice to all team drivers. I am a team driver and I feel I am more productive and driving the safest and best I can with rotating my driving with my co-driver every 5 to 6 hours. I've been driving for nearly 2 years, I was trained to change up every 5 to 6 hours. In doing so, I was able to accomplish awards of safety of 40,000 & 100,000 miles, including 1 year of incident and safe driving from my former company. If I have to endure this new rule, I'm uncertain of the altercations that could arise. I find myself getting tired, sleepy and I've witnessed the aftermath of other drivers having accidents on the road, I feel that the pressures of the road are enough for anyone of us out there, without forcing us to drive beyond our limits. I'm wondering if any of you have ever driven a truck or are your positions purely elected or appointed? You have to drive a truck to tell me how to handle it. Every team that Iknow of has complained that you people don't consider what's best for team drivers. I hope that isn't the case. I like driving team and the company I'm with now is a good one.

This is an edit and an addition to the above comment: The “injustice to all team drivers” referred to in the comment applies equally well to solo drivers. The difficulties described in the comment are similar to the difficulties suffered by solo drivers.



Ken - Comments 01/09/2006 PUBLIC SUBMISSIONS
The new law that came out Oct.2005, about 8 cosecative hours in sleeper plus two more hours off duty is vary unsafe.You are making drivers drive eleven hours straight.Because when they go in sleeper they have to stay there for eight hours.And also why are there not differant rules for team drivers. If you rotate more then the sleeper birth rule is to long a time,this forcing drivers to drive ten or eleven hours stright.

This is an edit and an addition to the above comment: Solo drivers are also forced to drive ten or eleven hours straight. The “force” being used is tantamount to an “economic sanction.”



Anonymous - Comments 01/11/2006 PUBLIC SUBMISSIONS
The new HOS does not take into account the true safety and well being of team drivers in that too many hours are required to sit behind the wheel while the other team member is getting their required time off.The new ruling seems to be addressing solo drivers getting more rest.My wife and I have talked to lots of other teams and very few of them split their driving times to periods longer than 5 hours of driving at a time,thus forcing them to falsely log their actual hours of service.

This is an edit and an addition to the above comment: The new HOS rule in no way allows a solo driver to obtain more rest. To the contrary, the rule robs the solo driver of much needed rest at the times when rest is most critical.



Anonymous - Comments 01/17/2006 PUBLIC SUBMISSIONS
obviously no one at this agency has ever team drove a truck. now i have to drive for 10 hrs straight with no breaks because i haul explosives and sensitive items for the gov. and cannot stop and relax i have to stay with load cannot leave truck. if my shift starts at 6pm i have to go till 4am. this is nothing about safety. when i wreck and if i live i will definatly be suing this agency and whoever made these ridiculous rules. you people have got to be held accountable for your actions. you are not above the law or no better than anyone else. so if you make stupid regulations you will have to deal with them. ther was nothing wrong with split sleeper berth for teams. teams have been driving 5/5 for years.



Kim K. Sullivan - Comments 01/19/2006 PUBLIC SUBMISSIONS
My husband and I have been driving team for several years now. The new HOS rule is absurd for teams. Our truck rarely travels more than 1000mi/day and the new rule requiring 10hr or 8/2 split has substantially contributed to fatique. Prior to the change, we were splitting 7/3 or 6/4 and as most of our non-driving time is spent in the sleeper berth, this new rule makes no sense at all. Please reconsider for safety reasons.

This is an edit and an addition to the above comment: A solo driver makes the same request: “Please reconsider for safety reasons.”


James W. Hoefer - Comments 01/23/2006 PUBLIC SUBMISSIONS
The 'new' HOS rules are endangering my life and the lives of other motorists.

Further, they are costing the trucking industry lost revenue and causing drivers to quit and find other employment.

I drive for a "hot shot" service - small trucks, usually under 10,000 LB GVWR but some up to 25,000 Lb GVWR - with no relief driver or sleeper cab. (I now only drive as a "last resort" - as favor to my employer when he runs out of drivers and will lose money or clients for lack therof. I took early retirement a year ago rather than continue to drive full time.)

To use a typical 'run' as an example; let us say two drivers are dispatched in separate trucks from Salt Lake City to Ruth, NV, a four and a half hour drive, one way,under ideal driving conditions. Both are driving trucks over 10,000 Lb. GVWR, but less than 26,000 LBS GVWR. (Most of the trucks we drive are UNDER 10,000 GVWR, but usually the only difference with smaller trucks is in the way the log books are kept. - Time record only vs. detailed data.)

The first driver has had a good night's sleep, woke up around 7:30 AM and is dispatched around 8:00 AM, with the load already on his truck. He does his inspections - which, under the new company requirements, now takes the better part of a half an hour (instead of the previous ten to fifteen minutes). He then drives about four and a half hours at the legal speed limits under ideal road conditions, delivers his load and returns to base. He may even take a lunch break as he'll have some time to spare - but not much, he can't really 'relax' while he eats. After driving that long, he SHOULD take a break (my driver's safety training in the USAF and with Pacific TEL & TEL - in the 1960's - both said at least 5 minutes for every hour on the road - with a minimum one ten minute break every two hours, preferably fifteen minutes at two hours, and a half hour at four hours - personal experience tends to confirm those guidelines). He is allowed 11 hours of driving time and three hours of additional "on duty" time (loading, unloading, fuel and meal stops, rest breaks). Nominally, his trip, including unload time (if there are no delays), inspection time, and two fuel stops (to meet company "3/4 tank" re-fueling directives) would be about ten hours (nine behind the wheel, a half-hour to unload, two fifteen minute fuel stops) - leaving reasonable driving time (two hours) for bad weather on the way back (which we often have "out west" in the winter, often with little or no warning, not even from the weather bereau - and let's not forget delays due to accidents by OTHER dirfers. I once sat for over two hours waiting for an accident to be cleared away enough to let traffic through. I SHOULD have been allowed to call it "off duty" because I was not actually driving - the engine was off and I was able to get out, walk around, or lay the seat back and doze), and about two hours of "On duty, not driving" time - which he could use for rest breaks and a meal. More practically and more wisely, he should take at least a half hour for lunch and then at least one fifteen minute rest break enroute. He should have taken at least one ten to fifteen minute break on the way out as well. No problems here - his HOS will be comfortably within the regulations (unless he has to wait for an accident to be cleared away!).

The second driver, also, has had a good nights sleep, and awoke around 7:30 AM. However, HIS call came at 4:00 in the afternoon. He has been awake for over eight hours and may have been "relaxing by the pool" or "working out" in one way or another. Now, eight and a half hours into his day he gets behind the wheel and hits the road. Same Hours of Service, same 'run' as the first driver.

However, by the time he reaches the unload point it is 21:00 or better and he is beginning to get tired - perhaps drowsy - it is approaching the time he normally would start winding down for sleep. His body is expecting him to be in bed in an hour or two. BUT he still has four and three-quarter's hours of work ahead and is running on an empty stomach. He needs food and rest. His four and a half hours of driving ahead, does not include time for a fuel stop - ON duty, NOT driving. This time also does not include the time to complete the paperwork at the end of the run (usually 15 minutes or better - depending on how tired he is and how clearly he can think at this point) and he still has to drive his OWN vehicle HOME from the office - he's STILL driving - just 'off the record' but just as dangerous as if he were ON the record. His log book shows the same number of hours available as the first driver, but his BODY says "NO WAY!" He NEEDS REST - at least he will by the time he is half way home. But if he takes a meal break (dinner, in this case - a LATE dinner, as the delivery must be made FIRST) it is now even later and he is likely even MORE ready for sleep - in addition, there is the normal bodily reaction that says "rest" after a meal. However, under the new rules, he hasn't got TIME to take a rest break (let's say 'nap') long enough to be properly rested, which rest he seriously NEEDS. If he sleeps in the truck at a rest area (remember, no relief driver or sleeper cab) for more than two hours (ON duty, not driving under the NEW regulations - OFF duty under the OLD regulations) he will likely be in violation of the HOS rules. He COULD take a room in a motel but THEN he would be required to take ten hours off duty (even if he only needs five or six to be rested enough to safely complete his trip) and he would have to pay for the room, and per the Company Hand book, part of his meal, out of pocket - a cost nearly equal to his pay for the trip. (Motel room - around $50 in Ely - a decent dinner, around $15 - over twice the Company "standard" allowance of $7 per meal, and half again the usual cash advance for that trip). If he DID take a room on his own, both he and the truck would be missed the next morning. AND the truck would be out of service, possibly costing the company lost business.

So much for the "DUH!" conclusions.

At 18 years of age, I often went 20 to 24 hours, sometimes as much as 72 hours, without sleep. At my age now, that has become impossible without taking 'alertness' drugs - which have been shown to be unsafe and relatively ineffective - even caffeine can only help just so long. Being required to obey the new rules now precludes using common sense and sleeping when tired - because the "rules" don't allow for common sense safety or bio-diversity among men and women - especially when it comes to driving "small" trucks. Ergo, under the new rules, "One Size Fits All" (NOT!)

Therefore, until we get authorization for drivers to take a rest break and or a meal when we feel the need, and call it "Off Duty Not Driving" on the log (as we could under the OLD rules) I simply will have to turn down any run that may push my physical limits, relative to the new HOS rules.

The only solution I have to this second situation is to delegate certain drivers for 'night runs' and others for 'day runs' - even then, the problem may still exist unless the "night" drivers get enough work to establish a s leeping routine that allows them to consistently sleep in the daylight hours and be rested for evening runs - something I think would be nearly impossible to accomplish.

There you have it, Mates.

Intelligence is that factor which enables some people to get along without a college degree. A college degree is, apparently, that factor which enables some people to get along without the use of intelligence! I'll lay odds that the folks who made up those driving (HOS) rules all - or nearly all - have college degrees!

Maybe they all wear neck ties - which have been shown to cut off the flow of blood to the brain and therefore impair mental acuity.

James Hoefer
169 Sun Arbor Terrace, Apt 1222
Salt Lake City, UT, 84116
Cell Phone: (801) 688-6989


Knight Transportation - Comments 01/23/2006 PUBLIC SUBMISSIONS

The new Hours of Service Rules, Do NOT address the Sleeper Team Operation. Teams should be able to split drive time and Sleeper birth time at least 5 hours driving and 5 hours Sleeper Birth or 4 hours driving and 6 hours Sleeper Birth to meet the 10 hour reast rule./ My wife and I have driven a team operation for 14 years. 2,000000 accident free miles. The new rule forces us to drive 4 to 5 hours longer at one driving scession WITHOUT sleeper birth rest.

The 8 hour plus 2 hour sleeper birth rule makes NO SENSE for a Team! We drive refreshed after 4 to 5 hours consecutive sleep in the Sleeper Birth and can get the loads to customers who require next day delivery. Whoever writes these rules has not studied team operations and most of the data has come from individual drivers. Team Driving operations need more attention and should not be lumped in with Solo Drivers!

This is an edit and an addition to the above comment: This is an edit and an addition to the above comment: An exception to the rule for teams implies that the HOS rule in dispute here is somehow more tolerable for solo drivers. This is far from true.


Paul Ozier - Comments 01/26/2006 PUBLIC SUBMISSIONS

Hello,

Everything I read concerning truck driver saftey shows that truck safety is at an all time best. If that is the case, why did FMCSA change the Hours Of Service to a rule that causes drivers to become more fatigued. No driver wants to take a rest stop due to the fact that the 14 hour clock does not stop. The rest period will eat into their work day. But, now drivers are trying to drive straight through their 11 hours. Has anyone at FMSCA driven for 10+ hours straight, everyday for a week? Real world experience would make you change the HOS in a second!

To me it makes sense to stop the clock if a driver needs a rest. More fatigued drivers will lead to safety issues. At least offer something to accomodate the needs and safety of the drivers. Many times driving a person will get very tired. A simple 30 minute nap will do wonders for a person. Now I am not saying stop the clock for a 30 minute break, but let's use the old rules. Remember, safety was at an all time best. Why mess with something that is working?

Thanks for allowing me to comment.
Sincerely,
Paul


Doyle H. Moore - Comments 02/14/2006 PUBLIC SUBMISSIONS

as a driver of 17 years, I am of the opinion that the entire h.o.s. regulation(s) are overdue for complete rewrite. That said, specific suggestions follow: 1)the two/eight split of sleeper time doesn't work. The idea that taking an hour off for a meal must be connected to either a two or eight hour sleeper break, in order to avoid counting against the fourteen hour clock, causes drivers to either skip meal breaks, or not show them on the log. I personally don't ever take two hour naps, but for example, if I show a three hour or four hour nap it negativly impacts the time I am allowed to work for that day. The net effect is either a false log entery or a tired driver. Within the rest period required, the driver should have the freedom to decide when and how much rest he/she requires. Further a certain amount of off duty time should be allotted,without impacting the 14 hour clock, weather it's spent watching tv, eating or just releaving tension at a mall/store. Mental/physical stress is not always best resolved in the sleeper. Of course the real answer is to change the per mile/percentage based pay to an hourly based pay with overtime. Remove the reasons for illegal running, solve the problem. An hours driving for an hours pay, sheesh what a concept! Thanks for your time.


William R. Rogers - Comments 02/21/2006 PUBLIC SUBMISSIONS

Instead of all the upcoming court battles over the HOS regulations, sleeper berth time and off duty time, let the driver drive the miles the way he(She) feels like but put a limit of the number of miles a driver can drive. If the miles are limited then the driver has plenty of time for rest. Just a thought.


Kathy A. Buck - Comments 03/01/2006 PUBLIC SUBMISSIONS

as a husband and wife trucking team, we had to quit our $125,000 household income job with jb hunt due to our inability to cope with the new hours of service. when we could drive 5 and 5, we did just fine. 10 and 10 does not work for us. please return to hours of service that allow teams to run 5 and 5 so that we can be gainfully employed again. sincerely, Kathy Buck


Benn Dipp - Comments 03/06/2006 PUBLIC SUBMISSIONS

OOIDA, as well as others seem to think that the non sleeper berth provision is unsafe, unhealthy and stressful for team drivers. For the record, It is no more stressful for a team driver, to have to be caged in a sleeper berth for eight hours straight, Than it is for a Solo Driver. The only difference is, that in one instance the truck is rolling verses setting still. They need to think through this split-sleeper berth provision thoroughly.

The best known senerario is to adopt the Texas Intrastate HOS. The safety record for TX intrastate drivers, proves this to be the safest and most fair rule across the board.

The main difference in adopting the TX Intrastate rule, is that when you [the driver] are asleep (you,can log it as sleeper berth), when you [the driver] are off-duty, (you, can log it as off-duty) when you [the driver] are on-duty, (you,can log it as on-duty} and when your driving, whether its for one hour or twelve hours, you [the driver] have the flexiblity to utilize the clock to your best advantage ,therefor not jeopardizing safety for anyone.


Robert A. Hughes - Comments 03/13/2006 PUBLIC SUBMISSIONS

In my opinion the new split sleeper berth rule is unfair. I haul expedited freight, and if there is not time for an 8 hour break in the load, I have to turn it down. It has cost me a lot of money. Also the logbook example #3, for the new hours of service is wrong. The 14 hours would be up at midnight, not 1:00 AM


William W. Holcomb - Comments 03/27/2006 PUBLIC SUBMISSIONS

The new Hours of Service rugulations which came into effect October 2005 leave a great deal to be desired. The main complaint is the split sleeper rule which maintains that it must be taken in an 8 and 2 hour split with the two hour counting as part of the 14 hour work criteria. Most drivers don't use the split sleeper rule, because it does count against the 14. Most drivers don't understand it and don't even attempt to use it. I understand that some people feel that we all must have 8 hours of uninterrupted sleep and have even done studies to prove thier point. I only sleep 8 hours if i've had a very hard day and normally get by with 5 (ever since the Marine Corps showed me that I functioned better and that was 1964). Rich Clemente of Federal Motor Carrier Administration tells me theis rule was developed after compehensive research and studies of sleep and fatigue. Scientific studies always tickle me because according to such a study; bumble bees can't fly. The bumble bee, not being very scientific, just keeps flying. Prior to this change of rules I could drive five hours, take a nap for five and drive again or change up this combination, as long as the breaks always added up to at least 10 hours and my driving peroids did not exceed 11 hours. A driver could schedule a break if he happened to be approaching a city or congested area at rush hour, removing a vehicle from traffic and reducing the stress on the driver.

Under the current rule many drivers are pushing themselves to drive 11 hours, even though their bodies and common sense says stop. The rest areas and truck stops are bedlam and crowded at night forcing many drivers to stop on off/on ramps to sleep. DOT officers I've spoken to on this subject can't understand the reasoning and state that it should have been left alone. For it was simple to understand and regulate. I ask that you return to pre-Oct. 2005 regulations. In short the revised regulations puts undo stress on traffic, facilities, DOT and the driver.


- Comments 03/30/2006 PUBLIC SUBMISSIONS

I only recently become an OTR truck driver. I was flabbergasted to discover that the HOS rules actually prevented me from sleeping when I needed to. It is common knowledge among sleep experts that regularity is vital to getting good sleep. You need to sleep when your body is ready to sleep! It is frequent occurance for truck drivers that you get a load assignment which requires a late pick-up and an early delivery. The only way to get such a load delivered ontime is to drive all night, take a 10hr break in the middle of the day and then drive all night again. The end result is that you go for 48 hrs with no sleep, because the 10hr break during the middle of the day is worthless. Drivers would be much better served if they had the freedom to break up their sleep period on days they pick-up or deliver so that they could get as much sleep as possible during wee hours of the night when their bodies are ready to sleep and, in fact, trying desperately to do so. Fatigue related accidents happen all the time just within my carriers fleets and they happen in the very early morning hours for just exactly the reason I've described. Do you guys actually care about whether drivers suffer, live or die? Do you care about the safety of the general public? If you do, then you will get new experts to change the HOS rules, so that us truck drivers can start driving well-rested and safe. Your current "experts" seem fixated on this whole "10hrs unbroken" crap. Well, the truth is that, 4hrs of sleep between 2:00 and 6:00 am is vastly more restorative than 10 hrs in the middle of the day. If your "experts" don't understand or appreciate that, then they are a clueless lot of fools and don't agree with the majority of sleep experts out there.


Debra I. Jurashen - Comments 05/08/2006 PUBLIC SUBMISSIONS

To whom it may concern: I have been driving since 1980,the HOS need to be changed,we drive as a team,we need to be able to drive as we feel comfortable with it.We need to be able to split our sleeper birth in 2 times,without being punished for it.There are days,when I feel like driving 10 hours straight,but then there is days when I hate to have to drive 10 hours,before I can sleep.We need this HOS changed for everyone, not just team drivers.I personally invite you to go with us on a long haul and drive 10 hours straight,each time, I really feel you would know exactly what we are saying about the rules do not help us-instead they are hurting all truck divers.
Thank you ,Sincerly,Debra Jurashen


Carol A. West - Comments 05/09/2006 PUBLIC SUBMISSIONS

Please consider that we are explosive and weapons haulers for the D.O.D. The new hours of service rules do not allow us as team drivers to properly drive and guard the loads that we haul. We are required to be in attendance of all loads at all times, this means that one driver must remain in the truck awake and in the seat, not the sleeper bearth if the other driver leaves the truck for any reason. In doing so, this breaks the sleeping driver's sleeper berth time. We have always run team for these loads and we have made the split sleeper berth work for us and the United States Government for many years.

It seems tha along comes the FMCSA and changes the rules and thus, puts our country in jeopardy by making new rules that we cannot follow and still follow the rules of the DOD. We cannot serve two masters, and the safety and security of our country comes first with us and with Homeland Security. Please consider an exemption for the weapons and explosive haulers and allow us to continue to keep our country safe by allowing us to continue to use the split sleeper berth and to continue to safeguard our loads as we have in the past.
Thank you very much.


Gary R. Patten - Comments 06/20/2006 PUBLIC SUBMISSIONS

To whom it may concern,
I have been driving X-country sleeper truck for over 18 years. Under the old hours of service rules a sleeper team could run 10 hours on and 10 hours off if that is what worked best for them in giving them enough rest. They could also run 8 and 8;6 and 4; 5 and 5; 8 and 2; 4 and 4; whatever worked best for them (flexibility. But now under the new hours of service a driver must take 8 consecutive hours off in the sleeper berth. I must say that I can't sleep for 8 consecutive hours at home in my waterbed, let alone in a moving truck bouncing over rough bridges and potholes in the road. Now under the new HOS rules I find myself driving more and sleeping less. THIS IS NOT SAFE! We as drivers in the field WERE NEVER ASKED how the HOS rules would affect us. This does not happen in the airline industry: pilots do have input when the FAA contemplates new rules. WHY IS THIS HAPPENING TO US??!!

I would much appreciate it if there would be a review of the HOS rules for the sake of tired drivers who shouldn't have to log illegally in order to stay alive.
Signed,
Gary Patten
Road Driver with UPS Freight (formerly Overnite Transportation)


John H. Dickey - Comments 06/26/2006 PUBLIC SUBMISSIONS

HOURS OF SERVICE
On the Hours Of Service it would be better to let the drivers have a little flexibility on when they stop. If they are almost out of hours, but would like to stop at a certain truck stop, or go on to the customer and sleep there, and it is one or two hours further down the road, they still have to stop some place they don't want to.

Let the drivers drive for some time after the 14 hours so they can pick a better, and maybe safer, place to park. If they drive for one hour longer, then the next time they drive they would only have 10 hours to drive the next time, or 13 total hours on duty. This would make it more flexible, and the driver still gets the same amount of time off and the same total driving time.


Deborah R. Eudy - Comments 08/01/2006 PUBLIC SUBMISSIONS
i have been trying to adjust to the new hours of serivce without the split sleeper berth. i am informing you that the removal of the split sleeper berth is a complete safety violation. as a team driver with 11 years of safe driving i am being forced to drive when i am tired. my legs hurt extensively my back aches my legs swell all because i am required to stay behind the wheel till my team driver gets in his 10 hr break.

we were much healthier and better rested with the 5 on 5 off. who ever decided this was safer is a complete idiot. you obviously dont understand team driving at all. when you sit for 24 hrs without driving both parties have been in the sleeper for most of that 24 hr period. then when one starts driving the other one cant sleep for another 10 hrs. then when the other driver starts driving they are now tired but the log book says they must drive.

we have to make delivery of our freight and with hauling arms ammo and explosives you cannot leave the load unattended and you cannot sit for more than 2 hours. so your hours of service rules arevviolating safety regulations by requiring me to drive fatigued. i am very upset and considering quitting or getting a lawyer to file a lawsuit against your regs.


Melody L. Jackson - Comments 08/15/2006 PUBLIC SUBMISSIONS
My Name is Melody Jackson, and i am a truck driver here in texas,I have been driving since 1998. I have seen alot of things in those years, But since you all have taken away the split sleeper beth and made it consecutive. This has caused Very Very Tired Truckdrivers on the Road, YOU SEE BEFORE THIS CHANGE, THE DRIVER GOT TIRED HE PULL OVER AND WAS ABLE TO GET THE SLEEP (HIS OR HER REST), THEN SAFELY GET BACK ON THE ROAD TO DELIVER THEIR LOAD. BUT NOW THEY ARE UNABLE TO DO THIS. WITH OUT RUNNING OUT OF HOURS. SO THEY NOW CAN NOT GET THEIR NAPP. WHICH REFRESHED THEIR MINDS AND BODY TO CONTINUE ON WITH THEIR DELIVERY SAFELY,SINCE YOU ALL PAST THIS NEW SLEEPER BERTH LAW,I HAVE LOST 7 FREINDS TO TRUCK WRECKS AND I MEAN MANGLED , JUST LAST WEEK THE 22ND OF THIS MONTH A VERY GOOD FRIEND WHOM HAULED BREAD FOR MRS BAIRDS OUT OF HOUSTON TX BURNED TO DEATH IN HIS TRUCK,AND ANOTHER DRIVER WHOM WAS BEHIND HIM DIED 14 HOURS LATER,THIS WAS NEEDLESS,ANOTHER TRUCK ROLLING NORTH BOUND FELL ASLEEP,HE KILLED MY FRIEND.

PLEASE LET THESE DRIVERS HAVE BACK THEIR SPLIT SLEEPER ,THEIR ARE TO MANY TIRED TRUCKDRIVERS ON THE ROAD,LET THEM GET THEIR REST, UNLESS YOU HAVE DRIVEN A TRUCK FOR A LIVING YOU DONE KNOW,HOW THE MIND NEEDS A NAPP ,WE ONLY SLEEP 4 TO 5 HOURS AT A TIME AND THAT IS MOST OF THE DRIVERS OUT HERE. YOU ALL CAN ALSO THINK ABOUT SOMETHING LIKE GIVING THE DRIVERS 750 MILES ADAY TO DRIVE AND THIS WOULD HELP TO ELEMENATE SPEEDING AND LONG HOURS AND THIS WOULD BE EASISER TO KEEP UP WITH DRIVERS CAN REST WHEN NEEDED AND ALL WOULD BE BETTER .BUT IM SORRY YOUR NEW WAY IS NOT WORKING,MORE PEOPLE DYING THAN BEFORE.


Michael M. Davis - Comments 09/06/2006 PUBLIC SUBMISSIONS
It has been some time since the new HOS rules have taken effect. I have a deep concern regarding the way in which the rules have not only changed the way we as Truck drivers work but also the fatigue we are encountering out here on the road.

First, I do not know who decided that a fourteen hour workday with no rest break is "safer" for the driver or the public. I do not know what study this individual relied upon to suggest that without at least a 2-4 hr break on a long shift such as this, that a person is alert and able to react in any situation which requires fast thinking in order to avoid tragedy.

I have more than twenty two years behind the wheel with No Accidents. I can assure you that these new HOS rules are creating a less safer environment on the highway. My fatigue levels have increased dramtically since trying to comply with these new rules. I have also experinced a higher level of stress due to the inability to rest periodically during my 14 hrs. This is not a situation that needs a longer work day,(which it does) to complete my duties and operate my vehicle safely. While on the piece of paper these rules seem to work for the companies who paid for and wrote the HOS change, the REAL effects to those of us out here who have to follow them are dangerous and deadly. The health issues due to increased stress and fatigue on the drivers, although not apparent at this time, will undoubtedly be a factor in future major accident statistics.

The rules should reflect the needs of the driver and not that of the companies we work for. The life and death situations we occasionally face out on the highway, with inexperienced drivers both commercial and non-commercial should mandate the we are given the "opportunity" to take a rest break to ensure we are properly rested. In other words,I NEED a nap once in a while when I don't get enough rest. And only a 10 hr. break once a day is fine if you go to work at 06:00 and get home at 20:00 every day. This does not happen in the real world of trucking. And the absence of adequate parking spaces forces a driver to continue long after they can safely drive to find a "spot" to park leaving the issue of dangerous roadside parking accidents.

The science that has been relied on to form the opinion that rule changes do not need to allow for intermediate rest periods to continue a workday that, as most of us out here know, far exceeds what is allowed by law. This is just fact, and no amount of regulations can change this. And until this is "accepted", any rules change will only create more problems for the public safety issues you are trying to address. While trying to regulate compliance issues with more, and increasingly ipossible to follow rules for the drivers, why not consider making rules that force the shippers and recievers to adjust their "just in time" requests.

The burden of responsibility rests with ALL who are involved in the transportation business. Regulating one part to satisfy the other leaves a gaping hole for unequal blame and unprecedented lack of responsibilty.
Thank you,
Michael M. Davis


P. LaRue - Comments 10/10/2006 PUBLIC SUBMISSIONS
General Comment:
I would like to say that the H.O.S. as they currently stand, do NOT secure a safer driving situation for most of us. There are simply too many variables to be able to control the drivers' hours of driving at that level. These variables include for instance, the loading/unloading times, the traffic congestion in a given area, and the weather. Also, I would say that the current H.O.S., while younger drivers may be able to adapt to them, there are a significant number of us older drivers (age 40+). No research has gone into how the Hours of Service affects our sleep cycles, which differs radically from what it was when we were 25 years old. Furthermore, the studies that were done suggest that naps are GOOD for people! How many progressive companies over the past 15 years have adopted policies that allow a worker to take a nap? It does improve performance. So what is wrong with the government that you all can't see that?

Personally, I seldom sleep more than 5 hours at a time. To be forced into an 8 hour break (minimum, if I took a 2 hour break to combine for the required 10) causes me to waste 3 hours waiting for the clock to catch up. Then.. later in the day, when I could use a good 3 hour nap, I'm limited to 2 hours, or none at all if I want to be able to have a meal or shower.

I do not need a DOT officer tucking me into bed. I don't need a dispatcher running my body either. I am nearly 55 years old, I have raised 5 kids to adulthood. I don't think I need to be treated like a child, who doesn't know when it's time to go to bed. And I don't need to have my dispatcher breathing hot flames down my neck because I can't roll simply because I'm forced to take unnecessarily long breaks. I KNOW when I'm sleepy, and what to do about that. I know that a rested driver is an alert driver, and THAT is the name of the game for me. What I want to do is be in control of my driving and my sleep. No one is more concerned with my safety than I am. Just like the commercial, "It's not nice to fool Mother Nature!" Mother Nature is the one I would rather listen to. YOU don't know me, my life, or my needs. But I most fervently would love to see that we drivers are given the right and the freedom to sleep when we need to, without penalty, and drive when we are rested and alert, without penalty. I think the 10 hours sleeper time is enough. But let us work it out ourselves how that is going to fit into our driving day. It really seems perverted to me that the government wants to regulate my life in such a microscopic way.


Anonymous - Comments 11/22/2006 PUBLIC SUBMISSIONS
General Comment:
your 8hr sleeper birth and 2 hour sleeper birth which counts toward the 14 hr. work day is about as stupid as we truckers would expect you desk jockies to make. What in the world was wrong with us spliting the 10 hour sleeper birth to fit our schedules as long as one birth was no less than 2 hrs? And the rules for teem drivers...come on...are the people makeing these stupid rules envolved in driving a truck over long periods of time or are you having some collage do sleep studies that have no idea how long haul truckers develop a time clock on how we run and our bodys adapt. In my opinion you have made the highways more unsafe by forceing us to brake the 10 hour sleeper birth to satisfy some rule insted of letting us sleep as we need it as long as 1 birth is no shorter than 2 hours?


Delbert R. Vaughn - Comments 01/03/2007 PUBLIC SUBMISSIONS
General Comment:
I AM SUPPORTING THE OOIDA PETITION 100% ON THE REVISED HOUR OF SERVICE. THE C URRENT LAW IS A KILLER FOR THE DRIVER TO GET THE MUCH NEEDED REST WHILE IN TRANSIT. 8 HRS. IS OK BUT THE EXTRA TWO NEEDED FOR A BREAK IN ROUTE SHOULD NOT BE USED ON THE 14 HR.RULE. BY COUNTING THE 2 HR.INTICES THE DRIVER TO DRIVE FASTER TO MAKE THEIR E. T. A. ON TIME. MANY, MANY LOADS COME RIGHT DOWN TO THE VERY LAST 5 MINUTES BEFORE SCHUDLE ARRIVIAL TIME. THE DRIVER DOES NOT HAVE THE PROPER TIME TO STOP AND EAT,RESTROOM BREAK,OR MANINTENANCE VEHICLE IN ROUTE,OR HANDLE A MINOR BREAKDOWN. THE 2 HR. RULE IS VERY VERY CRITICAL IN COMPLETEING A DAYS WORK SAFELY AND TIMELY. PLEASE, PLEASE FOR ONCE ASK THE PEOPLE THAT ARE DOING THE WORK WHAT THEY NEED, TO DO THE JOB SAFELY. I THINK YOU WILL FIND THAT IT IS NOT THE DRIVERS BUT THE SHIPPER GETTING THEIR PRODUCT OUT LATE AND EXPECTING THE DTIVER TO MAKE UP THE DIFFERANCE IN TIME ON THE HIGHWAY. IT IS NOT THE DRIVER AS A WHOLE BUT THE SHIPPERS THAT CAUSE THE PROBLEMS. YOU REALY HAVE NO IDEA WHAT WE ARE FACED WITH EACH AND EVERYDAY TO MOVE ALL THE GOODS ACROSS AMERICA. WE NEED THE PEOPLE IN CHARGE THAT ARE MAKING THE RULES TO FULLY UINDERSTAND THAT ARE TWO SIDES OF THE STORY. I DO NOT TELL YOU HOW TO RUN YOUR DEPERTMENT , SO DO NOT TELL ME WHEN TO SLEEP! I KNOW WHEN, MY BODY TELLS ME. WE NEED YOUR HELP 100 TIMES MORE INFORMING THE GENERAL PUBLIC ABOUT THE GOOD OF TRUCKING AND SHAREING THE HIGHWAY WITH ONE ANOTHER. THAT IS THE PROBLEM NOT THE 10 HR. RULE. GOODGRIEF!
DON'T BE A STUMBLING BLOCK, HELP US.


Robert W. Johnson - Comments 01/10/2007 PUBLIC SUBMISSIONS
General Comment:
I don't know who needs to get this, if it even would matter, but I have some comments about the HOS regulations. Firstly, why do ya'll buckle whenever some little activist group doesn't like the rules. We used to have a break, but not anymore. Now they say we don't get enough rest. Well, DUH! Our break was taken away. If I have a head cold and need a little rest, I can't get it without risking a drop time. There are some drivers that say all we need is a seven hour off duty time. They are wrong. Personally, I like the 10. Sometimes it's a bit excessive, but generally it's ok. I like the restart. We needed that. Driving 11 hours? Only if I have to. That's too much for anyone. Speaking of which, a 70 year old man with no proper training can buy a 40' RV and drive as long as he wants. THAT is dangerous. Why are we the only profession the government sees fit to play Communist dictator with? The problems of trucking lie with the shippers, receivers, and dispatchers. WE just do what we have to. 95% of the time, all is good. That other 5%, well.....

I just turned down a load the other day because it had me going 1000 miles in 24 hours. That's a few hours shy of what it would be legally. Of course, I turn down a load, I get a black mark...even tho it was a legitimate reason.

Back to the activists....tell them to shut up. The only reason they are listened to is because they "donate" to politicians. Those politicians need to have some sense of dignity, but it won't happen in our lifetime. Activists only care about the here and now. They don't think about the outcome down the road. This goes back to the split break. We need it, just the way it was before ya'll took it from us.

Yes it is bad when a truck is in an accident, due to our size. However, most of the time it isn't our fault. People nowadays drive like they are the only ones on the road. They whip in and out of traffic, barely missing the car they just passed. A kid whips in front of a big truck, suddenly traffic stops, you got a dead 18 year old. It is then the trucker's fault for "following to close", when it's the kid who thought he was in "The Fast and the Furious" that caused his own death.

I'll be the first to say, if a driver is over the 11 hours and he has a wreck, yank his license. If he kills someone, he goes to jail, and his company has to pay the family very well. I don't let the driver off the hook because he knows he's not supposed to do that. The company...because they forced him to do it. Appointments can be changed when the shipper takes too long to load. Nothing hauled by truck is that important.

Another problem is loading/unloading. We drive the truck. These places shouldn't make us unload their freight. (Or pay a lumper). They want it, they put it on and take it off. PERIOD!

Anyone with common sense will understand this. It's the ones that would rather fatten their wallets that don't care. I wish every trucker in the country would shut down for two weeks. I bet we'd get OUR concerns heard. We don't need on-board recorders. We don't need to be governed at 68 mph (unless you want to govern cars to). Anti-collision devices are ok on the sides, but not the front (I have a windshield, I can see). We don't need split speed limits (that's discrimination). We need better pay, but doesn't everybody (except the people "running" our country). We don't need the body that sets our rules and regulations running scared from whiney little activist groups that just want to make other folks as miserable as they are.

If you are still reading this, I thank you....and I will shut up now. I have a load to haul tomorrow that's not going to get me home.


Robert L. Stanton - Comments 04/09/2007 PUBLIC SUBMISSIONS
General Comment:
Dear Sir,
Concerning the HOS rules, it is my opinion that if the FMCSA was truly concerned about the safety and well-being of the drivers, they would conduct a study involving medical doctors, psycologists, and law enforcement officers, perhaps having them ride with a select group of professional drivers, and observing what actually happens while driving on the road. However, in order to truly get an accurate idea, the group of drivers selected, should be offered immunity for any mistakes they may make while the study is being conducted.

I believe this could alleviate any opposition to a new HOS rulemaking. Thank you for your consideration on this issue.


Dennis N. Johnson - Comments 07/31/2007 PUBLIC SUBMISSIONS
General Comment:
Regarding the hours of service rules: I submit to you that a piece of paper connot dictate to a driver of when he or she is too tired to continue to drive. The 14 hr rule is totally rediculous. It is completely unsafe and unwarranted. The 14 hr rule is forcing drivers to continue driving when they may be too tired to be behind the wheel of a big truck. The reason is because a driver connot afford to stop and take a rest during the 14 period if he or she is too tired to be driving because it penalizes their progress in being to the legal point of where they need to be at the end of the day to keep their deliveries on schedule.

If a driver gets too tired to stay behind the wheel a short nap is very affective in keeping the driver alert and able to continue. Then let the driver continue to drive until his or her 11 hr period of driving is up! Eliminate the 14 hr rule and let the drivers use their own judgment as to when they are too tired to be behind the wheel. All the drivers I talk to hate the 14 hr rule because it forces them to continue driving when they should not be driving. Let them take a nap and then continue until the driving hrs are fulfilled.

Also the 10 hrs off duty in one stretch is excessive. No one should be required to sleep for a 10 period each day. No one needs 10 hrs of sleep each day. Let us sleep when we are tired and drive when we are awake. I think that each driver knows when he is tired and when he is not. A piece of paper should not dictate his needs.

Give us 14 hrs of work a day with a total of 10 hrs off duty and or sleeper berth each day in the order of driver disgression!

Dennis N Johnson


David W. Cox - Comments 08/14/2007 PUBLIC SUBMISSIONS
General Comment:
I am tryin to figure out how you people who have never drove a truck before can sit there and tell us drivers what's best for us.Everytime there is an accident the big truck is to blame.I find that wrong and profoundly unsettling.The FMCSA ties are hands to were we cannot do anything without getting harrassed by the DOT on everyday bases.You want to change the hours of service cause you assume fatigue is causing all the accidents on our nations highways.Well I disagree for a bunch of college educated people you don't have a clue what goes on out here only what you see on the news or what is on a piece of paper.As a driver I already know the police don't like us and we really don't care cause the feeling is mutual. Four wheelers cut us off,slam there brakes in front of us,speed up and slow down but no one seems to care about that.7 out of 10 times all accidents are caused by four wheelers but the big truck seems to be at fault and to put more restrictions on us because of what four wheelers do is wrong and to blame it on fatigue is very disturbing.Ther is nothing wrong with the hours of service and to stand there and blantenly lie in front of a Federal Judge and say it is driver fatigue is a joke. You people in Washington can sit there push your pencils,press your button's and beleive what is said to you or what you read that's fine. To rear a truckers ugly head is a bad move to make do you care I didn't think so.


Charles R. Danielson - Comments 09/04/2007 PUBLIC SUBMISSIONS
General Comment:
I have been in the OTR for 30 yrs plus. First I believe the rules should be looked at reviewed by people in the business with strong consideration given to those that have to abide by them. They are the ones that know what works and what does not. First let me say that driving while sleepy is really a moral issue and morality can never be regulated. And often regulation puts such a burden on morality that one violates the law to keep his highest morality. So either way the driver loses their morality.

Such as. Split driving gives the driver the ability to sleep when they feel sleepy and yet able to get the job accomplished. Many drivers have ill health and not because of the industry. They had it before coming here as a last ditch effort to support their family. The industry allows it because OTR has never and never will be that glamorous to the population of workers ever. These drivers need special consideration of sleeping when they get tired. Splitting hours of service allows this. This does not account for the many other circumstances that arupt a systematic life style.

If ever anyone ran team they know to sleep 10 hours in the bunk is impossible. Especially if one has eaten bad food, or the road at that moment is rough, and temperature changes that affect one to wake up. Once awaken, often hard to get back to sleep. So the driver lies awake and then drives. WooHooo that makes sense.

34 hour reset has driven companies to make sure their drivers get home on this and every week. This allows drivers to touch base at home and take of those issues and a hug to the wife and kids and time in their own bed. Nothing like good sleep in ones own bed. Compared to the truck engine and changing temps in the truck and noises around. By using 8 day rule you in essence tell the company and driver they must sit. If done away from home it creates more anxiety to the driver that will be there when he drives again. The driver may not be tired or maybe because out of boredom the driver went to playtime. If not tired he is now in an anxious, upset mood that lends to accidents because the attention is not on driving but on other problems. The 34 gives one time to recoup without extended to boredom and the activities that go with it that lend to accidents when driving.

Last but not least is the constant rule changing frustrates drivers and frustration leads to accidents. Who here is really safety minded?? Please leave things alone until a thorough hearing has been done, which should have been done the first time. Above all listen to the drivers that have to abide to them. Union drivers are OTR but often should be considered Local because the operation set up with that idea. I am sure they would love you to regulate it so they can unionize. This is only one example of many private interests within the trucking industry. That means we need to look for much more flexiblity to handle the many different scenarios of the industry. So the driver can be safe and safety minded.

Listen to the drivers as the research I have seen is often for the average guy. Driving will never be average. It takes someone who will adjust and can handle adjustments. Because weather and truck breakdowns, and etc can never be completely controlled.
TIA
charley danielson


Jon Haley - Comments 09/04/2007 PUBLIC SUBMISSIONS
General Comment:
I would like to say about the hour of service rulling. I like the 34 hr restart it helps me get the time off I need. also I would like to see the old split sleeper come back. not everyone can run 10 to 11 hrs a day. we need to be able to stop our clock if we get tired after 5 hrs of driving or when wating at the shipper or reciver. thank you for your time. Jon Haley


Jay C. Shipley - Comments 09/05/2007 PUBLIC SUBMISSIONS
General Commment:
The biggest thing that stands between the trucking industry, and safety.....is these stupid rulings made by people who know NOTHING about being actively on the road. Don't "force" us into a 14 hour day.....when we don't even sleep when you do....normal hours. We should be permitted to nap, when necessary....eat, when necessary....shower and relax a few hours away from the traffic.....but NO....we'll run out of 14 hours. How stupid is that, people? So we ride the big rigs (once we start our 14 hour clock, it can't be stopped) whether we're hungry, fatigued, filthy....needing the refreshment of a shower....because a customer HELD us there too long, or someone caused a backup due to construction, etc. Wonder if FMCSA ever had to stand in line for their fuel slips for 40 minutes and wait......because truck stops are no longer......travel centers, who cater to cars and make us wait. But that 40 minutes adds into our 14 hour rule. Let's see now.....4 hours at a receiver, in the morning....drive for 2 to a shipper, for another load.....then 4 hours at the shipper.....now have 4 hours to drive 300-400 miles? And the load has been promised the next morning???? How does that work, folks? Our system is broken by people who can't walk the walk.....but they sure CAN talk!


Norma - Comments 09/07/2007 PUBLIC SUBMISSIONS
General Comment:
I think the new rules should be the best and most advantageous to the individual driver. We are not robots as these rules try to make us.Since long haul trucking is a 24hr a day job,the rules should reflect that and still give the driver the optimum use of time. Keep the 34hr restart,keep the 10 or 11 hr rule,get rid of the 14 consecutive hr day,(have it instead a rolling 14),and give back the split sleeper. That way,if we become tired after say 5 hrs,we can take a break in the sleeper and get up refreshed,ready for say another 5 hrs down the road.


Norma J. Christie - Comments 09/07/2007 PUBLIC SUBMISSIONS
General Comment:
You people should try living your rules before making us do it. Regulate yourselves to 11 hrs at your desks straight. No more than 15 min allowed each for bathroom breaks,eating,and showering and still sit in that seat for 11 hrs. Better yet,live on a rig for a couple months in each of the 4 seasons. you make the rules-live them,too.


Michael J Lovitt 12/12/2007 PUBLIC SUBMISSIONS
General Comment:
I don't mind the HOS regulations the way they are now, except for the 14 hour rule. This rule only encourages either cheating, or driving when you are tired in order to make delivery on time. If a driver gets tired, he should feel free to lay down for a nap, but with this STUPID rule, he is left to make a choice between laying down and driving past the 14 hours and hope that he doesn't get caught, or driving while he is tired.

If the driver works for a company that is checking his logs against the qualcom hourly, as mine does, you are left with only one choice...drive while you are tired. No matter how any company will preach during their saftety meetings that the load can be rescheduled if you feel that you need to take a break, in reality there will be repercussions...either you will see non-desirable dispatches until the dispatcher forgets this instance, or after you do this a couple of times, they will find another reason to let you go.

The 34 hour restart is not without flaw either. The problem with doing a restart on the road is that after you spend 34 hours trying to figure out how to keep busy and not be bored, it is more mentally taxing than if you just kept on working. If the restart could be done at home, it would be alright, but in reality, that just is not going to happen. It is better than nothing though.


Cheri Heppner - Comments 12/13/2007 PUBLIC SUBMISSIONS
General Comment:
As a driver subject to the Hours of Service rules, I strongly believe that the current system is exacerbating the problem of driver fatigue. Not allowing the fourteen hour "on duty" limit to be stopped for a break, (ie. a two hr nap), forces drivers to remain behind the wheel for the full eleven hours available. This is insanity!

Whether team or solo, a driver needs the freedom to divide the drive time into 2 segments, of 5 or 6 hours each, with a break between of at least 2 hours.

I do not enjoy driving for 10 to 11 hrs straight, nor do many drivers I know. The rule that forces us to do so was ill conceived, impractical, and contrary to it's stated objective of reducing driver fatigue. With all due respect, it's an asinine law, and needs to be rescinded as soon as possible.


E. Paul Everard - Comments 12/13/2007 PUBLIC SUBMISSIONS
General Comment:
I agree with Mr Lovitt on one point: driving 11 hours, day after day, will cause a driver fatigue. However, a great percentage of the trucks on the road are on regional routes, and many are local non-log drivers.

The one-size-fits-all mentality has created more problems for some drivers while making the highways safer for others. Many regional drivers are faced with the decision to continue driving in order to make it home where they can get restorative sleep, or stop for needed rest only to run out of hours and spend the night along the highway in circumstances that do not allow good rest.

The current HOS regulations are so rigid that a driver is forced to plan trips through congested metro areas during peak traffic. The former HOS regulation allowed more flexibility with split hours in the sleeper. This gave drivers the option of planning trips around peak traffic.

Rule makers need to adjust regulations so there is safety and profitability for everyone.


Anonymous - Comment 12/13/2007 PUBLIC SUBMISSIONS
General Comment:
I think the rules should remain as they are. I have been driving for six years and I am more rested now than under the old rules. the only thing I would change is the sleeper berth execption many drivers would like to stop for a short nap to refresh thenselfs under the current rules the only way you can is to stop for eight hours.


Michael P. Goldstein - Comments 12/13/2007 PUBLIC SUBMISSIONS
General Comment:
The only aspect of the current rule that I see which needs to be addressed at this point is the split sleeper berth provision. There needs to be more flexibility involved. If I understand the current provision correctly, sleeper berth time can only be split into two sections- one two hour section and one eight hour section. So if I am tired and I pull over and go into the sleeper berth for four hours, then drive to my scheduled rest stop and go back into the sleeper berth for an additional six hours I would be in violation of the new rules. Under the old ruling, it was acceptable to split your sleeper berth time into two parts however you felt was necessary as long as one part of it was not less than two hours long.

The new ruling is unsafe because it forces drivers to continue driving when they are tired and are unsafe to be on the road. Every one of us is different; there is no "one size fits all' when it comes to being tired and fatigued. For safety's sake, we need the flexibility back in the split sleeper berth provision.


Ginger S. Abel - Comment 12/13/2007 PUBLIC SUBMISSIONS
General Comment:
I find the current HOS regulations lacking flexibility. The 11 hours of driving and 10 hours rest is good, however the 14 hour clock makes it tough on a driver to have time to sit down for a meal, or take a short nap if a driver feels the need. We are put inside a box that doesn't take into account that different people require different sleep patterns.

I am now forced to grab my food to go, and eat it while driving down the road. There are several reasons why drivers want the split sleeper berth to come back, and not just for the team drivers, it's just as important for us solo drivers, because we have no other driver in the truck to take over if we run out of the 14 hour clock.

The 14 hour clock is another rule that does not allow a driver to drive down the road at the rate he or she feels comfortable with. We are rushed to get down the road, because we only have so much time to get it all done in, now. Drivers end up being more aggressive in their driving, because they can't be slowed up, they must go go go now.

There are several reasons why we need to get rid of the 14 hour clock, or bring back sleeper berth to stop the 14 hour clock. Here are some of them.

1. I have a headache and want to lay down for a short time to get rid of it

2. Hit rush hour and want to shut down for a spell to give traffic time to clear

3. If the roads are bad or closed because of bad weather, and I decide to sleep while they become clear

4. An accident closes the road, and a person can take a nap while waiting for them to reopen.

5. Or I just feel like breaking up my driving time, and having a rest half way through my 11 hour drive time.

There are many reasons why we need these changes, we are individuals out here and one size does not fit all. Everyone is different in their sleep patterns. No matter how hard you try to make this a 9 to 5 job, it just simply is not. There's too many variables in this industry to do that. We live in our trucks, we have a bed in the back of them, and we should be allowed to take advantage of them, when we feel the need for it.

I did quite well on the rules that were in place before this last change. We were allowed to stop the 14 hour clock with a sleeper berth break of at least 2 hours or more. It was flexible enough for me to take a break when I felt I needed one, and be safe and productive at my job.
Thank you for taking my comments in consideration,
Ginger Abel


Cam Hamilton - Comments 12/13/2007 PUBLIC SUBMISSIONS
General Comment:
The FMCSA erred in creating new Hours of Service rules by solely listening to scientists, ?public safety advocates?, and looking at studies instead of asking / listening to the persons who the rules affect. The drivers.

I am a driver will approximately one million miles of experience. As a driver, the FMCSA is going to make the changes listed below, so we, the drivers will be safer.

A majority of truck drivers are paid by the mile. Few receive compensation when they are not moving. The FMCSA has the authority to create the following rules, as they DIRECTLY affect safety.

Money = safety

The FMCSA will create a rule to require that drivers are compensated for all time spent on line four ?on duty, not driving?. (Money = safety)

The FMCSA will create a rule that requires shippers / receivers to compensate motor carriers for all time drivers spend loading and unloading, and motor carriers to pass 100% of the charge on to drivers. (Money = safety)

The FMCSA will create a rule requiring shippers / receivers to have persons available for loading / unloading and prohibit shippers / receivers from charging this cost to motor carriers and / or drivers, and prohibit drivers from loading / unloading, or assisting in loading / unloading, unless it is specifically agreed to in a written contract with shippers / receivers. If drivers are required to load or unload, or assist with loading / unloading, the motor carrier will be compensated by the shipper / receiver, and motor carriers to pass 100% of the charge on to drivers. (Money = safety)

The current Hours of Service rules have taken away the FLEXIBILITY truck drivers had in being able to get rest when they need it.

The FMCSA will make the Hours of Service to read the following:
*Keep 11 hours total driving. (Drivers do not get behind the wheel and drive for 11 continuous hours. I have never met, or heard of a driver that has driven 11 continuous hours without stopping for some reason.)

*Keep 14 hour rule, bringing back the ?stop the clock? provision, so drivers can stop and eat, take a nap, etc. Not being able to ?stop the clock? is CREATING fatigue, as drivers no longer stop to take breaks.

*Keep 10 hour rule.

*Bring back the old sleeper berth rules. Drivers are no longer able to ?stop the clock? and take a nap if they feel fatigued. The new sleeper berth rule is CREATING fatigue in both single drivers and team drivers by removing the FLEXIBILITY they once had.

*Change 34 hour restart to:
24 hour restart option when driver away from home, 48 hour restart option when driver at home.

Spending 34 continuous hours away from home in a 77? or smaller sleeper berth CREATES fatigue. 24 continuous hours away from home is plenty of time for me to get rejuvenated. Spending 34 continuous hours cooped up in my 70? sleeper berth when away from home with nothing to do CREATES fatigue, as I get bored and tired from excessive sitting around, and want to be moving, making money. (Money = safety)

These rule changes, when implemented by FMCSA, will create safer drivers, as they will give the over THREE million drivers the FLEXIBILITY each INDIVIDUAL driver needs to get rest as their body requires. They will also address the sole reason drivers break the rules as currently written. MONEY.

MONEY = SAFETY


Bobby L. Worthington 12/14/2007 PUBLIC SUBMISSIONS
General Comment:
I like 11 hours driving, with a 10 hour break, but I think the teams should be allowed to split their breaks, whether it be 5.5/5.5 or whatever. There is no way to stay in a sleeper for 10 solid hours bouncing around.

This is an edit and an addition to the above comment: An exception to the rule for teams implies that the HOS rule in dispute here is somehow more tolerable for solo drivers. This is far from true.


Tom D. Peacock - Comments 12/14/2007 PUBLIC SUBMISSIONS
General Comment:
I am a over the road semi-driver with concerns about the HOS rules. It only makes sence to allow split sleeper berth for the 10 hours off, and here is why. If a driver is going cross country and will be going through any major city during rush hour, the driver will add to traffic congestion and their will be a loss of time the driver suffers because of triffic. With split sleeper berth the driver can lay down for 2 or more hours and wait for better traffic conditions. That make the roads more safe for everyone.

I run as part of a sleeper team, and from a sleeper team point of view split sleeper allows me to drive MORE rested. I can tell you that companys don't care about the drivers all they want is their freight moved. Driving in winter conditions is very fatiguing and 10 hours behind the wheel is to much. If the driver does the rite thing and pulls off till conditions are better that driver will not have a job very long.
PLEASE make the rules for the drivers not the companies.
Thank you


Tom - Comments 12/14/2007 PUBLIC SUBMISSIONS
General Comment:
You won't be on-call forever. Companies force drivers to run 11 hours with no concideration for weather or any situations that cause stress. If drivers refuse and get rest when they need rest they won't have a job for long. The rules are fine but split sleeper has to be put back.


Mike T. Schwartz - Comments 12/17/2007 PUBLIC SUBMISSIONS
General Comment:
I would just like to say that I agree with the new HOS rules except for one thing. The sleeper birth time sould be revised to give the driver the option of being able to choose between spliting it 5hrs on lduty and 5 hrs in the sleeper or just taking the whole 10 hrs in the sleeper. This would give a great benefit not only to the Team Drivers but also the single drivers that can't sleep a straight 10 hrs in one shot. Thank you for your time and consideration in giving me the opertunity to voice not only my opinion but probably the opinion of many other drivers who don't take the time to do it.

This is an edit and addition to the above post: Five/five is great for teams. It’s the way they have done it for so many years. If the full flexibility of split bunk time is returned as it stood before October, 2005, then teams could continue to do 5/5 or similar. For solos, a mandated 5/5 is only marginally safer than 8/2. Here’s why: Many times, a driver has plenty of log book time available to complete the run and get rest. However, sleepiness shows up and a break is called for. The type of sleepiness we’re talking about here needs only an hour or two of sleep. If a driver knows that the clock only stops when five hours in the bunk has been logged, the driver will forgo that very necessary 2 hour break. This is why we need the return of the original split sleeper berth provision.


Art Pruden - Comments 12/17/2007 PUBLIC SUBMISSIONS
General Comment:
My opinion of the 11/34/14 HOS is: The 11 and 34 are both good for safety, but, the 14 hour clock rule isn't. The 14 hour clock rule pushes drivers into driving all of the 11 hours in one Duty cycle. The main thing I've seen that the 14 hour rule really interfere's with, is trying to find a place for parking at the end of the day. It's almost impossible for anyone to be able to do 10 hours in a sleeper in order to restart for the next day. I feel that the split sleeper time was more than sufficient for one to get the sleep needed to maintain a SAFE operation.


Christopher B. Bishop - Comments 12/17/2007 PUBLIC SUBMISSIONS
To whom it may concern:
General Comment:
My name is Christoper B. Bishop. I have been a commerical truck driver since August 27, 1999. I currently deliver performance fishing boats for Skeeter Products, located in Kilgore, TX. Skeeter Boats has seven company trucks with seven drivers. We work Monday through Friday. We work through Saturday morning on slight occasion. We do not pull backhauls. We leave Kilgore, TX, deliver anywhere in the 48 states, and deadhead empty, straight back to Kilgore, TX. When we are not driving, we are sleeping or unloading. There is no wait time at shippers and receivers. When we return home on Friday, we are off duty until Monday morning, anywhere from 3 a.m. to 8 a.m. On occasion, a driver may have a doctor appointment, and leave out later.

The 34 hour restart is critical for our operation. If we do not have the restart, we are unable to return home and start out the next week with a full 70 hours. We enjoy our time off on the weekends to spend with our families. All seven drivers go to church on Sundays. If the 34 hour restart is taken out of the equation, we will not have our home time on the weekends. We will be stuck out over the road somewhere while we re-gain our driving hours.

The restart is a very good thing. We do not have to falsify our log books because our company pays us well for every thing we do. If the restart were taken out, I believe drivers would falsify logbooks a lot more in order to get home or get to where ever they need to go. There is a simple solution to highway saftey, leave the 34 hour restart, cut back the driving time to 10 hours, cut the sleeper berth back to 8 hours, or leave it at 10 hours, but let us be able to split the sleeper berth into 2 consecitive hours and then 8 consecitive hours. If we could split the sleeper berth, we could take an afternoon break, stop the 14 hour clock, and still get the rest that we require.


Jr. Watts - Comments 12/17/2007 PUBLIC SUBMISSIONS
General Comment:
To Whom It May Concern.
I would like to send some comments concerning the current HOS rules. You are trying to make one set of rules apply to all segments of the industry and they just do not fit. I have been in the industry since 1966. I have been and am now a driver as well as maintence mechainc. wrecker operator, and in supervision. I have a class 8 CDL with all endorsements and a clean record. I currently haul Propane, Anhydrous Ammonia and Asphalt. All of these are HAZMAT loads. In order to keep our customers supplied with product I have to load and unload 3 or more loads a day when possible.

With the rules like they are now I am driving more fatigued than I ever have. I am not able to stop during the day to eat, shower, or take a short rest period because it will count as on duty time and cut into my productive time. Under the old original rules I could stop and take a short break to eat, shower, and maybe take a short nap and go back to driving feeling refreshed and log it as off duty. This did not count against me as it stopped the clock. The way it stands now there is no stopping the clock once you draw that first line down coming on duty. That means that you must work a 14 hour day without a break. This does not seem to have the health and safety of the driver in mind.

It seems to me that the rules as they now stand are more for the benefit of the trucking companies than they are for the driver and general motoring public. I would like to see the rules amended to allow us to take a short break or two during the 14 hours that would stop the clock and allow us to relieve some of the stress that we work under.

I would love to be able to sit at a table and eat a healthy meal rather than eat a sandwich or something of that nature while driving and to get a shower when I need it. My breaks do not always fall where I have facalities and I may have to drive for 1 to 3 hours to get somewhere where I can eat or shower. For short haul drivers who operate as I do the old rules with a 34 or 48 restart would be worth considering. Please use a little common sense when making the rules.

Listen to what the drivers tell you. We are the ones who have to work under your rules and you have no clue as to what goes on out here in the real world. I know that all of the people are highly educated, but please use common sense. From what I see I know this seemsto be in short supply these days, but there are still a few people who know what it is and how to apply it. Thank you for the opportunity to post these commentsand I do hope that you read and consider them.
Jr. Watts


Larry D. Barnes - Comments 12/17/2007 PUBLIC SUBMISSIONS
General Comment
Dear Sirs, regarding Hours of Service. My only concern is not being able to stop in the middle of the day and "get away from it all" without it affecting my 11 and 14 for that day. This is the only industry that I know of that the regulations make it more detrimental to ones health by not allowing drivers to "clock out" for an hour or two and relieve a little stress. Any health worker will tell you that getting away from the job is beneficial at relieving stress. The way things are if I am stressed out I can't get away without adding to my stress because I need those hours to complete my task. Please make it possible to stop the clock in the middle of my day.
Thanks
Larry


Paul A. Townsend - Comments 12/17/2007 PUBLIC SUBMISSIONS
General Comment:
The Hours of Service for the 11 and 34 rule I am in agreement with, however the sleeper birth provisions I am not. I think our sleeper birth provisions should be what the team or single driver can utilize safely during the day. All of our bodies are not all cookie cutter in our circadian rhythms, and what sleeper birth provisions work for one driver, will not be safe for another driver to operate under. I have been a Commercial Motor vehicle operator for over 35 years. And my sleeping habits are still only 5 hours at a time. Weather I am at home or on the road, I do not sleep more than 5 hours. With that understood the 8 hour mandatory sleeper birth time has forced me to drive tired more often than not.
I thank you for this opportunity to make our comment to this bill.
Paul A. Townsend


Michael Neal - Comments 12/17/2007 PUBLIC SUBMISSIONS
fmcsa-2004-19608
I like that the 34 hour restart are kept but being able to stop the 14 hour clock would greatly help in certain situations such as traffic accidents and rush hour. Team operations should also be able to split sleeper time. I do not know anyone who can sleep 10 hours bouncing down the road. Please reinstate the split sleeper time.


Grady M. Story, Jr. - Comments 12/18/2007 PUBLIC SUBMISSIONS
General Comment:
I think the 14 hour and 34 hour restart rule is just what the doctor ordered for our industry. The only thing that I would suggest changing is allowing the teams to split there breaks. Please strive to keep the rules as they are and make the change to the team provisions.
Thank you

This is an edit and addition to the above post: Five/five is great for teams. It’s the way they have done it for so many years. If the full flexibility of split bunk time is returned as it stood before October, 2005, then teams could continue to do 5/5 or similar. For solos, a mandated 5/5 is only marginally safer than 8/2. Here’s why: Many times, a driver has plenty of log book time available to complete the run and get rest. However, sleepiness shows up and a break is called for. The type of sleepiness we’re talking about here needs only an hour or two of sleep. If a driver knows that the clock only stops when five hours in the bunk has been logged, the driver will forgo that very necessary 2 hour break. This is why we need the return of the original split sleeper berth provision.


Matthew W. DeYoung - Comments 12/19/2007 PUBLIC SUBMISSIONS
General Comment:
I drive a truck and wanted to give you some input from my point of view. I think you should keep the 34 hour restart and the 11 hour driving rule but at the same time i think that you should really consider changing the sleeper berth rule so that we can go to sleep when we are tired. The way that it is now if we stop and o to sleep it counts against the amount of time that we able to work which i do not think is fair nor do i think that it is right. I think that we should be able to sleep when we as truck drivers are tired and it not count against the amount of time that we able to work.


Anonymous - Comments 12/19/2007 PUBLIC SUBMISSIONS
General Comment:
As a driver and owner operator for more than 20 years I feel compelled to comment on the hours of service. The 34 hour reset is a must as most anyone can be more than rested enough within this amount of time off. As to the 11 hours driving I personally do not drive more than 9 or 10. I personally would like to see the 14 hours on duty be extend by added sleeper berth time. But above all lets keep the 34 hour restart.


Rodger Harmon - Comments 12/20/2007 PUBLIC SUBMISSIONS
General Comment:
I am submitting my comments towards the current Hours of Service under review. I am a long haul driver and like the hours as they are for the most part, driving 11 hours per day with 10 hours off is fine. However if I have a longer than a day and a half to get somewhere, shipper to reciever, I would like the ability to drive for a number of hours then be able to leave the truck, take a nap or anything to break up the 11 hours available to me. As it is if I take off get tired and take a nap I lose those hours from the 11 I have to drive. I would like the ability to stop during "commute time" and start agin as traffic dies down, not losing any of my 11 hours or 14 total hrs for that day. I am all for taking tired drivers, whether it be commerical truck drivers or mom taking kids to soccer practice, off the road. Tired drivers are unsafe in any vehicle.

The 34 hour restart is a benefit as well to us to be able to keep ourselves going in a safe and legal manner. So the biggest help you as the regulating office can do for us is to give us back our split sleeper berth provision. This will make it so we do not feel as if we HAVE TO drive our 11/14 hours then shut down for our 10 hour break, I know I feel at times I am pushing myself to make it, I am legal to drive but would much rather park for a while to let traffic calm down or me to feel re-energized. I have a family that is on the road and want them as safe as possible as everyone else on the road with me or any other driver.


Bruce D. Sudman - Comments 12/20/2007 PUBLIC SUBMISSIONS
General Comment:
First of all the sleeper berth provisions are more important than the rest of this. FMCSA used the same method (not enough comment period) that the court used to throw out 11 hours and 34 hour reset.

I have met many people who routinely have driven (and continue to) what is considered to be excessive hours (11+) safely. On the other hand I seldom drive 11 hours straight, This seems to indicate to me that the single greatest impact on safety out here is knowing your personal limits and not pushing over them. I don't think any rule can dictate that. Therefore I say leave the 11 hours intact but initiate some education programs to let new drivers learn there limits etc.

the 34 hour reset, to me, is a vast improvement over "bumping up against your 70" because I believe that you can get rested and continue without all the figuring etc. to keep track of your total and take another 34 off when required.

On a final note, it is my firm persoanl belief that almost no one in this business really cares about safety because if they did the log book start of the day would have changed from midnight to 8am or even noon so that when you were "bumping up against your 70" you would be waiting until 8am to start driving again. This is of course not nearly as important now as it used to be before the 34 hour reset but if you do away with that it becomes really important again.
Thanks!


Thomas L. Rowan - Comments 12/27/2007 PUBLIC SUBMISSIONS
General Comment:
As a professional truck driver for the last 15 years, in my opinion, the current HOS regulations should stay the same with the exception of the 14 hour limit. This limit has a negative effect on drivers. If they feel they need to stop for a short nap, or would like to stop and rest to avoid traffic congestion, they feel they can't because it all counts against the 14 hour rule unless they stay in the sleeper berth for 8 hours. So they stay behind the wheel.

Imagine if the average 'John Q. Public' (non commercial driver) had to keep track of his duty status like commercial drivers, and their job needed them to start working a 7 day work week because of an increase in production was needed. All of his work time and travel time to and from work had to be accounted for. If he only put in 8 hours a day and lived more than 15 minutes away from work, then he would have to quit early on the 8 day in order to keep from exceeding 70 hours.

Think about how many more people crash their personal vehicles and lose their lives every day compared to number of commercial vehicle crashes where some one is killed.

The government's own NTSB has shown that around 70 -75% of all accidents between commercial vehicles and passenger vehicles that result in a fatality were the fault of the passenger vehicle. Based on witness accounts, crash data, and law enforcement crash investigation. In fact, since the 1st revision of the HOS 4 years ago, accident rates involving commercial vehicles has declined. And those accidents that did occur, more often weren't in the 11th hour of driving, or weren't shortly after a 34-hour restart. So changing those to provisions wouldn't have prevented these accidents.

Please keep the HOS regulations as they are. If we keep having to change our way of doing our paperwork it will only speed up the retirement of older drivers because they are frustrated with the industry as a whole. As a result newer, less experienced drivers will have to be hired. Which increases the likelihood of an increase in accidents. Not that experienced drivers don't crash, but tend to avoid situations that get them involved in accidents.
Thank you


Ted - Comments 12/27/2007 PUBLIC SUBMISSIONS
General Comment:
2 items:
1)please review and insert a rest period that will stop the clock due to the 14 hour rule. \Customers do not honor the hours of trucking due to time zones or costomers time table.

2)eobr, as stated by p.a.t.t. on wednesday Dec.19, 2007 "every other country already has it", it makes me sick to be insulted by her. I requested that it be not adopted because we are not robots. We are not out here to kill our fellow country men in 80,000lb vehicles that require us to be controled even more by computers that has no feelings of surroundings. If you must put a electronic device in our cabs due to pressure from none trucking and "safety advocates", then have us put in cameras. 3 cameras, 1 forward and 2 (right & left) looking cameras that can really help with law enforcements determination of who is at fault.


George W. Haywood - Comments 12/27/2007 PUBLIC SUBMISSIONS
General Comment:
First, I would like to take a moment to say Thank You for standing by the Truckers out here who are trying our best to keep America Movin'...by your decision in UpHolding the 11 Hour Drive Time and Our 34 Hour Restart....you as a Government Agency have Spoken on our behalf and we (as Truckers) feel that it was the correct and only Fair Action to take....

I, as well as many others in our Industry hope that you will continue to show your support and help get this Action placed into Law..so that we as Truckers may Continue to do our Jobs out here on the American Highways........

Second, The only other way that Your Agency could help to make things better for the American TruckDriver, Would be to try and configure someway for us to have more control over our Split-Sleeper Berth Provision... as it stands now... we are somewhat forced to Drive for extended periods of time whether we are Tired / Fatigued or not.....

Giving us a more "Realistic" approach to our own needs as far as "Rest" Periods, would greatly allow most of us to Stop our 14 hour clock....and not be Forced to take an 8 hour break when all we need say is a short 3 to 5 hour "CatNap"... to satisfy our own rest needs.........

Just a small thought from Truck Driver out here Trying to do his Job... To keep America A Great Nation..
Thank You
George W. Haywood


Virgil M. Tunks - Comments 12/27/2007 PUBLIC SUBMISSIONS
General Comment:
I think the 11 hr. and the 34 hr. restart are fine i think we shoud be able to break up the 14 hr. day . we shoud be able to eat and take breaks during the day without loseing time on the 14 hrs. this is all about safety. to me this unsafe to drivers that make multable delivers they are forced to eat and drink while driving because theirs not enought time in the 14 hrs. to take a break and get the job done. i've been driving trucks for a living since 1962 so I think I know what is safe and the streight 14 hrs. is'nt.
thank you


Bill Chandler - Comments 12/27/2007 PUBLIC SUBMISSIONS
General Comment:
I have been driving OTR for 33 years. I feel the HOS regs.prior to 2003 were fine and should have been left alone. A lot of time and money has been spent in a failed attempt to "improve" my life as a trucker. I have work harder now than before. If I feel tired or sleepy I have to continue to drive to get my day in before the 14 hour clock stops. A nap or rest break during the day is very refreshing and allows me to finish my day. Throw out all the nonsense and return to the original HOS regulations.
New is not always better.


Kenneth I. Wolford - Comments 12/27/2007 PUBLIC SUBMISSIONS
General Comment:
As reading thru your ruling I see you still haven't addressed the issue of the sleeper berth. Why should a driver be subject to sleeping 10 hours straight? You can do all the studies in the world, but when someone, especially a driver, is tired and needs rest he should be allowed to take it. There are times I only drive 2 hours and I am tired. When you as a person from the general public and you are on vacation, don't you find a motel room to go to or do you continue to travel and risk the lives of others? This is what you are telling a driver to do!


Robert L. - Comments 12/27/2007 PUBLIC SUBMISSIONS
General Comment:
15 years as otr driver,please stop the clock for 2 hour break. Twice in last week I had to push on to beat 14 hour clock ,when I was struggling to keep my eyes open. A two hour sleep would have been just the ticket. What part of "listen to the truckers" don't you folks understand!

P.S. A small tip! If you want to reduce accidents and deaths by 85% just ENFORCE the existing speed limits!! EVERYONE is speeding!!!! It's chaos out there.

From a 2 million mile driver.

Thanks.


Paul W. Weber - Comments 12/27/2007 PUBLIC SUBMISSIONS
General Comment:
Here We go again as of the date of this posting people are filing lawsuits to regulate something they know nothing about. If they did and where truly interested in public road safety, maybe they would look into something that seams to boggle my mind if you want to make a impact on road fatalities seams the most good could be done by going after the group that causes the majority of the accidents. The car drivers as per government stats the driver of the car is sited in better than 75% of the accidents between large trucks and auto's. now throw in the number of people that are killed each year in car on car or single Vehicle accidents. Wow what a difference you could make in the blood shed on our highways, if the number was just cut in half that would be that would a lot better if all commercial driver at faults where completely wiped out (which you are dreaming if you think it is possible there called accidents for a reason.) So lets see what we can do about stopping or at the very least drop the number of car driver at fault numbers Then perhaps we could truly get some highway safety not just a personal attacks vailed as public interest huh Jone??


Rodger Harmon - Comments 12/27/2007 PUBLIC SUBMISSIONS
General Comments:
I am a small trucking company 1 truck/trailer operation. I am submitting my comments on the Hours of Service currently under review. I am in favor a change to the current regulations and believe only one needs to be done. We need to have the ability to take a break during our day once we leave the shipper we should know what our body needs, everyone is different and does not fit into a black and white world of regulations. If I have over 1 days worth of driving to make my delivery I would like to be able to stop the truck for traffic, a nap, meals or just re-enrgize myself, but not take away from my 11 hours driving or my 14 hour total day.

The clock needs to stop for us as it does for someone working at a desk, the get several breaks off the clock per day but still have to put in their 8 hour day. Why are we not able to do this? A split sleeper berth provision would allow us to do this and feel safer, healthier and more alert to drive our 11 hours each day. I am all for staying legal to work within what regulations have been handed down to me, I feel I have to push myself at times to make my hours work, I may be legal but not comfortable. I am as concerned as anyone out here as to tired drivers be it a commercial truck driver hauling 80,000 lbs or a mom going to soccer practice with her children, either one is dangerous and can kill.

So in summing up my thoughts on our Hours Of Service I would like them to stay as they are 11 hrs driving, with a 14 total hour work day and the 34 hour reset. The best thing we could recieve back is the split sleeper berth, we would not work any additional hours in a day but be able to make what hours we have work for us an a safe manner.


ames L. Andrus - Comments 12/27/2007 PUBLIC SUBMISSIONS
General Comment:
I can see by the rules there is no one that has experience in driving that makes up the rules. I have a sister who can sleep 8 to 10 hours once in a while but I have never met any one else that would fall into that mode. If all of you sleep 10 hours a day I think it is clear why not much gets done on your watch.

That being said, Being in the sleeper for 10 hours is impossible. With all the drivers that I have seen that run sleeper only a very few that could even hope to drive 10 hours at a time. I found it really depended on how you felt. I have spilt as low as 2 to a high of 6. the average being 4 to 6 hours. to keep you both feeling alert and safe. If you have any doubt please feel free to come with me and stay in the sleeper 10 hours. and then feel rested enough to drive for 10 hours. It is so clear that this sleeper berth rule is a joke, I cannot believe sane people even came up with it. My drivers are complaining as we are auditing their logs so close to try to make sure they are keeping to the rule. I have been called names and most drivers now to not want to run team as they stay they do not feel safe. either in the sleeper or then trying to drive their 10 hours.
Thanks for the chance to leave a comment, and please feel free to call me.
Sincerely
James L Andrus


Sean P. Rooney - Comments 12/27/2007 PUBLIC SUBMISSIONS
General Comment:
Please do something to make these hours realistic for those of us who have to work by them. In my opinion, the current set up and the new proposal are a burden to drivers. They are confusing, and do not allow us to do our jobs properly, or safely. Why are we required to have 10 hours rest when most of the working public can work with 8 hours or less? By the time I have my 8 hours off, I am fresh and ready to go. The extra two hours is unnecessary, and causes me to twiddle my thumbs!

The current set up of 8/2 split sleeper berths is ridiculous, as well. It's confusing, and does nothing to help a driver. I would propose changing the 10 consecutive hours to 8, and the split sleeper berth to two periods of 5 to equal 10. Once the time off is completed, then a fresh day (14) would "restart." With the split sleeper, the first 5 hours would allow 5 more working hours, as long as they did not exceed the 11 driving. It would require having at least 5 more hours off to reset. Keep the 11 hours driving. Another possible provision would be to allow for a 1 or 2 hour break to "stop the clock" for meals.

The current law forces drivers to cram as much driving and work into a day that they can without meal breaks, or even to "stretch the legs." We're all so afraid of running into problems within the 14 hours, that we push the current law to the limits. With trying to make the roads "safer," you now have thousands of drivers with unhealthy habits of not eating, and staying sedentary for longer periods of time.

Add a provision for all drivers to have access to a 16 hour exception once a week. There are many times when we are stuck in circumstances beyond our control for well over an hour. Ask any professional driver who runs through Atlanta how often that happens.
Respectfully submitted,
Sean Rooney


Daniel J. Rosenfeld - Comments 12/27/2007 PUBLIC SUBMISSIONS
General Comment:
AS AN OLDER TRUCK DRIVER (AGE 61) I FIND THE CURRENT RULES FOR HOS TO BE PROVIDING THE BEST REST I HAVE HAD IN MANY YEARS OF PROFESSIONAL DRIVING. I WOULD, HOWEVER, LIKE TO SEE ABANDONMENT OF THE CURRENT 8/2 MANDATORY SLEEPER BIRTH RULE/


Robert Skinner - Comments 12/27/2007 PUBLIC SUBMISSIONS
General Comment:
I feel this rule is ok and workable. When you are out on the road for 3 or 4 weeks you need that 34 hr restart. It's just like having the weekend off on a regular job. But what does need changing is the 14hr rule. We as drivers need to be able to stop the clock for various reasons. If you come into a major city at rush hour you should be able to stop and let traffic die down before going thru. This will also help with congestion. You should also be able to stop and take a nap if you feel like it during the day with out it being held against the 14 hr clock. The way the rule is now we are forced to drive thru these examples by the way the 14hr clock rule is in place. Please give the driver the ability to do what is best for them and what is safe for them and the motoring public.


Laurie S. Palmer - Comments 12/27/2007 PUBLIC SUBMISSIONS
General Comment:
I am part of a team driving operation. Your 11 hour ruling is not good for a team operation. W'hile one driver is on duty;the other one wakes up before the break is over and when it comes time for him/her to drive; they are too tired. It needs to go back to 5 on and 5 off. Also, not being able to break up the sleeper berth. I know alot of drivers that will go all morning and then want to take a nap and then drive. The problem is that no driver logs legally. If they did freight would not move as quickly. No driver is going to log 6 hours on duty at a shippers dock waiting to get loaded. Your solutions is not working to solve the problems with the carriers,shippers and receivers. I dont know what the answer is. But its not working the way it is.


John E. Foy - Comments 12/27/2007 PUBLIC SUBMISSIONS
General Comment:
I as professional driver am asking that the hours of service be adjusted as far as the following. The 14hr rule needs to be adjusted to allow flexibilty to be able to take a nap if needed during the day. It also really messes schedules on overnight runs. The rest of the hours of service is fine i have no problem.


Kari Trulson - Comments 12/27/2007 PUBLIC SUBMISSIONS
General Comment:
I do not feel we need to limit the 11 hour rule or the 34 hour restart. The crash ratings have decreased since these were put into place and the agancies fighting for this have no true footings to base their opinions on. If we truly want a safer driver HOS regulations we need to reinstate the flexible sleeper berth provisions. We all know that on a long road trip we tend to pull over and move about, eat, rest, anything to avoid the road hypnosis.

By telling drivers they have 14 hours to complete their 11 hours of driving they are trying to take less breaks - especially if they are LTL drivers. The flexible SB allows a driver to take a nap or rest when their body needs it. Many drivers could perform safer if they were able to take a 2 hour SB without it adversly affecting their 14 hour day.

I run a small fleet of LTL trucks and this is the biggest complaint they have - the HOS rules do not allow for them to take a nap without being penallized. The enactment of the 34-hour restart allows an easier method for myself and my driver to watch their weekly hours. I have heard many positive comments on this rule.

I believe the drivers limitations of a 14 hour day and 11 hours of driving are fair, to make the roads even safer you should allow the driver to split the 10 hour sleeper without shortening their 14 hour day. Think logically about it; say you need to take a 625 mile trip (11 hours drive time) and make 1 stop on the way but you have to be there in 14 hours. Most people are going to want to rest for awhile inbetween. Without the split SB, the driver is expected to drive that say 7 hours to the first stop, deliver (1-2 hours) and get right back on the road for the reamining 4 hours. The current regulations on the split sleeper are hard to keep track of and do not offer the flexibility needed for a driver to decide when they need a rest.

Please, do not make the HOS regulations any stricter - there is already such a shortage of good drivers. If the smart, capable drivers can no longer earn a decent living by driving they will leave the industry. The industry will end up lowering it's standards and accepting virtually anyone and you will see a dramatic increase in fatalities. The industry needs more understanding, not more regulations. I also find it very interesting that bus drivers have less limitations than those carrying cargo, do we value the lives of the bus passengers less than the cargo?

There was a fatal crash near where I live a while ago involving a semi and a bus. The semi driver and company are being sued because the driver was falsifying his logs. I believe the driver was at fault for that - he was breaking company and federal regulations. The problem is, the 70+ year old bus driver, who was not wearing the glasses he was required to be wearing, had been up for about 24 hours at the time of the crash and that was ok by HOS regulations.

I am very curious as to what the passenger carrying rules are based on.


Alice Fairchild - Comments 12/27/2007 PUBLIC SUBMISSIONS
General Comment:
Having driven under all types of HOS rules, the 2003 rules worked just fine. Instead of screwing them over with the 2005 revision, justify the 2003 rules to thecourts and let public criminal mind their own business. The 2005 revision is actually worse for driver fatigue than the original 10 hrs driving 8 hrs off rules that I drive under now as a passenger carrier. The 03 rules were not perfect but they allowed us a great deal of flexibility to stay reasonably rested. the 05 revision does not. If you force drivers to choose between rest and income, income with usually win no matter how tired a driver is. Some days you can driver 8-11 hrs straight, some days you need a nap. the current rules force us to give up driving time (aka money) to take that nap. This is the only industry I know of where the rules are this unreasonable


Barry Zeringue - Comments 12/28/2007 PUBLIC SUBMISSIONS
General Comment:
We need to sit back an put the facts on the table.Yes we do have very unsafe drivers in our trade.We do need regulations.But why do we keep putting these rules that hurt more then help.I've been driving for 27 yrs.with no chargable accidents.Now we know it could happen tom.but i can tell you this check how many private vehicles will have a accident in the next 24hrs and fatally take someones life, to it happening to a commercial vehicles.The new rules hurt more than do good because i can no longer the breaks I'm used to taking because i need to make as many miles i can in the 11 hours i have to drive.It hurts that we have to be away from home a extra 30hrs.in 3 weeks because of the 34 restart.

Instead of making it heathier for the driver it is making it harder please help us an show the public the facts don't keep hurting us to satisfied a chosen few that will never be satisfied till they put us out of bbusiness.


Keith Jones - Comments 12/28/2007 PUBLIC SUBMISSIONS
General Comment
I understand the intention is to make the highways as safe as possible.We have a lot of people that I am sure have never driven a truck making policy that effects our livelihood. I appreciate your efforts. Please leave the 11 hour drive time and restart the way it is. With the new tractors being so much improved, I don't believe fatigue is a problem. If you want to help us, please reconsider the 2 hour break that stops the 14 hour clock. Not having the ability to stop the 14 hour clock encourages drivers to drive when they are tired.
Thank you for the opportunity to comment.


Robert E. Dillard - Comments 12/28/2007 PUBLIC SUBMISSIONS
General Comment:
I have been a driver for 42 years, and I disagree with 14 hour rule. This makes a beat the clock game out of it. The 11 hour driving time and the 34 hour restart are fine, but felt more tired by following the new rules/standards than I did by using the old rules that had been in effect since 1935. I believe that prior to setting new rules/standards for the professional driver the rule makers should have to spend a month in a truck and log their time under their rules so they can see how we have to live, because this is our profession.


Keith A. Franks - Comments 12/28/2007 PUBLIC SUBMISSIONS
General Comment:
I applaude the agency for taking the stand against the safety advocates who dont understand trucking at all. The 11 hr driving and 34 hr restart are perfect we do need to be able to have some flexibility in break times one rule will not work for everybody we all have different rest/sleep habits if we could go back to theprevious split sleeper provision life would be just great for the otr trucker


Robert Yoder - Comments 12/31/2007 PUBLIC SUBMISSIONS
General Comment:
i think that having the 14 hrs rule taken off would help me to be a safer driver on the road because i could take a nap when i am tired and it would'nt count against my driving hrs
thanks


Marvin M. Koe - Comments 12/31/2007 PUBLIC SUBMISSIONS
General Comment:
i would like to thank you for the chance to comment. i picked up a load at 3pm and had to deliver at 8am the next morn so i drove 11hrs in about 12 hrs so i arrived at 3am that morning. took my 10hrs off and at 1pm i left to go back 11hrs and since i could only sleep until 9am, about 11pm that night i got tired so i laid down for 3hrs so i could make it within my 14hrs and at 2am i got up and drove another hour. that one hour i had one heck of a time to stay awake! i asked to make the appointment at 3pm instead of 8am but the answer i got was that is when the company we haul for wants it. but if my 14hr clock would have stoped i could have got enough sleep and still made my 8am appointment time and the road would be safer. we need to be able to stop the 14hr clock when we are in the sleeper birth.

thanks alot marvin a koe


William J. Staley - Comments 01/02/2008 PUBLIC SUBMISSIONS
General Comment:
I would suggest that any period of bonified rest in excess of two hours conscetive stop the clock and as a stop gap before reaching 48 hours after 34 hour reset a continuous 10 hours must be taken and again before 48 hours after end of that. Example: start from 34 reset 6:00am monday must have 10 before 6:00 am wed. The two hours anytime but the 11& 14 still factor.

This change would solve many problems: Flexability, efficent team operations, ability to adjust schedule for entering problem areas(rushhour, ete.), credit for long waits loading or unloading, A nap as needed without penility, Less stress for driver big cause of fatiuge, ETC.


John B. Parham - Comments 01/02/2008 PUBLIC SUBMISSIONS
General Comment:
The current Hours of Operation and the new proposal are a burden to drivers. They are confusing, and interfering with our jobs and making if difficult to be safe. We are penalized by having to have 10 hours rest when most of the working public can work with 8 hours or less. 8 hours is sufficient for most and those that require more can take as required.The extra two hours is unnecessary, and causes hardships that entice professional drivers to waste time and then take risks to make up this wasted time. The current 8/2 split sleeper berths is confusing and burdensome. Changing the 10 consecutive hours to 8, and the split sleeper berth to two periods of 5 would be a step in the right direction. Another provision would be to allow for a 1 or 2 hour break to "stop the clock" for meals. This would greatly help and make drivers safer.The current law forces drivers to cram as much driving into a day that they can without meal breaks, and push the current law to the limits. With trying to make the roads "safer," you now have thousands of drivers with unhealthy habits of not eating, and staying sedentary for longer periods of time.


L. Carl - Comments 01/02/2008 PUBLIC SUBMISSIONS
General Comment:
Dear Sirs/Madam,
I keep hearing from fellow drivers that the biggest mistake you made with HOS was taking away the two hour break. It is apparent that your office does not even consider it, so I thought maybe you might be interested in this little poll that was taken on a truck driver website as to how many have fallen to sleep, or dozed on the road.
http://roundtable.truck.net/viewtopic.php?t=68955

I drove class A breifly in 2003 with the two hour break in place and never dozed off. I returned under the new hours of service without the two hour break, and have dozed twice. Luckily I caught myself in time. I have no problem with the 11/14 rule. I kind of like it, but I can't take a nap without loosing my hours, and money. YOU are putting the publics life in danger. Think about it.
Regards,
L Carl


Lloyd O. Clay - Comments 01/02/2008 PUBLIC SUBMISSIONS
General Comment:
I would like to let it be known that the hours of service are working out very well. As a driver who knows what I am talking about I have not seen at any time that I was more fatigued in the 10th to 11th hours as any other time in the day. You know I do not have to load and unload as I did 5 years ago but the guys do have to unload their trailers the fatigued does not come from driving long hours it comes from doing the receivers job.

If you want to make our roads and driverssafer than make the shippers and receivers do their job and stop putting it onthe drivers. If you go to any food warehouse the drivers are required to off load the truck by hand we are not allowed to use any motorized equipment. They have temp services that are on the dock to unload the trailer if you want to pay $80.00 to have someone on a forklift unload the trailer. If the load has to be stacked than you could be looking at up to $250.00.So the drivers end up unloading them and not getting the rest they could be getting while the truck is being unloaded.

A driver should not be allowed on the dock unless driver needs to witness the loading. now if you could get Mrs Claybrook on track and stop tell her 1/2 truths that make her side look good than you would be on your way to making our roads safe for the truck drivers.

How come no one is talking about the way the general public drives around trucks.


Robert - Comment 01/02/2008 PUBLIC SUBMISSIONS
General Comment:
Request FMCSA reconsider the interim/permanent hours of service rule to include a split sleeper berth provision. The current provision in the rule requiring 10 hours of uninterrupted off-duty/sleeper time berth creates a safety hazard for the majority of drivers and the traveling public. As illustrated in the below citation, very few people sleep 10 hours per night. The result is drivers who sleep for 7-8 hours (over 70% of the adult population) are required to stare out the front window for 2-3 hours before starting their 11 hour drive within a 14 hour period. Who is more alert a driver who has gotten 8 hours sleep and driven 11 hours or one who got 8 hours sleep, sat around for two hours, and than drove 11 hours more than 70 percent of Americans who the National Sleep Foundation estimatesget less than the generally recommended eight hours of sleep per night (.pdf).

Commercial drivers are expected to make thousands of decisions every hour while driving. Why can?t they be trusted to manage their sleep? To exemplify the complexities of driving a commercial vehicle - the military has used unmanned aircraft for decades, but despite expending billions of dollars in research and development funding to develop an unmanned ground vehicle that can operate with civilian traffic, annual DARPA competitions have yet to produce an accepted solution.

The FMCSA solution of imposing a ?one-size-fits-all? Washington DC solution based on the lowest common denominator (the 5% -10% of the population that sleeps ten hours in one sleep period) puts the other 90-95% of the drivers and the majority of the traveling public at a higher risk of accidents. Giving Drivers the opportunity to manage their sleep with an 8 hour/2 hour split sleeper berth provision will allow those who need 10 hours of uninterrupted sleep get the rest they need while also giving the majority of drivers the flexibility to sleep 8 hours and also stop for a 2 hour break later in the day.

Simply stating the FMCSA has measured a 4% decrease in the number of accidents since the introduction of the current hours of service rules, does not validate the position that ?every part of the current hours of service rules are a direct cause of accident reductions and therefore can?t be reassessed?. As stated above, operating a commercial vehicle is a complex process and accordingly the rules that govern commercial vehicle operation must be assessed and reassessed in a dynamic environment that takes into account all the independent variables.

The current Hours of Service regulations have been a 'goldmine' for trial lawyers because they use a one-size-fits-all approach that doesn't accurately reflect the sleep patterns of almost all drivers. Reflecting on Dr. Deming's "Total Quality Management", if a process is not working the way it was intended, it is likely the processes fault not the fault of the people who work within the process. Measure the amount of lawsuits trial lawyers are filing against commercial drivers for Hours of Service violations. The lawsuits don?t prove the drivers were tired but rather that they violated a rule. A split sleeper berth provision would alleviate a lot of the lawsuit nonsense, increase safety, and help with retention of drivers. After all, how many of the people reading this would want someone telling them they have to sit and stare at their computer screen for two hours everyday before they can turn it on?


Jay C. Fanning - Comment 01/02/2008 PUBLIC SUBMISSIONS
General Topics:
The Hours of Service (HOS) rules need a provision which stops the clock when a driver needs to take a rest break during the on-duty period. The 34 hour restart is successful for drivers who can take the time off to reset the HOS clock. Team operations need to be able to split driving time to accomodate 5 hours driving, and 5 hours sleeper. The current format is unacceptable for team operations. There is also harm when a truck is stopped for inspection, and team driver who is in sleeper berth is called out during the inspection, breaking the sleeper berth period, and affecting the change of duty status to on-duty. The 11 hours driving is acceptable to me, and 14 hours on-duty is acceptable.

It would be nice if those that write the regulations had spent time as a professional driver, where they could understand the reality of trucking, and remember that an overwhelming majority (75%) of truck crashes are the fault of the other driver. No two individuals function the same, and trying to one size fits all approach will never work. Drivers should be allowed to operate until they are bordering fatigue, get rest, and proceed safely down the road. An enforcement officer should be able to determine when a driver's actions define fatigue.

There are safety organizations that will continue to pound against the HOS, regardless of the rule. Many of them have lost a loved one in accidents, but, have no true grasp of trucking, the demands of shippers, receivers, and carriers towards driver performance of duties. The FMCSA should be willing to support drivers who run within the HOS, and not be harrassed or intimidated by shippers, receivers, carriers, and law enforcement agencies who force/threaten a driver to violate HOS against his/her will. While we would like to see a resolution to HOS quickly, I would have regulators or writers of the HOS get in a truck and spend time working as driver/observer of the real world.
Jay C. Fanning
oktrucker@oktrucker.com


Stanford G. Collins, Jr. 01/02/2008 PUBLIC SUBMISSIONS
General Comment:
Before the 14 hour rule I enjoyed a ride each day as a truck driver.
Before the 14 hour rule I never drove thru a major city during rush hour, found it safer and less stressful to take a map till traffic eased off. Before the 14 hour rule I found time to stop for a meal, showers, and walks to stay inshape. I drove for eight and a half hours a day, about 550 miles. Now the trucking companies what 650 miles a day , Why ? You gave them 11 hrs driving time. Most all drivers out there are driving to beat that clock. This rush is going to present its self by the way of higher accident rates and more hiway deaths. An if the accidents don't get us, the damm 14hr days will. With the 14 hour rule I now have to race the clock every minute of the day. I miss showers, skip meals, never get to walk for my health. And most of all I 'm stressed out,tired, and not sleeping very well, I've gained 180 lbs sence 2000 and I want to know what in hell is so healthly about the new hours of service. And what is so safe about the new hours.


James E. Smith - Comments 01/02/2008 PUBLIC SUBMISSIONS
General Comment:
The only part of the hours of service that can are a problem is not to slip the time up in the bunk, like in the old rules. since the current hos come into affect a lot of team operations have quit working as team operations an gone to solo operations, an have added more trucks to the road systems causing more conjeston.


Curtis W. Swanson - Comment 01/02/2008 PUBLIC SUBMISSIONS
General Comment:
It is good for the trucking industry that the 11 Hour Driving Rule and The 34 Hour Restart rules were kept in place. The 34 Hour Restart is very adequate time for a driver to get rested and be fresh to another work cycle.

However the problem is with the 14 Hour Rule currently in place. This does not give any flexibility to take rest or meal breaks, etc. without penalizing the driver because of limited work time. The HOS regulations were originally designed to make sure drivers had proper rest to protect them and the motoring public. With the current rules a driver is pushed in order to maintain a level of productivity.
The flexibility of splitting rest periods needs to be reintroduced.


Kenneth W. Sellers - Comment 01/02/2008 PUBLIC SUBMISSIONS
General Comment:
I HAVE BEEN OUT HERE FOR 14 YEARS. DUE TO DIFFERENCE IN BUSINESSES, DIFFERENT TIME ZONES, ETC I feel that the split-sleeper berth should be brought back Used to I would pull over sleep for 3-4 hours or more then continue on Under the 14 hr rule it makes me drive while i need to be in bed asleep. the 34 hr restart gives plenty of time to recouperate since under the 70 in 8 days only gives drivers 8 hrs 45 mins per day for all work related activities which no matter how you slice it you can not drive the allotted time the FMCSA and DOT gives us


Tom Hassler - Comment 01/02/2008 PUBLIC SUBMISSIONS
General Comment:
I have 28 years over the road trucking experience, please make our roads a little safer by returning to the 10 hour driving rule, and being able to log off duty for naps and breaks and not the 14 hour rule that is pressing drivers to drive unsafe. Truckers realize republicans are not for the working man so democrats are gaining thousands of votes from this hours of service circus.


Phillip S. Stodgell - Comment 01/02/2008 PUBLIC SUBMISSIONS
General Comment:
I m submitting this opinion on the hours of serviceproposals or changes. Im in favor of the eleven hour rule and the 34 hoour restart.they work well for me. The 14hour rule is something else. it doesnt allow for enough flexibility. youare generally pushed for adiquate time to do your prescribed work.if you become tired you are not allotted any time to take a break because if you do you run up on your 14 hour clock,so instead of taking a short rest stop or nap you continue on working tired,just the oppisite of what these rules are trying to negate. more people are apt to be working when their tired because they cannot take a rest break. if you do take a break, you are then tempted to falsify your logs to fall under the 14 hour rule.

Also; I believe the dropping of the split sleeper berth was also a big safety mistake every ones sleep habbitsare not the same and by you saying so doesnt make it so. if you follow the rules like you want,you either get nowherewhen rulnning a team operation or you have to improvise on filling out your logs. for most people sleeping 8 10 hours in a maving truck is simply not feasible, their are far to many interuptions and you spent half or maor of your sleeper time awake, then your expected to get up and drive your 8 10 hours. Idrove for26 years under the ond split sleeper system but was not able to function under the new system, I was fortunate to be able to switch running single on a ltl operation,but still run in to some problems because time is not alloted for naps without exceeding the 14 hr. rule.

You may think the new rules are working but i suspect this is on paper only


Danny T. Autrey - Comment 01/02/2008 PUBLIC SUBMISSIONS
General Comment:
I WOULD LIKE TO SEE THE H O S STAY AS THEY ARE. HOWEVER IT WOULD BE NICE TO TAKE A COUPLE HOUR NAP DURING THE DAY AND STOP THE 14 HR CLOCK . THE 34 HR RESTART SHOULD ALSO BE LEFT AS IS. AFTER 2 SLEEP CYCLES MY BODY IS FINE. DRIVING 11 HOURS A DAY IS NOT AS BAD ON MY BODY AS PEOPLE WORKING DOUBLE SHIFTS AND DRIVING 20 OR 30 MILES HOME AND BE BACK TO WORK IN 8 HOURS.

THANKS

DANNY AUTREY


Larry Willhite - comments 01/03/2008 PUBLIC SUBMISSIONS
General Comment:
I feal the 11 hour driving and the 34 hour restart is good. All though it would be nice to have a split sleeper berth so a person would have a chance to pull over take a nap and not have it count against the 14 hours.


Bruce D. Sudman - Comments 01/07/2008 PUBLIC SUBMISSIONS
General Comment:
This is my second time to comment and I very carefully followed the comment instructions but it did not show up.

First of all, sleeper birth, it is absolutely crazy to have to give up your driving time if you opt to stop and take a nap to be safe. Please repair this!!

I feel that most of us do not drive 11 hours on a regular basis and that the extra hour mainly allows you to drive 10 and start finding a place to stop without going over your hours because there were no parking spots in the place you had planned to stop.

The 34 hour restart mainly allows me to not worry as much about going over 70 when I am out for only 5 or 6 days. It takes a lot of the paperwork time away in making sure you stay compliant.

In regard to safety in general it is my feeling that if ya'll and/or companies really were interested in safety you would have figured out many years ago that it was anti safety to have someone running out of hours at say 10AM and then sit around waiting till midnight to get hours back and start driving again. This of course was more of a problem under the old HOS.


Melvin C. Rexwinkle - Comments 01/07/2008 PUBLIC SUBMISSIONS
General Comment:
In my opinion, to drive for 11 hours without a break is not in the best interest of the drivers. At least a one hour break after 6 hours should be required. All of the doctors tell the drivers to eat several meals per day, and especially not a large meal before going to sleep. the current hours of service prevent this from happening. the current hours of service are not in the best interest of the drivers health. I suggest a 15 hour work day with 11 hours total driving, with a one hour break after no more than 6 hours driving, and a 9 hour sleeper berth period. The sleeper berth time could be split with a minimum of 7 hours in the sleeper and a 2 hour break that could be any combination of sleeper or off duty.


Howard K. Rosvall - Comments 01/07/2008 PUBLIC SUBMISSIONS
General Comment:
I've driven trucks for 20 years, with over 2 million miles and zero accidents. I've worked with both the new and old HOS rules. The 11/14 and 34 hr restart has worked well for me, except there should have been a way to stop the clock for teams and time spent in the sleeper berth.

Many times at docks I and other drivers can sleep while loading and unloading, because we no longer are required to spend that time on the docks because of agreements with shippers and receivers.

The main thing that has allowed me to not be in an accident the last 20 yrs is if I feel the need to stop and take a nap I do. Thats why we should be able to stop the clock, No one should be required to drive 11 hrs straight without a break, No one should have to spend hours upon hours at a dock while they are not on duty and are in the sleeper and still have it go against the 14 hrs clock.


Anonymous - Comments 01/07/2008 PUBLIC SUBMISSIONS
General Comment:
The current rule that is in place works well for most otr drivers. We still need to be able to stop the 14 hr. clock when we go into the sleeper. Due to changing weather cond. and climates sometimes it is very hard to drive 11 hrs without a break, but do to the current rules we are sometimes forced to continue on while we are tired. So far their is no decrease in safety due to this rule. Teams should be able to split their sleeper birth option as it is very hard to sleep 10 hrs at a time in a moving vehicle with rough roads (I drove team for 1 year). The 34 hr restart is an excellent idea. Local divers and regional drivers need a separate set of rules for driving since most of their time is city driving or long hrs. sitting in front of a dock making a delivery. Overall the current rule is working well, but their is not a one size fits all rule. My recommendation is keep the current set of rules to limit any more confusion. Thank You for your time.


Marvin B. Rogers - Comments 01/07/2008 PUBLIC SUBMISSIONS
General Comment:
I've been driving 10 years. I like the 34 hour restart, but sorely miss the split sleeper berth. These new rules make me drive when I'm tired and shouldn't be driving, if I've been up all day on my own time and have to pick up late at night and deliver the next day, I'm forced to drive all night to get there. Under the split sleeper berth I could get some quality sleep and get up and drive again. The two hours allowed are not enough for me to get rested. I would like to see a two line log, on duty and off duty, 14 hours on duty and 10 hours off duty, do what you need to do for the 14 hours on duty. Driving is the easy part of our job nowdays, these rules date back to the 30's and don't allow for the comfort of the trucks on the road today. We are regulated by the hour and paid by the mile, if we were paid by the hour it would solve alot of the problems and delays created by shippers and recievers.


Donald A. Butler - Comments 01/08/2008 PUBLIC SUBMISSIONS
General Comment:
I have been trucking since 1973 and there was nothing wrong with the old hours of services

when you changed them and stop the split sleeper you made things wrose not better. Also people are making changes to rules that have no clue as to what they are doing. Get some one that has back ground in the business. Put the split sleeper back in leave the 34hour restart.


Robert O. Cain - Comments 01/08/2008 PUBLIC SUBMISSIONS
General Comment:
the 14 hour rule makes drivers chose rest when thay need it or driving there are time when im driving that i would like to stop and rest but i dont becouse i dont know what mite happen latter in the day that will slow me down if i take a nape for 3 hours that leaves 11hours to do all i have to do fuel load unload ect. and then if i run into bad weather or traffice that all gose ageins my 14 hour so here it is i take a 3hour nape it take 30min to pretrip my truck a hour to load 30 min for fuel hit bad traffic for a hour and a half now if you add all that up thats thats 5.5 hours which i dont get paid for sure the traffice is something we cant do anything about but that other stuff should not count toward the 14 hours im not getting paid

thank you ROBERT O. CAIN


Timothy R. Fisk - Comments 01/09/2008 PUBLIC SUBMISSIONS
General Comment:

Sirs,
I am commenting on Docket# FMCSA-2004-19608. I feel that the hours of service are fine the way that they are now with the 11 hours of driving and the 34 hour restart. I am company driver for Wal-Mart Transportation, and very seldom go past the 9 hours of driving and use 12 to 12.5 hours of my 14 hour daily clock. Where I feel that the HOS needs to be fixed is that I am not being penalized on my 14 hour clock if I need to stop to get a short nap or stop to get something to eat. Also I feel that there needs to be something added to help team drivers to better utilize their hours so that they are not having to stop to pick up hours that they can drive. I thank you for taking this time for letting me give comments on this very important issue. Sincerly

Timothy R. Fisk


William W. Hitt - Comments 01/09/2008 PUBLIC SUBMISSIONS
General Comment:
I would like to see a return to a variation of the old hours of service because if you needed to take a break or take time off in the middle of the day, you weren't penalized. Under these new hours or service, if you need to take a nap in the middle of the day, you eat into the available hours that you have to drive. Other professions have the ability to take time off during the course of the workday and then return to work to finish out their day.

I believe the old rules of service were safer for the driver, especially team drivers, because they had the ability to stop and take a break in the middle of their work day, or had the ability to split their sleeper berth time. The new hours force a driver to continue to drive and/or work because any time that is taken off is counted against their available work/drive time because their 14 hour clock runs out

.

I do agree that drivers need a period of rest that exceeds four hours, but most people do not sleep for 10 hours at a time and to force the driver to do that is unnatural.

A rule needs to be established that takes into account the different needs of the city driver, the team driver and the over the road solo driver, all in one easy rule.


Lily Y. Williams - Comments 01/10/2008 PUBLIC SUBMISSIONS
General Comment:
We should keep both the 11 hour rule and the 34 hour restart. Statistics have shown that since these two rules were implemented incidents of accidents involving commercial vehicles have dramatically decreased. But I think that we should also re-introduce the split sleeper birth as well.

Professional drivers are not paid for all the hours they actually work. We are detained for long periods of time by both the shippers and the receivers. We cannot look for relief from the companies that we are leased on to or are employed by as they are deeply involved in competititon with each other in order to get the shipper/receiver in the first place. I believe that we all know that it would be cost prohibitive for us to fall under the juridiction of the DOL.

Allowing us to split our sleeper birth times takes all of this into consideration by allowing us to get additional needed rest while at the same not penalizing us for being safe drivers.


Frederick G. Murray - Comments 01/10/2008 PUBLIC SUBMISSIONS
General Comment:
We should keep the 11 hour rule and 34 hour restart just as they are. These rules allow me to be more productive in a safe manner. The split sleeper rule needs tweaking though. That rule should be put back to the way it was under the old rule with the provision of any of the sleeper periods stopping the 14 hour clock. This change will allow drivers the ability to rest when needed and reduce fatigue.

Many drivers, myself included, were able to use these periods to rest and avoid rush hours in many major cities, thus making the highways safer by having fewer big rigs in the traffic flow at times of greatest congestion and having better rested drivers on the road.


Frederick G. Murray - Comments 01/10/2008 PUBLIC SUBMISSIONS
General Comment:
I believe we should keep the rules as they are now with the following exceptions:

1) The split sleeper provision should be reinstated as they were in the old rule. This will allow team drivers the ability to adjust their schedules to get the BEST rest possible (ie. resting when tired, not when wide awake because someone says that they have to.).

2) The 14 hour clock should stop when split sleeper provision is being used. This would allow ALL drivers to rest when necessary, not just when mandated, and not loose any productivity time. Another added benefit: Drivers like myself used to be able to take a restful 2 - 3 hour nap when approaching a major city at rush hour, thus avoiding these cities at that time of day. This has the duel effect of a decrease in driver fatigue and fewer trucks in rush hour traffic, both making the highways SAFER!!

Lastly, to those who think the 11 hour rule allows drivers to drive 77 hours per week, you obviously do not understand how the 70 hour rule works. That makes me wonder if you really know what you are commenting on or understand trucking at all!


Ronnie J. Terry - Comments 01/15/2008 PUBLIC SUBMISSIONS
General Comment:
I-am-disapointed-that-provision-for-driver's-rest-period-was-removed,and-being- rested-is-now-held-against-the-driver-(or-at-least-it-takes-away-work-time),but- since-I-don't-expect-to-ever-get-that-back,I-must-give-up!

But;
On-the-11hour-driving-time-and-the-34hour-restart,I-humbly-ask-that-they-be- allowed-to-be-continued,as-we-now-have-them.

As-an-Owner-Operator-I-do-not-like-not-being-allowed-to-stop-and-rest-without- being-penalized,but-nobody-has-addressed-that-issue-since-the-beginning-of-the- discussion.


Rick B. Brewer - Comments 01/15/2008 PUBLIC SUBMISSIONS
General Comment:
Please consider changing the "14-Hour Rule" This rule should allow a driver to "Stop The Clock" when ever he/she enters the sleeper berth. Please see attachment..Best Regards, Rick Brewer

January 14, 2008

Docket #FMCSA-2004-19608
Docket Management Facility
U.S. Department of Transportation
Room W12-140
1200 New Jersey Avenue, S.E.
Washington, DC 20590-0001

Re: Hours of Service of Drivers: Interim Final Rule

Dear Sir/Madam:

R.B.Transport Inc. of Statesville,N.C. supports the Federal Motor Carrier Safety Administration's (FMCSA) December 17, 2007 Interim Final Rule on Hours of Service of Drivers (HOS). We urge FMCSA to retain the 11 hour driving limit and 34 hour restart provisions as published in the Federal Register notice. Our company's experience with these HOS regulations has shown that the rules promote driver safety, alertness and performance better than the old rules.

We are located in Statesville,N.C. and most of our trips are within a 10-11 hour time period to the final destination. We have adapted our schedules to the new rulings but have a problem with the 14 hour rule. This rule should be altered to allow a driver to go into the sleeper for a minimum of 2-hours and this time would "STOP" the 14 hour clock. The current rule does not allow a driver who is tired to stop and rest for fear that the "14 Hour" rule will cause him to run out of time before reaching his/her destination. We strongly feel that any time a driver enters the sleeper berth, that his time stops and begins again when he again gets behind the wheel. PLEASE, look at this rule and realise how "unsafe" this really is. We feel this "14-Hour" rule could be improved upon to enhance the safety of drivers and the motoring public.

The 11 hour driving limit has been beneficial. This provision provides important flexibility for drivers to manage their schedules, particularly in times of unexpected delays due to traffic congestion, incidents, weather, etc., and has had helped in scheduling matters related to our customers.

The pro-safety aspects of the 34 recovery and restart provision are real and it has enhanced the quality of life for our drivers. It is an essential part of the rules that allows our drivers to obtain an extended period for rest and recovery.

Our company's safety experience operating under the new HOS rules parallels the industry's improving safety experience since 2004. The new HOS rules have resulted in improvement in driver health, truck safety and overall highway safety. FMCSA must preserve the rules, including the 11 hour driving and 34 hour restart provisions, to continue the safety gains achieved by our company and the trucking industry and also look at changing the "14-Hour" rule for added safety.

Thank you for the opportunity to comment on this important issue.

Sincerely,
Rick Brewer President


Anonymous - Comments 01/15/2008 PUBLIC SUBMISSIONS
General Comment:
34 hr Restart is great, the 11 hrs of driving and 10 hrs off is good, but the 14 hr rule really hurts the regional driver that wants to be home more often.


Maverick - Comments 01/15/2008 PUBLIC SUBMISSIONS
General Comment:
I think the 11 hours driving is good> I don't us it that much but its nice! I love the 34 hour restart. But I think if use the split sleeper berth the 2 hours should also stop the 14 hour clock>


John A. Faust - Comments 01/15/2008 PUBLIC SUBMISSIONS
General Comment:
In regard to your hours of service, I like it all except for the 11 hrs of driving in which you don't allow for a break for team drivers,in fact all drivers should be allowed to take a break without penalty of lossing driving time. Now if we had all shippers and recivers on the drivers schedule we would not have to worry about our time as we would be able drive in a legal matter. Most drivers try to do it legally but its really hard to do with JIT freight.


Donald Ziegler - Comments 01/23/2008 PUBLIC SUBMISSIONS
General Comment:I THINK THAT THE HOURS THAT WE HAVE RIGHT NOW ARE GOOD FOR THE TIMES , I THINK THE DRIVERS SHOULD SPLIT THE SLEEPER BERTH UP SO THEY CAN GET THE SLEEP THAT THEY NEED WHEN OUT ON THE ROAD. THE FMCSA SHOULD LOOK AT ALL DRIVERS, CAR DRIVER SHOULD BE EDUCATED ON THINGS NOT TO DO AROUND A BIG TRUCK. LIKE UNSAFE LANE CHANGING, TAILGAITING, NOT PAYING ATTENTION TO THE ROAD. CAR DRIVERS CAN WORK 8 HOURS A DAY AND WHEN THEY GET OFF THEY CAN GET INTO THEIR CARS AND DRIVE ANY WHERE THEY WANT AND ANYTIME. IF THEY GET INTO AN ACCIDENT WITH A BIG TRUCK, THE DRIVER OF THE TRUCK WOULD BE BLAMED FOR THE ACCIDENT EVEN IF HE WAS DRIVING LEGAL AT THE TIME OF THE ACCIDENT. EVEN IF THE CAR DRIVER WAS A FAULT FOR THE ACCIDENT. I THINK YOUR DATA END YOUR IFR SHOWS THAT THE TRUCK DRIVER GETS MORE SLEEP AND OFF TIME THAN THE CAR DRIVER. I ALSO THINK THAT THE TRUCK DRIVER SHOULD HAVE 34 HOUR RESTART. I HAVE BEEN DRIVING A TRUCK FOR 13 YEARS AND I KNOW WHAT GOES ON OUT HERE ON THE ROAD AND ALOT OF PEOPLE IN WASHINGTON HAS NOT IDEA WHAT GOES ON OUT HERE ON THE ROAD!!!!!!!!!!!!!!!!!!!!!

DONALD ZIEGLER


James W. Reynolds, III - Comments 01/23/2008 PUBLIC SUBMISSIONS
General Comment:
As an OTR driver for 12 years, I have driven under the old rules and the new rules. Under the old rules, I was able to take breaks as needed for rest and rejuvination which stopped the work clock. This was wonderful, and I felt much more relaxed in my work life than I do now having to contend with the 14 hour clock. Under the new rules I feel much more stress to get the driving and work done as fast as possible in order to make the most income I can in the 14 hrs allowed each day. This stress is unhealthy for the truck driver and unsafe for the motoring public.

The 34 hour restart provision is good, but it would be totally unnecessary if we didn't have to contend with the 60 and 70 hour rules. Many workers (not subject to the DOT regulations) are allowed, required or encouraged to work 80 hours per 7 day week, but no-one seems to be concerned about the negative impact that it may have on the worker or the motoring public. I don't believe that the number of hours worked per week by a DOT subjected driver should be regulated as long as the driver gets an 8 hour break between each work/driving day and 2 additional hours of rest during the work/driving period. Forget about this 14 hour clock that can't be stopped. It is counter-productive.


Gery L. Nelson - Comments 01/23/2008 PUBLIC SUBMISSIONS
General Comment:
DEAR FMCSA, FAILURE TO ALLOW SPLIT SLEEPER BERTH MANDATES THAT THE DRIVER CONTINUE WHETHER DROWSY OR NOT. THE 14 CONTINOUS HOURS RULE IS CONTRARY TO SPLIT SLEEPER BERTH RULES FROM PAST YEARS. THERE IS NOT ONE SHRED OF EVIDENCE THAT SUPPORTS TERMINATION OF THAT RULE. IN 41 YEARS, I HAVE USED THAT AFTERNOON NAP TO TERMINATE MY DROWSY CONDITIONS. THE 34HR RESTART IS GREAT. AFTER I REACH MY WEST COAST DESTINATION, I ENJOY A COUPLE DAYS OFF. AFTER THAT, I START TO TIRE, NOT REJUVINATE. CARRIERS HAVE REDUCED RATES BELOW THE COST OF OPERATIONS FOR THE OWNER OPERATOR. ANOTHER STRESS FOR THE DRIVER TO DEAL WITH. COME GO WITH ME, EXPERIENCE THIS FOR YOURSELF, THEN YOU'LL HAVE REAL FACTS TO LEGISLATE FROM, NOT JUST THE "STUDY, RESEARCH, SOMEONE TOLD ME". WITH ALL DUE RESPECT, NO ONE IN DC HAS ANY IDEA OF THE REAL WORLD OUT HERE.


Betty Beaudoin 01/25/2008 PUBLIC SUBMISSIONS
General Comment:
i like what we have if we could split our driving up a bit. that would sure help even more. we drive team and 11 hrs in the bunk is way to long. by the time i'm ready to drive it is time for a nap. the rough roads dont help also. I could be sound asleep till we hit a section of roads that will get me right out of bed. and say jiminy christmas i know where we r. now i'm awake cant fall back to sleep. i like the 34 hr restart that is the best thing anyone could have done. go home get somekind of rest not much but some. at least it works with and excuse with the dispatcher. almost out of hrs!!! got to go home. have a real hard time driving that 11 hrs always taking a 15 min break every 4 or so hrs. for a cup of coffee. and take the dog out. got to stretch a bit. to keep alurt. i have never yet made 8 hrs driving time always having to quit. but then we have to sit for about 2 hrs other half cant drive yet. more time loss. always late to deliver. cant seem to keep moving. for 10yrs before the new regulations came out we use to do the 5 hrs on and 5 hrs off some times 5-6 hrs rules just depends how we feel. we always agreed no driving when tired if we can swap great if both r tired we park. that worked out well. now it sucks. have to drive tired not good. there is always someone especially the local driver is taking a nap cant miss that on the side of a ramp or rest area sleeping at the wheel. if they get tired and take a nap how do they log it not sure. but i know that is pentilzing us to take a nap. again i like what we have if we can just split our sleeper time that would really help so very much. then we would not have to drive in the rush hr traffic like atlanta, st louis or indy etc. somepeople would like to park it for a bit when the rush is calm down, then we can finish what we r doing. waste to much time going 10 to 15 mph down the road bumper to bumper. it would be great if we could park then go.


Larry W. Harlow - Comments 01/25/2008 PUBLIC SUBMISSIONS
General Comment:
AS A TRUCKER I SEE THE RULES OF THE 14 HOURS NOT BEING ABLE TO STOP BY GOING TO LINE 2 FOR A FEW HOURS WITHOUT STOPPING THE 14 HOUR CLOCK HARMFUL TO BOTH THE TRUCKER AND THE LITTLE GUYS. NO TWO PEOPLE ARE ALIKE IN THEIR REST/ACTIVITY CYCLES. SOME NEED LESS AND SOME NEED MORE REST. NOW HERE'S MY POINT. A SURGEON CAN OPERATE AFTER A 24 HOUR AWAKE PERIOD. A POLICE OFFICER CAN STAY AWAKE ALLL HOURS AND BE DEEMED FIT TO CARRY AND USE A WEAPON. FOLKS CAN WORK 8-16 HOURS A DAY THEN ARE CONSIDERED SAFE TO DRIVE, YET ONLY A TRUCKER IS DEEMED UNSAFE AFTER THE 14TH HOUR OR THE 11TH HOUR. IF WE TRUCKERS WERE AFFORDED THAT TIME INSIDE THE 14 TO COP A NAP WITHOUT IT EATING OUR HOURS UP THINGS WOULD GO MUCH SMOOTHER ON OURSELVES.


David B. Reed - Comments 01/30/2008 PUBLIC SUBMISSIONS
General Comment:In that a more articulate owner/operator has addressed this issue better than I, I will echo his comments by re-posting his remarks. They are as follows;

The HOS rule disallowing clock stops for naps could stand some sober reconsideration.

HOS rules are deadly if they require a driver to stay on the road when sleepy in order for him or her to meet a delivery requirement.

Disallowing split sleeper berth time and clock stops for naps also encourages driving at maximum speeds. Please consider the following:

If a driver realizes he might not arrive at his delivery destination soon enough to complete a full eight hour clock stopping rest period, he will also be aware of the following consequences:

Although he may get 6 or 7 or even 7 1/2 hours of good, restful sleep before he must sign in at a receiving office, it is worthless, HOS-wise. If he gets several additional hours of sleep while being unloaded, that also is worthless. He will not be legal to take another load until it's too late in the day. He will lose a day's work and be forced to spend another entire day and night in a parked truck, even though he's well rested. The scenario is highly stressful. It is not good for the health. I know because I have lived with it since October, 2005. Nobody, especially an over the road trucker, has enough time in their lives where they can afford to ignore 6 or 7 hours of their time, as if it were worthless, several times a week.

Considering the above, which represents real life trucking under real life conditions, the present HOS rule disallowing split sleeper berth time and clock stopping for naps often places drivers in circumstances where they feel compelled to drive when sleepy (at maximum speed) and park their trucks when they're rested and should be driving.

Furthermore, since October, 2005, drivers often feel compelled to drive through rush hour traffic in population centers instead of taking a rest break and passing through at a more efficient hour. Why? Because their rest break wouldn't stop the clock and they'd not be able to meet a delivery requirement. Real life trucking? If you can't meet delivery requirements, you're out, quickly!

It's easy to suggest that we should all have eight uninterrupted hours of sleep each day, but how many Americans really need it, or get it? Legislating such a requirement for truckers unintentionally leads to the above mentioned stressful and potentially dangerous consequences.

It is highly speculative that legislating eight uninterrupted hours of sleep improves highway safety or driver health in light of the above mentioned consequences of an HOS rule.

Drivers who wish to keep honest and legal logbooks presently have every incentive to arrive at their destination at least 8 hours, not 7 1/2 or 7 3/4 hours before a hard and fast appointment time.

Who would like to share in the responsibility for a lost life where an otherwise responsible trucker pushed the envelope in order to gain the time needed to meet an HOS requirement?

A regulation asserting that eight hours of sleep is safe, while almost eight hours followed by another two or more hours is unsafe, or is unhealthy, is a regulation worthy of further consideration.

A regulatory posture inadvertently ignoring the danger of encouraging maximum speed and the danger of driving while sleepy, is one that needs to be amended.


Dina Z. Rips - Comments 01/30/2008 PUBLIC SUBMISSIONS
General Comment:
The HOS rule disallowing clock stops for naps could stand some sober reconsideration.

HOS rules are deadly if they require a driver to stay on the road when sleepy in order for him or her to meet a delivery requirement.

Disallowing split sleeper berth time and clock stops for naps also encourages driving at maximum speeds.

And no matter what's the rules, or enforcement are, it's still going to be a very dangerous situation! There is nothing about safety in this provision! Please make it reasonable, and you'll save lives!

Thanks for listening!


Robert V. Harsell - Comments 01/30/2008 PUBLIC SUBMISSIONS
General Comment:
The HOS rule disallowing clock stops for naps could stand some sober reconsideration.

HOS rules are deadly if they require a driver to stay on the road when sleepy in order for him or her to meet a delivery requirement.

Disallowing split sleeper berth time and clock stops for naps also encourages driving at maximum speeds. Please consider the following:

If a driver realizes he might not arrive at his delivery destination soon enough to complete a full eight hour clock stopping rest period, he will also be aware of the following consequences:

Although he may get 6 or 7 or even 7 1/2 hours of good, restful sleep before he must sign in at a receiving office, it is worthless, HOS-wise. If he gets several additional hours of sleep while being unloaded, that also is worthless. He will not be legal to take another load until it's too late in the day. He will lose a day's work and be forced to spend another entire day and night in a parked truck, even though he's well rested. The scenario is highly stressful. It is not good for the health. I know because I have lived with it since October, 2005. Nobody, especially an over the road trucker, has enough time in their lives where they can afford to ignore 6 or 7 hours of their time, as if it were worthless, several times a week.

Considering the above, which represents real life trucking under real life conditions, the present HOS rule disallowing split sleeper berth time and clock stopping for naps often places drivers in circumstances where they feel compelled to drive when sleepy (at maximum speed) and park their trucks when they're rested and should be driving.

Furthermore, since October, 2005, drivers often feel compelled to drive through rush hour traffic in population centers instead of taking a rest break and passing through at a more efficient hour. Why? Because their rest break wouldn't stop the clock and they'd not be able to meet a delivery requirement. Real life trucking? If you can't meet delivery requirements, you're out, quickly!

It's easy to suggest that we should all have eight uninterrupted hours of sleep each day, but how many Americans really need it, or get it? Legislating such a requirement for truckers unintentionally leads to the above mentioned stressful and potentially dangerous consequences.

It is highly speculative that legislating eight uninterrupted hours of sleep improves highway safety or driver health in light of the above mentioned consequences of an HOS rule.

Drivers who wish to keep honest and legal logbooks presently have every incentive to arrive at their destination at least 8 hours, not 7 1/2 or 7 3/4 hours before a hard and fast appointment time.

Who would like to share in the responsibility for a lost life where an otherwise responsible trucker pushed the envelope in order to gain the time needed to meet an HOS requirement?

A regulation asserting that eight hours of sleep is safe, while almost eight hours followed by another two or more hours is unsafe, or is unhealthy, is a regulation worthy of further consideration.

A regulatory posture inadvertently ignoring the danger of encouraging maximum speed and the danger of driving while sleepy, is one that needs to be amended.


Kimberly A. Southers - Comments 01/30/2008 PUBLIC SUBMISSIONS

General Comment:
In order to avoid driving tired and traveling through cities at their most congested times, drivers NEED to be able to take a meaningful rest and stop the 14 hour clock. Safety is supposed to be the reason for the HOS and the 14 hour rule, with no room for needed breaks, occasional naps or traffic avoidance, that does not penalize the driver financially, is contrary to safety. For teams it is downright unsafe; most people can not sleep 8-10 hours in a truck, so they sleep 4-5 then sit around waiting 4-5 before they are able to start their 10 hours of driving. Ten hours is a long time to drive before you can take a nap or let your co-driver take over. Many teams prefered the 5 on/5 off or some other schedule SHORTER than 10 for SAFETY safety, with that schedule it is much easier to remain alert and get needed rest. As a team driver, I prefer 6-8 hours of driving at a time. That's all I like to do as a single driver as well. I prefer to sleep when I'm tired and drive when I'm not. The 14 hour rule almost NEVER fits my body's pattern.


Michael Cummings 01/31/2008 PUBLIC SUBMISSIONS

General Comment: Hello,

I am retired DOD after 32+ years. Director of Information Systems, Defense MegaCenter Columbus, Ohio

Been driving truck since 1999. I think I have some insight into driving safetly.

1. You are Not Taking everything into consideration in the 11 hour driving and 14 day rule. Loading Times and Unloading Times are NOT being considered and this is a major factor. You go to pick up and the load is supposed to be ready and it takes 2 to 4 hours to load! Same for the deliver. These times need to be considered in determining the over all rules, they are Not Being Considered.

2. You are Only Looking at Hours and Not Miles, key issue is miles driven Not Totally the Hours driven. One should not be driving more than 550 to 600 miles per day regardless of the hours of driving. Miles are Not Being considered in the mix.

3. If you drive say 6 hours or less in a day, you are required to take the same break as someone who drives say 10 or 11 hours. This does not make sense either. Also, this gets in the split driving issue. One drives say 5 hours and takes a 5 hour nap/break or 6 hour nap/break. There is No Reason why that person could not drive another 5 hours. Personally, I think the driving time should be moved back to 10 hours as 11 hours is too much but with No Method of Extending the 14 hour day, drivers Push Themselves to get the load there and have to get the load there within 14 hours and 11 hours driving as there is NO Alternative. There needs to be some way to Intelligently extend the 14 hours, using some Intelligent break period of 5 to 6 hours in the middle. Also, this break period should be taken within the range of 4 to 6 hours of driving and followed by 4 to 6 hours of driving maximum. Then a 10 hour break should be mandated.

4. There should be No 34 hour rule, where does this come from. My daughter is a nurse in the heart ward and she works 12 hour shifts and 8AM to 8PM, comes home and is off 12 hours and goes back for another 12 hour shift. Sometimes, she works 14 or 16 hours and goes home and is back for the next shift at 8AM. If you take a 10 hour break after 10 hours of driving or 600 miles maximum one should be good to go day after day. There is No Industry out there that madates a specific number of days or hours off to be ready to go again. If you can show me where this comes from (the 34 hours) and what it is based on (what study or rational) then I would like to see it! Enough said, when I was coming up and got my two BAs and two Masters I was alway told to Look At Everything Before You Do Anything and If It Is Not Broken The Don't Try To Fix Something or Improve Something If It Does Not Need It.

Michael Cummings,


Daniel R. Kupke, Sr

General Comment:
I am a small bussiness owner as a cross country truck driver. These current HOS rules that keep me from stopping the clock to take a break are only makeing me a more tired and frustrated driver of a over 80,000 lb tractor trailer out on the highways of this nation. By not being able to stop the clock and get some rest when I need it dureing my day I am not as alert as I would be other-wise. This makes me more of a hazzard to the general public that I do not wish to be. Also being bothered or woke up in the time that I am trying to sleep because I have the truck running due to weather conditions also makes me a less alert driver. I don't believe in letting the truck idle for no reason but do need to be comfortable to sleep to get my rest and be fresh and alert out on the highway. Split speed limits are another dangerous problem. Anytime there are 2 different speed limits there will be accidents from the difference in actual speed that vehicles that are traveling when they are going the same direction ?? I have only the desire to work in my profession and service my customers as well as possible but with all of these unnecessary never ending changes to the rules it is becomeing allmost impossible to do this not to mention the cost of fuel and repairs ??? My lively- hood as well as millions of other drivers depends on you keeping the industry alive by not chokeing off our air supply with never ending rules !!!!


Leslie D. Lightner

General Comment:
RE: FMCA-2004-19608-2578 :
I gave up driving in 2006 after trying to live with the revised HOS that did not allow teams to split sleeper berth in any increment other than 8&2. My husband and I ended up driving 10 hour stretches so the other one would have the required 10 hour break. Neither of us could sleep 10 hours or even 8, so consequently we were exhausted every time we got behind the wheel.We had driven 5&5 since 1995. The 10 hours behind the wheel felt like a prison sentence, especially in bad weather. I actually fell asleep while driving on more than one occasion, and it was only by the grace of God that we were never in an accident. We hauled AA&E, so any accident had the potential to be a disaster. I decided to get off the road before I did kill someone, and my husband went to work for another company driving solo. My personal income went from over $60,000 a year to less than a thousand dollars. I am collecting SS benefits now, but I miss the road and being with my husband.

We liked the 34 hour restart, but not allowing the 14 hour clock to stop for breaks is almost as bad as denying us the option of splitting our sleep time in the most practical and efficient manner for us. The FMCSA regulated me right out of a job that I loved and was good at-in 14 years I had never had an accident of any kind.


Gary B. Hull

General Comment:
It is my opinion despite the fact that the latest crash figures are positive that the current rules are the most dangerous rules we have worked under. This would include the 1948 rules. The reason is simple. Although it does not say this in the rules but in practice it is true. That once a driver is loaded he must stay in the seat until his 11 hrs is up. And if he stops he will loose out of pay check $10.00 to $15.00 for just a 30 minute stop.

Another way to say about the same thing is that the current rules treat the driver like he is 5 years old. We are Professional drivers and as such we wish to be treated as such.

I also believe that one of the reasons that the safety statistics are as good as they are is that drivers are doing the driving in a safe manner and then filling out the log to look right.

Also their has been some discussion to have us drive less time during the day. This would create even more problems because their would not be enough parking space. And when a driver stops with say 12 to 14 hrs to kill they have too much time on their hands. What will happen is they will become involved in activities in the truck stop such as prostitution, gambling etc. These activities will then create problems at home. Now as he drives down the road he does not have his mind on his business. This will create accidents. At the same time drivers will not watch the time and then all of a sudden realize they will have to return to work in 4 or 5 hours and they have not been in bed yet. So they go back on the road tired. This too is not good. The current 10 hours off is long enough to get good sleep but not too long.

Now for the local drivers there may be a need to change their time off. If an OTR driver is tired he can be in bed 15 minutes after he stops. And he can sleep until 45 minutes before he leaves and still get something to eat. On the other hand a local driver with only 10 hours off will only get about 4-5 hours sleep. Because of family responsibilities and commute times.

Then the current rules do not allow us to stop so we do not have to fight rush hour traffic. Houston TX is about 70 miles across. During non rush hours it can be driven in about 1.5 hours. When you drive through during rush hour it will take 3 hours. Everyone would be much better off if the trucks could park, get a little rest and drive later.

In short these are bad rules


Anonymous

General Comment:
Ive been driving thusk for about 37 years and i didht see anything wrong with the old HOS,but the goverment saw fitto change them, now we have gotten used to the new HOS and they want to change them again, This another example of people trying to run something they know nothing about, If you want to mess withe the trucking industry my suggestion is that every one of you get a CDL get in a truck running long hall for at least 6 monts before you start making rules for those of us that do it in a dailey basis,


Anonymous
General Comment:
PLEASE do not eliminate the 11th hour of driving and 34 hour restart! The extra hour of driving is more than compensated for by the extra two hours of break time mandated by the 10-hour break; to force drivers into a 10 on/10 off schedule will only serve to tempt drivers to disrupt the body's natural circadian rhythm (aka the sleep cycle) by waking up earlier each day in order to maximize running time. This disruption of the sleep cycle is FAR more fatiguing than any effect a single extra hour of driving time might have. Statistics show the 11th hour of driving is safe, why change it? As for the 34-hour reset, the opportunity for drives to "take a 34" to reset the 70-hour clock is the main reason so many more large carriers are now offering weekly home time, instead of keeping drivers on the road for weeks at a time. Do we really want to eliminate that? How does that help a driver's alertness and attitude as opposed to the current setup? Also, the ability to "start with a clean slate" after 34 hours downtime is far simpler for logging purposes than constantly adding and subtracting hours even after several days off, as would be required again if the restart is not available. Why make life on the road any more complex than it has to be? Also, drives who run short of hours while on the road will sometimes take a "34" in a truck stop or motel, emerging a day later rested and refreshed and ready to run. Without that option, drivers in this situation usually keep running, day after day, as many hours as their 70-hour limit will allow them to get away with and sometimes more. The 34 hour reset is the incentive that gets these tired drivers off the road and gives them the rest they need to drive safely, why would we want to eliminate that? Finally, let me point out that if ANY aspect of the current HOS promotes fatiuged driving it would be the 14-hour rule (no driving after 14 hours from going on duty). Why? Because the 14 hour clock CANNONT BE STOPPED! Stuck in line at a fuel stop? The 14-hour clock keeps ticking. Delayd seven hours at a shipper/reciever? Can't stop that 14. Faced with this fixed deadline, many drivers will push as hard as they can once they are rolling again, bypassing a chance to take naps, stretch breaks, meal breaks, or any breaks at all. Prior to the 14 hour rule, such breaks were common, but they are a rarity now for many OTR drivers. If any rule must be ammended, make it the 14, but PLEASE do not eliminate the 11 and the 34! Thanks very much for your time. -Mike P

ps- endless error messages while trying to submit. Please fix!


C.L. Klages
General Comment:
The 14 hour stipulation makes no sense. In my situation, typically I drive or am on duty 4 to 5 hours early in the morning. Then quite often, I need to drive another 2 to 3 hours in the evening. In this day I may be up at 6:00 am and in bed by 10:00 pm. In many instances, I may not have a full 8 hour break during the day, but do have a nap, shower, hot meal but am not allowed to drive my additional 2 to 3 hours to stay within the 14 hour clock. The current rule requires that I complete my drive to my new location without rest, food and shower and then spend a long period of time in a truck stop and / or in the bunk of my truck. I think common sense tells what is the best option.


Kip Bubar

General Comment:
I have been in the trucking industry for over 20 years in many different capacities and disciplines. Currently I am the Operations Director of a Intramodal firm in LaPorte, TX. Speaking from a position of having been a driver, safety representative, instructor, shop manager and Operations Director I feel the HOS regulations currently in place are very much contributing to the safety of the professional driver as well as the safety of the general public. I have two comments to make:
(a) The 34 hour restart allows our drivers to take a restful period from driving and also aids in keeping the logs accurate. Now a driver has an incentive to take a break longer than a day. Before, a driver may approach his/her 70 hour and just shut down for 1 day and only gain 10-14 hour increase in driving time. Now, a driver has the incentive to take another day off and regain all of his/her hours. It helps us lead a life a bit more like the rest of the public and have quality time with our families, etc.
(b) The 14 hour clock is contributing to fatigue in our professional drivers. When I was a driver I would drive for several hours and then I would stop, eat and then take a nap. After the nap I would complete a thorough inspection of my truck and then complete my driving cycle. With the continuous 14 hour clock our drivers can not afford to take a rest period. If they are delayed at a shipper or consignee (a common occurance) then they will need to run to catch up on their schedule before their 14 hours runs out. Additionally, in many circumstances, this 14 hour continuous clock will cause a driver to "eat on the run". This practice of driving while eating causes a driver to divert his attention from operating his equipment to reaching for his food, drink, etc. Again, he may have to eat on the run because he cannot afford to use his/her 14 hour clock parked and safely eating. Thank you for this oppurtunity to voice my thoughts on this matter and I sincerely hope that you take all of these comments into your thought process during this deliberation


Bill and Cindy Klemm

General Comment:
Terminate the Hours of Service regulation entirely, please. It's a complete waste of so many resources that can easily do more good improving something else, like longer get-on ramps for improved safety.

Drivers will be under less pressure from paperwork, regulation, and enforcement, so we can focus on real safety concerns, like the weather. D.O.T. officials can focus on real safety instead of this silly set of requirements that don't do anything anyway. Motor carriers can save money they need for all the other new expenses and new regulations you are always coming up with to make business more difficult. The FMCSA HOS commission people can finially move on to something more interesting. How many years have you invested in this nonsense?

Perhaps you could use the current HOS for training new drivers their first couple of years until they learn how to sleep and how to say NO to a dispatcher.

Perhaps you could the HOS for inmates on parole who are supposed to report to someone less often than we are.

Perhaps you could put Britney Spears under HOS so the media could better hound her.

Every driver we ask says it does nothing for him or her. Some drivers think HOS does something for some other driver, but not for himself. I ask you the same question: "Would being under this same HOS regulation make YOU a safer driver?" I'd love you to strictly try it yourself for a month and no cheating. Then have an expert or computer check your log, and match it to your qualcomm records, toll receipts, bills, ect. HA! It's a gotcha, nothing more.

HOS not only does not improve safety, it's a detriment and distraction to really effective safety efforts, and the good things the DOT and FMCSA have done.

Please get rid of the entire Hours of Service for the USA and for all the states. Please encourage the same for Canada and Mexico, and lets work together with insurance companies, legal officials, and especially drivers, to focus on getting the job done, and that means safely.

If you keep it for someone, at least put in a total exception for teams. You have nothing in there for teams. The rules force me to drive longer than I want with fewer rest periods than I want, as an over-the-road team driver. The rules discourage any rest for at least 10 hours at a clip. Without the rules I could take a break and still deliver the load before morning, avoiding rush hour times easily. With the rules I just can't stop because if I rest now the rules will prevent me from completing the job after I've rested and before morning. The 14 hour thing is absolutely crazy. Why can't I wait until after midnight and use the more empty roads when all the children are asleep? Rules, rules that put me right into rush hour when I could often wait it out resting or enjoying a good dinner. But with the government restrictions on our time we must not stop once we start we go all the way, even if the consignee is not going to unload for 3 days after we get there. So then we must sit in a parking lot instead of getting good meals along the way. These rules are mean hearted, I tell you.

Please get rid of Hours of Service for everyone, or make a lot of exceptions for decent people who have learned when to sleep already, without reported all our activities every 15 minutes, subject to legal penalties for errors.

I've not seen any statistics for teams in your discussions, or for owner-operators driving our own trucks. We have the extra safety incentive of our partner aboard, as well as the hefty investment in our own equipment at risk. It's not like a rent-a- car for us. Please except teams, and please except owner-drivers. Keep some stats on it and revisit it later. Use the HOS as a tool only for training.

The cost of enforcement on this is more than the dubious benefit, in disrupting drivers who might get more rest if we didn't have to worry about the HOS all the time. If there are some drivers who drive too long, they are doing it anyway: they are more likely to get the load than someone who waits due to HOS. Time sensitive freight over a great distance needs a team, period. Dispatchers or shippers who demand more than what can be done need only bear some of the responsibility for pushing it without a team. Currently they get no penalty for asking a single driver to get the load accross the country by morning. Are they not complacent in a dangerous game? When the responsibility is all on the driver and you need something to be there fast, why would be concerned if one driver says he will run it? You should get a team on it, but you might not.

Hours of service are not the answer, people. Please get rid of the entire Hours of Service and look at safety more realistically. I think you can.


Bill and Cindy Klemm

General Comment:
Hello,

I hesitate to even tell you we are from NY State, since I feel that our representatives are anti-business, because it seems there are always more rules, more regulations and more money being grabbed for governernment to give away in grants for non-sense pork. If we keep our income low we can get Healthy New York assistance. They really don't want us to get much work done, as evidenced by the tolls, taxes, regulations heaped on us, and programs to encourage not working, especially the Hours of Service regulation.

This HOS follows us every 15 minutes of our lives, all the time, incesantly, no matter what. It follows us to bed. It follows us on days off. It follows us when we stop for personal breaks and denies us rest by narrowing the time window to get our driving done, even when the shipper has given us plenty of time.

It would be so nice if you could do something to help us out, to have the chance to drive our own truck on the safest schedule, according to the shipper, the consignee, the weather, avoiding problem areas like construction and rush hour, our personal abilities to take turns driving when it's comfortable for us personally, without the overriding concern of the HOS regulation to goof it up.

Yes, goof it up, and that's all it does.

Please get rid of the Hours of Service regulation in it's entirety, and we will be ever thankful to you.


Cindy Klemm

General Comment:
Please discontinue all of the Hours of Service regulations, entirely. Please.

Tonight I am on duty for several hours, doing office type stuff like using this website, for several hours. After say nine hours of this you have authorized me to start up our truck and drive for 5 hours. The Hours of Service regulations prevent me from sleeping for 5 hours before driving the 5 hours I have in mind. That I could do nicely, but no. Someone has decided better than me, regulated, implemented, enforced, audited, discussed,determined, over several years to conjure up a 14 hour rule for me, based on somebody else's imagined day.

I would really feel better about driving if I could sleep 5 hours first, but you know best. Are you taking any responsibility for this? Oh that's on me.

It's my truck, It's my load. It's my responsibility for sure. I should be the captain of the ship tonight while you are asleep at the desk. It's not right that you should be driving my truck with endless regulations that work for you and your day, but not for me.

I love to drive after midnight when the air is clear and the kids are asleep. It's my best time to go. The phone doesn't ring. The daytime commuters won't miss me at all.

The HOS regulations just make things harder. Harder to coordinate with the conditions at hand. Please get rid of them or write team exceptions.

Thank you.


Bob

General Comment:
After 30 years of Trucking, and never hurting anyone with my 40 ton killing machine... The only stress and/or fatigue I'm feeling (other than fuel prices) is from all the left wing advocates ( trucker hate groups ) that keep dragging it back to appeals court..

Stand your/our ground and leave well enough alone... No matter what you come up with for rules they WILL NOT BE HAPPY...

Sincerly Bob


Ronald W. Hawley

General Comment:
my wife and i havee been driving for 37 years . the 11 hr and 34 hour restart is ok the one thing that upsets us the split sleeper. we have always log 5 hrs on and 5 hrs off. now there said we cant do this we love driving and beening on the road but we are thinking about quiting


James E. Caron
Hesperia, CA

General Comment:sir; as an over the road truck driver with fifty (50) years as a driver/ owner/operator,i believe that the currnet eleven (11) hours of driving is adequate for today's drivers. the thirty-four (34) hour restart is far and away much better than the old way of picking up hours on a daily basis.

i would further say that there should be some changing on the sleeper birth provision.


John W. Bush
Manor, PA

General Comment:
the problem remains in the sleeper berth area. under the old rule we as drivers could follow the training we've had that teaches us if we are tired to stop and rest or (nap). under the new rules we are forced to continue on when we really could stop for short breaks to eat and the like when needed. this in my opinion is the largest problem with fatique. the old law allowed loop holes to circumvent the law and drive tired and for to long. my suggestion is to leave the drive time alone. demand the 10 hours off but allow reasonable breaks during drive time to rest without causing our hours to be used so quickly. any other occupation gets breaks and lunch time off.

otherwise you all are on the right track with causing 10 hours consecutive good job there. thanks for the extra hour!!!!

but noone can sit in that seat for 10 - 11 hours straight with out stops. people dont want to stop anymorre because they are loosing valuable drive time.


John W. Bush
Manor, PA

General Comment:
the problem remains in the sleeper berth area. under the old rule we as drivers could follow the training we've had that teaches us if we are tired to stop and rest or (nap). under the new rules we are forced to continue on when we really could stop for short breaks to eat and the like when needed. this in my opinion is the largest problem with fatique. the old law allowed loop holes to circumvent the law and drive tired and for to long. my suggestion is to leave the drive time alone. demand the 10 hours off but allow reasonable breaks during drive time to rest without causing our hours to be used so quickly. any other occupation gets breaks and lunch time off.

otherwise you all are on the right track with causing 10 hours consecutive good job there. thanks for the extra hour!!!!

but noone can sit in that seat for 10 - 11 hours straight with out stops. people dont want to stop anymorre because they are loosing valuable drive time.


Danny K. Singleton
Conway, SC

General Comment:
Good day ladies and gentleman; Most problems have a simple solution,but I believe we are in a quandry here. Statistics may show that not having rest breaks during our 14 hr duty cycle is safe. People behind the steering wheel might have a different idea. Only they know of all the times that they have almost had an incident because they were drowsy and could not pull over to take a break. If this situation is allowed to continue, more near incidents will occur. As drivers are subjected to more and more stress then those 'near incidents' might become horrific accidents. I can offer no remedies but I think that a committee of drivers(the people who can explain how the real world operates truckingwise) should have a major say in HOS. Thanks for your time


James Hatten - Comments 02/11/2008 PUBLIC SUBMISSIONS
General Comment:
I have driven Trucks for twenty four years, I have been under both set of hours of service! The 34 hr. re-start works very well for me, under the old law my log book told me when I was supposed to go to bed, then I`d toss and turn not able to sleep because I was not tired! Then when The Log Book told me it was time to drive, my body clock would tell me now is the time to sleep!. So Yes, I could get as many hours as needed out of one page in the log, but in my mind I was still running Ill-legal. So PLEASE to me the 34 Hr. re-start would let me run when and sleep when I Feel like sleeping. LET THE TRUCKERS, Decide, We are the men and women that live and die in the trucks, so all Americans can have their daily necessities! Thank You for your time


Ben E. Massey - Comments 02/11/2008 PUBLIC SUBMISSIONS
General Comment:
The HOS is a rule that keeps our roads safe and our truckers rolling. The FMCSA is wanting to change the current rule of 11 hours driving and 34 restart. I would like to see the HOS changed to accomdate the driver. Drivers get up at different times and drive for 3-6 hours and then may get tired or want to take a break or have to deliver. The HOS should read something like this: the required time on duty in a 24 hour period can be no more than 15 hours and at can be either driving or performing duties of the job. Sleeping time in the sleeper berth must be at least 9 hours in each 24 hour period. After a 10-13 hours on duty, a 1 hour sleeper berth must be required. All hours in the sleeper berth count toward the 9 hour limit and at least 5 must be continous. The restart rule is still 34 hours.

The rule should allow that drivers can take naps in the day and it count towards the totals sleeper berth time. For instance: drivers wake at 5 am and begins the day. They drive until 11am and have lunch and deliver at 2pm. From 2pm-4pm the rest in the sleeper berth while being loaded. So they have been on duty from 5am-2pm (9 hours) and 2 hours of rest. They can continue to drive 6 hours to get to the next destination and get a good nights rest. So it is 10pm and the driver shuts it down and rests from 10pm-5am the next day (7 hours rest). All requirements meet and plenty of sleep in a typical day.

Ben Massey


Stan Shuey - Comments 02/11/2008 PUBLIC SUBMISSIONS
General Comment:
The biggest issue is not total hours as much as PATTERN of WHEN/HOW a driver can best utilize the required 8-10 hours of sleep! Many times one becomes sleepy after 4-6 hours and is BEST served by sleeping as necessary maybe 1-4 hours until thoroughly rested, then continuing until total 10-11 driving hours are used up. To "force" one to rest when his/her body is not ready for that is insane! A driver will still be "tired" when starting up again. Drivers will then push to get all 11 hours in before resting, so they ARE tired and can sleep, but this promotes drivers who are not fresh the last 5-7 hours of driving. Change the HOS rules to allow smaller segments of sleep as necessary, while still fulfilling total required rest time! The only way to safely drive now and get required sleep AS NEEDED is to lie on the log book as to WHEN the rest time(s) occurred.


Anonymous - Comments 02/11/2008 PUBLIC SUBMISSIONS
General Comment:
I Have driven under the old and new rules. I feel that the 34 hours reset is the thing that keeps the industry safe and alert at the wheel. I think the 11 hour rule is a whole other thing. 11 hours is ok for a good day's work without fatigue but the fact that I can't stop and take a 5hour break in the middle of the 11 hours is dangerous. Not all of my days start at 8am and stop at 7pm.and if I get sleepy after 5 hours of driving, i can't get needed rest without stopping my clock and having to start over on my 10 hours of rest.This needs to be changed back to the way it was before.


Mark West - Comments 02/11/2008 PUBLIC SUBMISSIONS
General Comment:
I find it hard to understand why I have to be penalized if I get tired and need to take a break. How can taking a 2,3,or 4 hr break in the sleeper be any less safe than pushing to drive a straight 9,10,or 11 hrs.when I'm tired and shouldn't be driving, but because the 2 hrs I'm now allowed to split cuts my available working hrs so I just push on.

I also don't understand that after driving 9,10,or 11 hrs.to the delivery point and waiting asleep in the sleeper for 5,6,or 7 hrs to be unloaded that I might not be legal to drive to a parking area because the 2,3,or 4 hrs I might have taken earlier counts against me even tho the customer won't let me stay on his property to regain my full 10 hrs. So now I have to move and if logged and done legal I have to wait another 10 hrs to continue to try and earn a living.

I

also don't understand that while driving teams I should be expected to sleep for 10 hrs in a moving truck every day instead of being able to split this time with my partner in an effort to be fresh and SAFE .!!!

My COMMENT IS SIMPLE Please look at all the variables in this business and not just those that passify this group or that. Even if it means looking at more than one set or rules. This doesn't have to be that complicated if a little common sense could by found rather than government b/s.


Anonymous - Comments 02/11/2008 PUBLIC SUBMISSIONS
General Comment:
As an over-the-road driver of about 37 years (since 1971) I have always felt that the hours-of-service regulations have no practical value for anyone in the trucking industry. For whatever reasons they were started some 70 years ago they were certainly not intended to create safety on the highways and when you compare today?s trucks and highways to those of that time in the late 30?s the same is even more so today. The cost of maintaining the system for all those years has been a tremendous burden to the American consumer.

However, being practical, I realize that the probability of them being eliminated completely ( as they surely should be) is practically non-existant so I am making the following comments and/or recommendations:

1. The 34 hour restart is extremely helpful to most drivers and should be maintained.

2. The 14th hour restriction contributes nothing to safety. In fact, it causes drivers to continue driving when they should be resting. Drivers should be allowed to take short breaks during periods of heavy traffic or during adverse weather conditions, or just simply when they feel the need for a short rest period.

3. The split sleeper provisions as currently configured ( 8 and 2) are not practical and should be changed similar to the old rules ( 5 & 4, etc). The eight hour requirement is completely useless and does nothing to contribute to safety (A driver might as well take the full 10 hours off)


Anonymous - Comments 02/11/2008 PUBLIC SUBMISSIONS
General Comment:

There is a big problem that does not seem to be getting any attention.

I have been a truck driver for 35 years and the first problem I became aware of was that mother nature has programmed my body and there is no way for me to override her programming.

Mother Nature has programmed me to be ASLEEP when the sun comes up.

And it is not just me from the number of daycab trucks ( no sleeper compartment) parked in..... anyplace.... they can find at sun up there are a lot of us..

Ok ..mother nature does not care about what time the clock says... she does not care about the 14 hour rule...she does not care about traffic...she does not care about what my dispatcher wants..she does not care that I just got out of bed an hour ago..I will be asleep at sun up...I hope that I remembered to PARK the truck first.

The HOS rules need to provide the drivers with the flexibility to deal with these kind of issues... (get the companies off our backs) the HOS rule should be protecting the drivers and the public Not the companies.


Martin W. Ellis - Comments 02/11/2008 PUBLIC SUBMISSIONS
General Comment:
I have worked in the trucking industry for hire section for approximately 14 years all driving for the same company. I also have another 7 years driving a commercial vehicle hauling privately. With changing the rest period from 8 hours to 10 hours, we need the 11 hours of driving. The 34 hour restart is essential to keep in effect because it helps drivers with their rest, at home or on the road. If the trucking industry was perfect, we would all be able to work 8 hours per day and be home with their families every night. This is not practical and never will be, so we need to figure out a happy medium with work and rest while at the same time, keeping safety at the top of mind at all times. A 10 hour break is more than sufficient to get proper rest. I have commented before on the hours of service and still believe that since the FMCSA is looking for a 1 size fits all rule, then I believe that we need to start totally fresh and simplify the rules by using the 24 hour log book and demand that a driver take 10 hours off in every 24 hour period but leave how that is done up to the driver. If that means that the driver wants to take two 5 hour breaks or any combination that adds up to 10 hours, the driver should be able to make that decision by the way his body feels. We can do away with the 70 hour rule and the 14 hour rule. Most people in other industries do not actually rest for more than 8 hours. If I had any other job, I could work as many hours as I wanted to, at one job, or several. I realize to people with other jobs, 70 hours seems like a lot, but by the time you take away the hours a drivers spends that is not copensated for, it shrinks those hours down considerably.

The way it is set up now, a driver must rest when the clock says to, not when his body says to. The driver must also drive in conditions that may not be the safest for him or others. The driver also has to drive at the speed limit posted when that may not be appropriate for conditions because the clock is always ticking. The drivers also need to drive at times such as rush hour when if he had the flexibility, he may be able to avoid this, resulting in less traffic congestion and of course safer roads. Thank you for taking these comments into consideration.


William - Comments 02/11/2008 PUBLIC SUBMISSIONS
General Comment:
Mr. Walker,
The website indicates it would appreciate any research on driver fatigue.
As an over the road truck driver, I offer this empirical evidence on driver fatigue.
a. Working 6 days a week, week after week causes fatigue because one comes home, collapses into bed, washes one's clothes and barely recuperates before one climbs back into the truck for the next week. Also, it is not good for marriages or raising children. A 5 day week is better and it can use up 70 hours (14 x 5) if the dispatchers and planners and customers are efficient.
b. Working 70-80 hours a week causes fatigue.
c. Starting off the week on Sunday night rather than Monday morning and never catching up on the sleep debt the whole week causes fatigue.
d. Being woken up in the middle of the night by police officers or prostitutes banging on the door causes sleep fatigue.
e. Not the driver flexibility in when to sleep causes fatigue. For example, in one case, I had just had a good nights sleep, a fresh 11 hours to drive available. I used a few hours to go and unload. But then, I was sent to a customer who made the truck sit there all day and evening for loading (10 hours wasted) such that by the time I got started and used up my new 11 hours of driving, I had not slept for over 24 hours. One can not bank sleep the same as one can build up a sleep debt.
Also, under the old rules, a driver could stop when he got tired and when there was a safe place available. And he could break up his hours any way he wanted. But with the new rules, the drivers and the trucking company managers expect the truck to be moving as long as there are driving hours available regardless how tired the driver is because he has to make sure when he stops it is either for 2 hours or 8 hours.
With all due respect to people addressing the problem of driver fatigue as a cause of accidents, the real problems of accidents are speeding, tailgating, and going too fast for the conditions regardless of the speed limit such as too fast in fog or on ice or on hills, or in backing up, or in towns. And then finally, immaturity is a factor because some immature drivers want to pretend they are super truckers.
Sincerely,
William Riker


James K. McKee, Jr. - Comments 02/11/2008 PUBLIC SUBMISSIONS
General Comment:
I have been a professional truck driver for 20 +years now. I believe the 11 hour rule is adequate. The 34 hour restart rule is probably the best thing to come out of the new rules! The rule encourages a long break and I think promotes a rested and safer driver. I think the 14 hour rule needs some work though. As a driver I sometimes get tired during the day. At these times I might want to stop and take a nap to refresh myself, under the old rule I could due this without taking away from my driving time. Under the new rule I lose this time so I am compelled to keep driving even though it would be safer to rest. This makes no sense. These times for me usually fall at about the same time as traffic is the most congested (rush hour). If drivers could pull over and stop during the times , by stopping the clock, the roads would not only be safer they would be less congested at times when traffic is at its peak! This sounds like common sense, something I think our culture is lacking today. I'm not out to hurt anyone, or myself. I just want to be able to make a living and enjoy life. Be safe!


Samuel Huss - Comments 02/12/2008 PUBLIC SUBMISSIONS
General Comment:
The hours of service are fine the way they are. The 34 hours restart is a great asset to the truckers. We can sit for a little more then a day and regain hours as opposed to sitting for 2-3 days to regain the same hours. 11 hours of driving vs. 10 isn't the problem. Look at your facts and see how many accident involved drivers in the 10-11th hour of driving. Versus how many involved the few dishonest drivers going on 14-16-18ect...hours. Those are the problem driver. Letting us drive 11 instead of 10 is a big help to us to make our runs. Cutting our hours back will only further the problem of driver shortages facing the carriers now. If you want your shelves full at the local walmart then let us drive. Punish the ones who drive days on end with no sleep. But the ones who abide by the law should be allowed to do so. Bring back the sleeper split to. At least then we could lay down for a nap if need be. Now we are forced to do the 11 hours straight!!!


(Note: The below comment is a form letter PDF that I found repeated at least 5 times so far. I haven't bothered to cut/paste any others since they were exactly the same. -G) Guy Wopinski - Comments 02/12/2008 PUBLIC SUBMISSIONS

February 8,2008
Docket #FMCSA-2004-l 9608
Docket Management Facility
U.S. Department of Transportation

RE: Hours of Service of Drivers: Interim Final Rule
Dear Sir/Madam:

Many of us Owner Operators leased to Quality Transportation, Inc. support the Federal Motor Carrier Safety Administration's (FMCSA) December 17*, 2007 Interim Final Rule on Hours of Service of Drivers (HOS). We urge FMCSA to retain the 11 hour driving limit and 34 hour restart provisions as published in the Federal Register notice. These HOS regulations have supplied the trucking industry tools to promote driver safety, alertness and performance.

Quality Transportation, Inc. is a flatbed carrier based out of Baker, Montana with a satellite office located in Rapid City, SD. We haul various types of flatbed freight (lumber, steel, pipe, etc.) throughout the lower 48 U.S. states and the 4 western provinces of Canada. They run 65-70 units, operated by solely by Independent Owner Operators whom are permanently leased to Quality Transportation, Inc..

In the past year our accident and incident rate has decreased significantly aided by the new HOS provisions, especially the 34 restart, it may even be enhanced even more if FMCSA reinstated the split sleeper berth provision for all carriers with owner operators, drivers, and our valuable sleeper teams.

The 11 hour driving time has been very beneficial. This provision provides important flexibility for us to manage their schedules, particularly in times of unexpected delays such as traffic congestion, and has helped in loading/unloading and other shipper matters.

As an Owner Operator I feel that the new 11 hour provision enhances the flexibility of my schedules, it allows us to drive the additional time needed to make it to unload/reload appointments, allow for construction and unforeseen weather problems without exceeding the allowable time to drive. The percentage of us Owner Operators that find it necessary to drive 10 or 11 hours straight is very small. As Quality requires all Owner Operators to take a half hour break after driving 5 hours to help enhance their safety performance as we feel driving 10-11 hours straight decreases driving awareness, thus as we stated earlier, reinstatement of the split sleeper would add to safety as all drivers could take rest breaks as needed to meet the present 10 hour sleeper berth requirement.

The pro-safety aspects of the 34 recovery and restart provision are real and it has enhanced the "quality of life" For us Owner Operators. It is an essential part of the rules that adequately allows Owner Operators to obtain an extended period for rest and recovery. The 34 hour restart had an immediate impact on the Owner Operators, not only did it allow more flexibility, it improved our quality of life by providing them a way to spend more time with their family, not only did it refresh our available hours for working, but it refreshed us mentally and physically which helps us be more alert and safer on the highways.

In my view the new HOS rules have resulted in improvement in Owner Operator health, attitude, truck safety and overall highway safety. FMCSA must preserve the rules and the 11 hour driving and 34 hour restart provisions to continue the gains these regulations have provided, us Owner Operators and the entire trucking industry. Thank you for the opportunity to comment on this proposal.


Dave Steggerda - Comments 02/13/2008 PUBLIC SUBMISSIONS
General Comment:
FMCSA Comments on HOS:

I am a CDL driver and I have been driving since 1978. I have many years of experience driving all sorts of rigs in all weather conditions. From my experience and conversations with others in the transportation industry, I would like to comment on the Hours of Service discussion that is open till Feb. 15, 2008.

First off, I would like to comment on the people that are against the current hours of service. They should "shut up" and let the professionals within our industry to decide what is best for the industry. More studies and experience have shown that they (the ones against it) don't know what they are talking about. They have no experience in the real world of trucking and appear to be politicizing the issue to promote their agenda.

I think the 36 hour restart is one of the better decisions to come along since I have been driving. It allows adequate rest and it is a simple way of restarting and controlling the drivers? hours of service. You should do the math required under the old system and keep your log straight.

The 11 hours of driving is a step in the right direction but it does not go far enough. If we are allowed to work 14 hours in a "day", we should be allowed to drive for as many of those hours as possible. It is far less tiring driving one of the current trucks on the road than working on a dock at a shipper or receiver. Oh, and by the way, the shipper or receiver should be responsible for what goes in and comes out of a truck. Load it, seal it, and unload it. Let the driver do what he is paid for. DRIVE!

The 10 consecutive hours off duty rule should also be reconsidered. 8 hours of rest is more than adequate (as the old rules allowed) and the driver should be allowed to break the rest period into smaller blocks of time so as to fit his biological clock or work day, This would allow for rest periods while getting loaded or unloaded, or a break to avoid traffic congestion in or near larger cities at rush hour.

You should also coordinate our system with Canada?s hours of service. While Canadian HOS are not perfect either, they allow 13 hours of driving with 14 hours on duty in a 16 hour clock. This is reset with an 8 hour off duty rest break. This program allows for adequate rest and an opportunity to take a lunch break during the day without being penalized as we are with the 14 hour running clock.

Oh, and if the hours of service are so important, why was Colorado allowed to suspend them in 2006. According to the Denver Post article dated 8-9- 2006, hours of service for truckers hauling fuel were suspended until August 18 because of the fuel shortage. They were required to operate ?safely? under the relaxed rules. HEY! We are talking fuel, as in flammable, hazardous, explosive being hauled by fatigued drivers.

Thank you for allowing me to "comment" on this issue.
"Captain"


Robert A. Brand, Sr. - Comments 02/14/2008 PUBLIC SUBMISSIONS
General Comment:
Dear FMCSA im writing in reguards to HOS .
ive notice lately that the economy has slow i see we dont need 11 hrs of drive time in today market as it is.more drive time more fatiuge.the 10 sleeper birth is way to long and if u have to idel u waste fuel how economilcal is that A 9 hr sleeper bearth divied By A 5 hr bearth and a 4hr birth or in a straight 9 hr berth i see being effective less wait time and more production with out tha extra hour this way we gain two hours in a day and suffencent rest.which ingenral could be used as sleeper birth or off duty either way were not driving .i love the 34 hour reset . i think the fourteen hour work day is to much because the genral public does not have to Labor That many hours. Thay do around 8 too 10 hours and there on ther way home and who knows how much rest thay get.the shippers and recivers thought process also has to change its their money out there and thay know it and the trucking company try's to meet it's customers whishes right or wrong because thay need customers .this brings a new meaning obey regulation that half the customers our not aware Ive Very Rarely SEE A FMCSA BOOK IN A SHIPPERS OR RECIVERS OFFICE The Trucking Company Is to Know all.Heres Were THE DOT becomes profitable that is there duties.due to ignoraince of the Industrie


Doug W. Pond - Comments 02/15/2008 PUBLIC SUBMISSIONS
General Comment:
i like the hr.of service the way thay are except we need the sleper birth where we can sleep 5 and 5 or can stop the clock so we can take a nap and not have it count. there is a lot of time we can take a nap during rush hr. time and then go throught and we are not adding to the problem at rush hr. you have also made it so when team is halling haz mat the co-driver can not get up for 15 min to watch the load while fuling as required by law on certon loads with out being vialiton of HOS. there is also problems with the law in halling oversize loads when you drive all day then you get to big city and thay will only let you move it after midnight and some of the bridges like going in to ny.and the bay bridge in ca.
I WOULD REALEY LIKE TO BEABLE TO TAKE A NAP DURING THE DAY AND HAVE STOP THE CLOCK.
there is also time we wate for road close for snow and thay get the road open and you cant go because you are out of hr so you take your 10 hr. and the road is closed one more. DOUG POND


Merlin D. Laub - Comments 02/15/2008 PUBLIC SUBMISSIONS
General Comment:
Hi,my name is Merlin L, and i have been in the trucking industries for allmost 22 years and there have been some things that have change not all have been good. On the hours of services this 34 hour restart was a good part and was helpful all though i don't use it because i get to be home for the weekend, the 11 hour drive time could be helped if there was more flexablity so when i am in need of a nap in the middle of that time i could stop take a 3or4 hour brake and then go on in safety with out taking away from the 14 hours, so that all of us could be much more safe, thank you. Merlin Laub


Donald R. McKinley - Comments 02/15/2008 PUBLIC SUBMISSIONS
General Comment:
I like the 34 hour restart. I like the 11 hours driving time. I do not like the sleeper berth as it stands. I would prefer to use a split sleeper berth if I am going into a large city at rush hour to take a little nap, eat, take a shower, and stop the 14 hour clock. To enhance safety keep the driver off the dock and the trailer for loading and unloading make the shipper/receiver responsible for loading/unloading. If it takes longer than one to two hours to load/unload make shipper/receiver responsible for an hourly payment to the driver. Donald R McKinley


D. Cliff McKinley - Comments 02/15/2008 PUBLIC SUBMISSIONS
General Comment:
I regards to the hours of service of drivers: I approve of the 34 hour restart and the 11 hours driving time. I disapprove of the sleeper berth portion as it stands. I would like to see us enabled to split the sleeper berth that way if I am going into traffic I could take a little nap, grab a bite to eat, or take a shower enabling me to wait for traffic to die down. Also an aspect that I feel would enhance safety is to keep drivers off the dock allow them to sleep then while the trailer is unloaded/loaded. Make the shipper/receiver responsible for loading and unloading the truck, it's their stuff anyway the driver is simply supposed to transport it. By having him/her responsible for loading/unloading it fatigues the driver more than necessary. Furthermore if it takes longer than one to two hours to load/unload the trailer then make the shipper/receiver responsible for paying an hourly wage to the driver for making them wait. A driver gets paid by the mile, not the time wasted waiting for someone getting paid by the hour who doesn't want to do more than they have to. Thankyou. D. Cliff McKinley


William G. Kendel - Comments 02/15/2008 PUBLIC SUBMISSIONS
General Comment:
I have driven a large truck since 1980 and amassed over 2 million miles, with one non-fault accident. The 11 hour rule and 34 hour restart are both good options for safe operation of trucks by drivers. Another rule would be the split sleeper berth time. Continuous 14 hour days could become safety problems and the flexability to take breaks that does not subtract from your on duty time is very helpful at some times and/or operations. Accidents are terrible events, but I think these rules can help prevent their occurance. Thank-you


Anonymous - Comments 02/15/2008 PUBLIC SUBMISSIONS
General Comment:
In my opinion, the current hours of service are detrimental to our health. You don't just drive for straight for 11 hours, the companys have you run through different terminals and customers throughout the day and night. Doing other related job duties most always you are working 14 hours in a day. What other proffesion has you work so many hours? To work like this every day, and to take a 34 restart break, creates fatigue. This translates into an unsafe driver. Every day you can see the carnage created by these rule changes. More and more truck accidents. Every driver is trying to get his work done in 14 hours, many times unable to stop for lunch or breaks, day after day. This is insanity. The new hours of service have done nothing but put the drivers and the motoring public in jeopardy


Peter D. Bell - Comments 02/15/2008 PUBLIC SUBMISSIONS
General Comment:
I am a Canadian driver who also happens to own land in New York state and spend many hours there for 7 months of the year. My wife stays there for many months during the spring, summer and fall with frequent trips home to Ontario. I come down every weekend during these same months after having drove a truck all week, with 90% of my driving done in the USA. I have been driving for almost 10 years at this time and have experience with both the old and new hours of service. The new regulations, I feel, are much better than the old and more accurately reflect my sleep patterns, although they are not perfect. The lack of the ability to stop and eat, catch a cat-nap, or relieve oneself without going off the clock is truly not fair, or life like. The 11 hour driving is ideal although I rarely utilize it to it's full extent. The 34 hour reset is more than adequate to refresh oneself. Being Canadian, I feel that the hours of service should be universal across Canada, United States and Mexico. No differences. The Canadian hours of service are more realistic in that they allow up to 2 hours a day, in 1/2 hour segments or more, to stop for naps, food, etc. without it counting against you. The 36 hour reset is basically the same. I feel that all 3 governments should blend these rules that are much fairer to the trucking industry, and most importantly, the drivers. If we revert back to the old rules, or worse, the industry will be hard pressed to secure enough drivers (competent, well trained drivers that is) to fulfill all the needs of the industries we serve. Parking for trucks is at a premium now and adding an additional 30 - 50 % more trucks to accomplish this would be a disaster.


Charles E. Guintard - Comments 02/19/2008 PUBLIC SUBMISSIONS
General Comment:
PLEASE KEEP THE 11 HR RULE AND THE 34 HR RESTART, I ONLY USE THE 11 HR DRIVING TIME EVER SO OFFEN BUT WHEN NEEDED BECAUSE OF TRAFFIC , WEATHER ETCBUT IT IS THERE IF I DO! THE 34 HOUR RESTART LETS ME SPEND TIME OFF WITH FAMILY AND I AM MORE RESTED AND THATS WHAT THIS IS ALL ABOUT ISN'T IT! THE ONLY PROBLEM I HAVE IS THE 14 HR RUEL BECAUSE IF YOU WANT TO TAKE A (POWER NAP) YOU LOSE WORKING / DRIVING HOURS, THAT PART OF THE OLD RULE IS NEEDED BACK, I AM NOT A ROOKIE OUT HER TRUCKING AS I HAVE BEEN A PROFINESSIAL DRIVER FOR 29 YEARS


Ward Wingler - Comment 02/19/2008 PUBLIC SUBMISSIONS
General Comment:
Your hours of service of 11 hours and the 34 hour restart are fine but I am 67 years old if I need a rest break in the middle of the shift I am working in order to be more alert and safer on the highways across this country, I need to be able log off driving and into the sleeper berth for that break..Only I know how I feel and when I need a break because it is my body and my responsiblity to operate in a safe alert way and no one else can judge that for me as it is my CDL that is at risk if I drive when Iam tired or not feeling up to the task. Please do not let these out side groups tell you how to run your office, because they have never driven a semi- truck or even rode in one.


Jack Williams - Comment 02/19/2008 PUBLIC SUBMISSIONS
General Comment:
Current rules that are in effect are within reason with a few exceptions. Ten hour consecutive seems to be a bit too much, I feel there should be an ability to split the ten hours of rest, possibly with one period being no less than six hours. This should be able to stop the 14 hour day. As a driver, I have found that sometimes I get a bit tired in the middle of the day and feel like taking a nap, I used to be able to stop, take a short nap, then continue, and catch up with the rest of my eight hour break later. Also, as an occasional team driver, we are now being forced to drive ten hours straight or the truck will have to sit for a while, with the commodity we haul, that would create additional problems in extreme heat or cold. So, my opinion is: Current Rules Remain with one change, the ability to split rest periods while stopping the 14 hour work day with one period being a minimum of six hours.
Thank-you


Frank D. Barbeau - Comments 02/19/2008 PUBLIC SUBMISSIONS
General Comment:
Changes to the HOS that need to be made are:
1. Split sleeper of five hours each to satisfy 10 hour off duty rule!
2. The ability to "stop" the 14 hour clock for meal breaks, fueling operations, and time spent at shippers and receivers during loading or unloading unless the driver is actively involved in the loading/unloading.
Frank Barbeau


William E. Brouillette - Comment 02/19/2008 PUBLIC SUBMISSIONS
General Comment:
It seems that when drivers ask for something, like a reasonable split-sleeper provision, lawmakers and the public automatically assume that the request is something drivers can use as a loophole to operate outside the law. It seems that people think that truck drivers have no regard for anyone's safety, including their own. The truth, however, is that no driver wants to drive tired and take the risk of falling asleep at the wheel and possibly hurting or killing themselves or others. Let's get past this image of renegade truckers and move on to the reality of men and women just trying to make a living without killing themselves.

In fact, it's quite likely that the vast majority of log book falsification is not due to a greedy desire to make more money in less time, but rather due to a desire to safely make a living.

Whether due to illness, stress, or just a long, boring drive, fatigue can pop up unexpectedly on anyone. When that happens, a driver should not feel forced, either by scheduling pressures, or economic circumstances (loss of pay, loss of job) to push on through that fatigue. With the current rules, the only option left available to those who wish to operate safely without facing economic sanction, is to falsify their log books to allow an additional rest period.

Sleep requirements are not one-size-fits all. Although the FMCSA has attempted to address this issue by offering rules that are designed for optimal sleep time, and added some wonderful flexibility to the rules with the 34 hour restart, it has completely neglected the fact that sometimes people just get tired.

The Hours of Service are intended to protect the public from fatigued truck drivers, as well as to protect truck drivers from abuses by carriers. The way the rules currently stand, drivers have little control over the hours they work in relation to their actual rest needs. With rules that do not allow for split-sleeper berth time, drivers that feel the need to pull over and rest will find that time counted against them. Certainly, they can stop anyway, as most responsible drivers do. In order to legally log such a break, however, a driver must either take a full ten hours off, and lose any driving time they still had available for that day, or lose the length of the rest period.

Considering the tight schedules most of today's freight is shipped on, both options could make for an angry carrier or shipper. Carriers often discipline drivers for not making delivery times, which gives a driver a powerful incentive to skip the much needed nap and push on to avoid getting in trouble.

Truck driving is a risky enough profession without the added challenge, imposed upon drivers by their own government, of having to choose between driving while fatigued or falsifying log books to afford a little extra sleep. A reasonable split- sleeper berth provision is necessary to create Hours of Service that actually promote safety.

--------------------------------------------------------------------------------- The difference between genius and stupidity is that genius has limits.


Richard O. Plummer - Comments 02/19/2008 PUBLIC SUBMISSIONS
General Comment:
I have over 27 years experience drivig tractor trailer. 10 hours of driving in a 14 hour day is plenty. It would be better to split the sleeper berth time into two 5 hour segments if the driver wanted to.


Randy Britten - Comment 02/19/2008 PUBLIC SUBMISSIONS
General Comment:
in response to fmcsa-2004-19608 i feel that the 11 hour rule is a good rule it helps the driver also the 34 hour rule is a help to drivers the sleeper birth rule needs to be looked at and revised. we are just now learing the rules now without speical entrest groups getting involved. also the issue of parking is horrible across the country.that should be adressed .i was taught if it isent broke dont fix it. fix what needs fixing as a tax payer it would be nice to see problems fixed with your time.insted of this stuff. thanks.


Williams E. Brouillette - Comment 02/19/2008 PUBLIC SUBMISSIONS
General Comment:
The HOS rule disallowing split sleeper berth time and clock stops for rest is an issue with implications for all Americans.

Because of its unintended consequences, which have been expressed to the FMCSA in many comments, the rule places the lives of over the road truckers, as well as the lives of other highway users, at risk.

But there's more. There is another danger uniquely implicit to this particular HOS rule; a danger to all Americans; and that danger will be the topic of this comment. The rule is a regulatory incursion into our lives which is not, and cannot be, justified by safety concerns. It effectively allows police intrusion 24 hours a day for every driver as long as he or she is out on the road. Under the rule, police intrusion micromanages the timing of even the smallest detail of life. This problem has been discussed at length in previous comments to the FMCSA.

In this comment I will attempt to illustrate the unique danger of the present rule and I hope that my comment may move others to express themselves to the rule makers.

When America began building our economic infrastructure with the motor vehicle as centerpiece, we may have underestimated, perhaps innocently, the dangers inherent to the developing system. In the 21st century few people are unaware that our highway legacy includes significant loss to life and limb.

The enormity of our automotive infrastructure is closely paralleled by its inherent dangers. We have attempted to attenuate the dangers of our highway system. The vast infrastructure is followed closely by automotive lawmaking, and inevitably by law enforcement.

Perhaps it's best described by a metaphor.

I believe that in creating our highway system, we have created a monster. It has been said poetically that we are a nation of people in love with our automobiles. We are also, with the exception of tee-totalers, a nation of people who like our alcoholic drinks. We are a nation of people on the move, fast. The level of our economy is measured largely by people who want what they want when they want it.

In our desire to have everything we want, including blood free highways, we have placed an unduly heavy burden upon law enforcement.

Every time we pass a law, we do two additional things: One, we place a further burden upon law enforcement officers, and two, we bestow further police powers upon law enforcement officers.

For law enforcement officers, we now have men and women with firearms, tasers, mace, bulletproof vests, etc…. Furthermore, those officers are often supervised by superiors who issue explicit instructions to be aggressive in law enforcement activities. In some states, we already have police with the authority to use a needle on a motorist if, in the officer's discretion, a blood sample is called for. This is an example of what our way of life has cost us in terms of our personal freedom at the hands of our own police.

The motor vehicle can be, and often is, an instrument which opens the door for the expression of many less than admirable human inclinations.

Here comes another figure of speech.

Highway traffic (likewise police intrusion) usually resembles the flow of water. People behave hydraulically. People flow around obstacles in their path like they were water flowing around the boulders and fallen trees in a river channel.

I've heard other truck drivers describe the phenomenon this way: "They're programmed to fill every available hole."

It's true. Whether approaching a traffic light or on the open road, often with their cruise control on, people will drive as if they needed to immediately seize every advantage in traffic. Personal restraint is not exercised. Because personal restraint is not exercised, often at high speed, law enforcement is called upon to provide the restraint.

Here, the same metaphor can be used. By placing a heavy burden upon law enforcement, and imbuing the police with ever expanding authority and weaponry, (weaponry which police refer to as tools) we create another monster.

If we, the public at large, drive our vehicles in such a way that restraint is minimized and opportunity is seized, then what should we expect from law enforcement?

The reference to hydraulics, the movement of water, is one way the phenomenon can be described. Why should police officers, who are often under pressure from higher up be any less human than we who empower them? In not restraining ourselves, we create an opening for a law enforcement officer, who's under pressure, to move in. Then, we have just allowed the fist of law to exercise its authority and power over us. We can only hope that law enforcement officers' restraint is better than our own. However, that which is exercised is that which becomes larger and more powerful.

Police officers are human beings. Here I will repeat what I stated above: "The motor vehicle can be, and often is, an instrument which opens the door for the expression of many less than admirable human inclinations."

When police act out their own less than admirable human inclinations, often with the approval of their superiors, we have the makings of a police state. The police state creeps upon us and into our lives gradually, usually with our own tacit approval, sometimes at our own request. We need to wake up here and holler.

The HOS rule disallowing split sleeper berth time and clock stopping for rest places drivers in the intolerable position of choosing to either meet a delivery requirement or rest. The driver needs to do both, not choose between the two.

Under the present rule, drivers are placed in a position, by the law, where they are pressured to do things which go against their better judgment. Under the rule, drivers are pressured to forego sleep when they need it most, which can be torturous. Do we really want to have police enforcing this kind of rule?

Remember that the HOS rules have the force of law. Every driver who feels that he Doesn't have time to rest, or stop and eat, or shower, or buy groceries, etc…, because of a clock that doesn't stop, will be a driver who will feel police presence twenty four hours a day, pushing him to drive when he's sleepy and ordering him to stop when he's rested.

If we do not correct the present HOS shortcoming that is being discussed here, then we will have allowed law enforcement to enter our lives on a very intimate and personal level, around the clock, dictating not only how much we sleep, but more absurdly, when. Our every move, throughout the entire day, week, month, will be accompanied by the anxiety of police scrutiny. This is how laws and law enforcement behave hydraulically, just like people on the highway, flowing into every available space.

Are you a truck driver? If the above mentioned incursion is overlooked in the case of one class of American, the American truck driver, then how much is your own privacy worth? Would you like to have the police with you 24 hours a day, telling you when to sleep, eat, go to the bathroom, or relax? And I ask you have or do drive a 18 wheeler ? if not then you don;t know any thing about driveing one so what makes you know that is bestfor me I ask


Diane M. Johannes - Comment 02/19/2008 PUBLIC SUBMISSIONS
General Comment:
As a former driver and wife to a driver the thing I wish the most is that you would actively seek drivers to be on these commissions so you can get an actual imput as to what happens out there on the road. News reports are biased so if you don't have first hand knowledge about the trucking industry how dare you legislate it. I think the 34 hour reset rule is a plus and must. It is a great way to get the drivers some need time off the road. Either 10 or 11 hrs drive time is fine with me, but when I was driving I could never drive that long. I would also like to see the split sleeper berth put back into force. Before it was easier for a driver to stop and take a nap when they got tired as opposed to now. The whole purpose of this is to have rested and alert drivers on the road, the opportunity to rest when tired without taking a full 10 hour break is more appealing to me


Ronald W. Perry - Comments 02/20/2008 PUBLIC SUBMISSIONS
General Comment:
I feel the 11 hrs and the 34 hr. restart are fine but the 14 hrs straight through should be changed as it is not in the best interest of the driver or safty. It needs to be so it can be broken up for drivers to take naps if they wish or other business.


Barbara J. Kelly - Comments 02/20/2008 PUBLIC SUBMISSIONS
General Comment:
I would like to comment on the HOS issues currently at hand. From being a safety Director AND driver - The current HOS rules are very effective and are definitely improving safety! There is one part of the current HOS which could use some change however. Forcing a driver to drive within 14 hours of coming on duty - has a severe downfall. The problem with this is if a driver begins driving and say 3 hours later feels ill - there is not much option for the driver to stop and rest until he/she feels better. The rules will allow that driver to stop for only 2 hours and according to the current rule - he would have to again drive (keep in mind he is ill this IS NOT GOOD) as he only has 14 hours to drive before having to shut down. I feel it would be much more effective allowing splitting of drive time and allowing drivers to extend their hours by taking a brake. From being in safety - the 34 hour reset works well the only concern I see is forcing drivers to drive even if they are ill or just don't feel like driving at any particular time - we are forcing them to drive within 14 hours! Allowing them to split/extend their on duty and drive time according to their physical ambition would make the HOS much more effective and would make our highways even safer!


David Marsh - Comments 02/20/2008 PUBLIC SUBMISSIONS
General Comment:
To assume that everyone eating at a particular fast food restaurant has the same taste would be ludicrous, likewise, to assume that everyone has identical sleep patterns and needs would be as far reaching......

While we are all in agreement that there is a need for HOS, the task of generalizing is very complex. As with any type of generalization, a need for options must also be present.

One individual may require 8 hours of rest, while another has the need for only 6 hours, however, to have a mandate that requires either to be placed in a holding pattern in order to obtain 10 consecutive hours of rest is interfering with their biological clock.

The ability to be able to stop the 14 hour clock in order to obtain 10 hours of rest is more reasonable; let the individual decide which 10 hours of the day is best for them, don't pressure one into driving for 11 consecutive hours, this creates an unsafe environment.

The 34 hour restart is a good thing and was long overdue!


Ruby L. Lanigan - Comments 02/20/2008 PUBLIC SUBMISSIONS
General Comment:
Get rid of the 14 hour rule and allow drivers to split off duty time as they see fit. working 14 hours straight wears the driver out more if he's not able to take a decent break in that 14 hours. If he does take a break he is violation if he goes over the 14 hours. Team drivers can't use that rule because it leaves one driver idle for 4 hours beyond their 10 hour break waitting for the other driver to finish his 14 hour shift. It is unhealthy to sit more than 4 hours driving at a time without break and with the 14 hour rule you are forcing drivers to ignore vital health advise.


C. Wayne Emerson - Comments 02/20/2008 PUBLIC SUBMISSIONS
General Comment:
I have been a trucker for many years. I come from a farm background. I have a degree from the University of Wisconsin. I gross $250k annually by myself. I know what I'm doing.
Highway safety is a public good. Laws governing motorist behavior serve us all. The objective of the hours of service rules is lauditory but impractical. One cannot regulate alertness.
Log books serve no more purpose than a data mine for enforcement officers. I have been more alert after a long day than after the first hour. Many times I stop to rest within an hour of a meal stop.
To get things done under the present rules I must continue driving rather than take a safety break because of the 14 hour rule. If I leave Gary, Indiana early in the morning to avoid rush hour in Chicago, go somewhere in Wisconsin to unload and reload then head back toward Ohio under the 14 hour rule I must drive in Chicago rush hour trafic in the evening. Anyone can see getting back near Chicago then stopping for a few hours is far better. This can't be permitted because it requires a split sleeper berth and violates the 14 hr rule.
I will continue to do as I can and make my books look as good as possible. I will first serve my customers. I will do so in a safe and reliable manner. I will not compromise these principles based on stupid regulations.
You should get rid of the 14 hr rule, allow split sleeper berths every other rest stop, continue the 34 hr reset, but extend to 75hrs in 8 days, not 70. If you're going to regulate tiredness, then find a way to do so in a more direct fashion.CW


Anonymous - Comments 02/20/2008 PUBLIC SUBMISSIONS
General Comment:
When was the last time that you drove a truck for 11 straight hours? You probably don't even have a CDL. How can you speak for people that do?


Paul L. Austin - Comments 02/21/2008 PUBLIC SUBMISSIONS
General Comment:
The 11 hr driveing rule is fine.The 34 hr restart is fine. The 14 hr rule is fine. Where the problem is sleeper berth!!! I am not afraid to tell you that teams should be allowed to split sleeper berth. The person that came up with the idea not allowing Teams to split sleeper berth is the one that has lost there marbles,mind,or whatever term you want to use. Myself an my Wife know whats best for us.Not some fool that probably has no idea of whats really going on. Or has not driven 5 &1/2 hrs across a stretch of road thats bad conditions.an thats when your a team operation,you should be allowed to go to sleeper berth an the co-driver drives there 5&1/2 hrs


Ted J. Otis - Comments 02/25/2008 PUBLIC SUBMISSIONS
General Comment:
I belive the 11 hours driving and 34 hour restart are working good the major problem is not being able to stop the 14 hour clock it forces a driver to drive tired and not be able to eat if you shut dow during the day to take a quick nap or do laundry at a time when it is convienient to do so you should be able to stop the 14 hour clock. It would be nice to get the split sleeper back but the most important thing is to be able to stop the 14 hou clock we are not robots and sometimes it is nice to just tack a break during the day the 14 hour clock does not alow you to do that it only add excess pressure on the driver so he has to sit in traffic were as if the clock could be stopped he could pull of the road take a break untill traffic died down . thank you for your consideration to this comment


Mark Nicolia - Comments 02/25/2008 PUBLIC SUBMISSIONS
General Comment:
The HOS that are currently in place are from a safety standpoint have been proved to be effective as seen in the statistics on commercial vehicle crashes.
The 10 hour rest time is a godsend especially to the company and new drivers as the companies cannot push their drivers to drive without proper rest as they did in the past.
However there is one word in the 14 hour rule that if take out would GREATLY improve safety on the highways, the word continuous needs to be removed, we need to be allowed to take breaks without being penalized for doing so, today drivers,especially company drivers are pushed to drive for more hours at a time than is safe they either don't eat for that 14 hours if working because they don't have the time, or eat while driving which isn't exactly the safest either!
Just to stop and stretch your legs or take a power nap if needed is now not an option, once you start your day you have to go, you are rushed to get your drive time done as soon as possible for fear that the receivers will take too much time to unload you so that you can get to a safe place to rest without driving illegally.
I have many times had to sit in a receivers parking lot of if that is impossible I have had to park in some very very unsafe places outside their gates just because I ran out of hours waiting for them to unload the truck and cannot drive to a truckstop or other safe place.
I usually take a nap while they do their thing and then get another 10 hours after they get done so i have had PLENTY of rest.
Another thing with next day deliveries a LOT of times I arrive 6 or 8 hours before they open and get that amount of sleep and then work an hour or so but since I have not had a 10 hour break I now have to start over with another 10 sitting at the receivers, by then it is 7 or 8 at night and I will then drive to a truckstop to get something to eat,be safe and then wait for the next day to get another load, essentially having 2 days and a hour or so on just unloading.
With the word continuous taken out I would be able to get more quality rest, take a nap when I need to, enjoy a decent dinner break getting substance and also refreshing myself at that time, and be able to get to a safe place to get my rest once the load is completed.
the added benefit is that the industry as a whole could be run more efficiently.


Grant L. Morrison - Comments 02/25/2008 PUBLIC SUBMISSIONS
General Comment:
PLEASE KEEP THE 34 HOUR RESTART,AND GET RID OF THE"CLOCK",,,and BRING BACK THE SPLIT-LOGGING(much safer).Thanks for your time


Cher G. - Comments 02/25/2008 PUBLIC SUBMISSIONS
General Comment:
I am a team driver and I don't like the fact that we can't split our shifts in the way we used to be able to. Sometimes my back really aches but I force myself to keep driving because we don't have the time to stop and we can't break the law by changing out ahead of time. Drivers know their own bodies and just as in your job, there are days and times and hours that you function better. One day you may feel like working 11 hours straight and other days you may only feel like work 8 hours. You probably have those options without being penalized. Truck drivers do not.

We like the 34 hour rule. After the 34 hour restart we are well rested and ready to begin again. It would be nice to keep it and yet go back to being able to split our hours after any amount of time as long as the other driver has had eight hours rest.


Mike - Comments 02/25/2008 PUBLIC SUBMISSIONS
General Comment:
On the rules for hours of service. Why not adapt the current rule with the old rules. Keep the now 11 hr drive time , 34 hr restart. Take away 14 hr rule. Give back the drivers right to sleep when he or she is tired.To do this you would haft to allow the sleep time to be broken up. Keeping the 10 hrs, but breaking up into two units with one unit to be at least no less than 3 hrs. This would give drivers a chance to rest when they need to instead of pushing themselves. Drivers are all different, along with sleep habits. We all cant be expected to be the same just because of are job. I feel that this would be a good comprimise,as well as safer for the drivers and public alike.


Joe Hall - Comments 02/25/2008 PUBLIC SUBMISSIONS
General Comment:
HI, fmsca I have over 2 million mile's of safe driving and this is my view's. the 10 hour rule was good,and the 11 hour rule is ok but I don't drive past 10 hour's. But a driver get's tried after five hour's of driving and the abilty to stop for five hour's and take a break would help with the tried issue. Also your split sleeper birth time should be two five hour period's not a two and a eight hour's to get a 10 hour break. But a break of five and five hour's not two and eight is best. Because a driver can get the two hour's most of the time by just sitting at a dock load'ing are unload'ing. This happen's all the time. But a break of aleast five hour's is hard'er to get and most driver's will not be setting at a dock for this amount of time. Also the 34 hour restart should not be change.


Anonymous - Comments 02/25/2008 PUBLIC SUBMISSIONS
General Comment:
I THINK ITS TIME THAT ALL OF THESE OFFICIALS GET THEIR ACT TOGETHER QND GIVE THE DRIVERS OF THIS COUNTRY THE RESPECT THEY DESERVE. THEY ARE OUT THERE DELIVERING THE ITEMS THAT EVERYONE IN THIS COUNTRY USES. IF YOU THINK YOU COULD DO WITHOUT THE TRUCKING INDUSTRY THEN TRY TO BUY YOUR VEGETABLE SEED FROM SOMEONE OTHER THAN YOUR LOCAL STORE THAT HAD THOSE SEEDS DELIVERED TO THEM ON A TRUCK.

IT IS TIME TO GET THE LAWS AND REGULATIONS STRAIGHT. THE DRIVERS HAVE BEEN LEFT IN LIMBO LONG ENOUGH. LISTEN TO THE DRIVERS OF THIS NATION AND NOT THE PERSON THAT SITS BEHIND A DESK 8 HRS A DAY. YOU WOULD LEARN A LOT MORE IF THE FINAL RULE WAS DETERMINED BY THE VOICES OF THE MEN AND WOMEN THAT KEEP OUR COUNTRY ALIVE BY DELIVERING THE ITEMS WE NEED IN OUR EVERYDAY LIVES.


Jeff L. Kull - Comments 02/25/2008 PUBLIC SUBMISSIONS
General Comment:
I like the hours of services the whay it is . i would like to see somthing done about the time that we spend loading and unloading.i pull a hopper and some times it takes 4 to 7 houers to get in to unload. and they don't care how long you sit there. if they had to pay each truck that is whaighting to load/unload by the hour they would get them in and out,so we can make better use of time


Del Grogg - Comments 02/25/2008 PUBLIC SUBMISSIONS
General Comment:
My co-driver and I like the 34 hour rule. After the 34 hour restart we are well rested and ready to begin again.

However, we do not like the fact that team drivers cannot split their hours in five or eight hour shifts. Before that rule was changed, if one of us got tired or was not feeling well we could legally trade out. I believe a driver knows when they need to rest, but when drivers are forced to run a certain way they tend to ignore their own body's warnings. So overall the truck driver is less safe now than they were before the hours of service changed.


Charles A. Srephens - Comments 02/25/2008 PUBLIC SUBMISSIONS
General Comment:
iam aq 54 year truck driver on the hos the 34hr restart is great 11hr is fine but you need to have a way to stop the clock there have been times when your not feeling not well and need to take a couple hr rest then finsh your 11hr the34 whole point is getting the rest i think there should be some of you should spend time in a truck to see what we realy go through


Harold W. Wohlheiter - Comments 02/25/2008 PUBLIC SUBMISSIONS
General Comment:
I would like to see the HOS be set back to the old rule. The new rules do not allow for any adjustment to traffic conditions. ie, under the old rule I might know that if my Load were not ready until 1500 hrs. So rather than set behind the wheel and be tired when I were finally able to leave and only have a couple of hours on the 14 hr rule. A driver could go in the bunk and choose to drive when passenger traffic had cleared up rather than going into traffic after a 6 or 7 hr delay. The old rule allowed for this and worked more to the advantage of the trucking industry. More freight moved in the evening and traffic congestion during daylight hours was less. This could also be acomplished by the elimination of the 14 hr. rule.


JC McCawley, II - Comments 02/26/2008 PUBLIC SUBMISSIONS
General Comment:
To the FMCSA,

In regards to the interim ruling now in affect for the drivers hours of service, I as a driver of nine years and Owner/Operator for three have to put in a vote for these rules to remain.

The majority of the time I rarely take full advantage of the full eleven hour day, but there are times when the shipper and or receiver dictate the need to do so. The best thing that I like is if I get one and a half days off I can reset my log book so that I am able to run legally and safely without having to juggle my body clock to fit what legal hours I have left to run.

I run over the road, but the freight times are still dictated by the shippers and receivers. To run safe and aware each driver has to listen to their own body and run according to their own health. Everyone is different and to let one group of individuals try to dictate how they think the world should behave is to say the least, a bit ludicrous.

In this case I'm not trying to disparage the FMCSA, but the 'Special Interest Groups' that have probably never been in a truck, much less tried to drive to a specific location on a highly regimented time schedule.

Thank-you for your time.
JC McCawley II
CDL holder and voter


Mike P. Gallagher - Comments 02/27/2008 PUBLIC SUBMISSIONS
General Comment:
I LIKE THE RULES NOW, BUT WE SHOULD BE ABLE TO STOP THE 14 HOUR CLOCK FOR REST AND EXERCISE. NOT BEING ABLE TO STOP THE 14 HOUR CLOCK MAKES ME DRIVE TIRED SOMETIMES AND IF I STOP FOR THE GOOD OF SAFETY I'M PENALIZED. WITH THE OLD RULES I COULD STOP THE CLOCK AT PEAK HOURS OF CONGESTION, TAKE A NAP AND ROLL WITH LESS TRAFFIC. CERTAIN STATES CHARGE HIGHER TOLLS AT PEAK HOURS AND I DON'T HAVE CHOICE TO STOP, JUST PAY A HIGHER TOLL. MY BODY WORKS DIFFERENT, SOMEDAYS I CAN DRIVE 10 HOURS STAIGHT, OTHER DAYS 2 HOURS THEN NEED A NAP. ASLO SHIPPERS AND COSIGNES MUST KEEP APPT TIMES. SOMETIMES U PULL INTO A COSIGHNE AT YOUR APPT TIME AND THEN ARE TOLD TO MONITER CB CHANNEL 8 AND WE WILL CALL U WHEN WERE READY FOR YOU, ALL THE TIME U CAN'T REST BECAUSE YOU MAY MISS U CALL ON THE C.B. ALSO WE SHOULD NOT BE REQUIRED TO UNLOAD FREIGHT THEN BEAK IT DOWN AND SORT IT. ALSO COMPANIES ARE COMPLAINING ABOUT DRIVERS WASTING FUEL, WELL WE DON'T HAVE A CHOIVE IF WE HAVE TO SIT IN RUSH HOUR TRAFFIC AND WASTE BILLIONS OF DOLLARS. THX


Don Everson - Comments 02/28/2008 PUBLIC SUBMISSIONS
General Comment:
the only problem I see with the HOS is not being able to stop the 14 hour clock consider this. Starting out with a fresh 14 hours. driver sit at a dock for 2-3 hours waiting to load after leaving shipper then he find a truck stop to scale,fuel,get a bite to eat. Now down the road he goes 4 hours later he feels sleepy and need to pull over for nap he sleeps 3 hours.
3 hours at shipper
4 hours driving
3 hour nap
______________ he now only has 4 more hours he can drive, but my delivery time won't allow him to stop again to finish my required break.so he ends up having to illegally drive past the 14 hour clock to deliver on time.when if he could have stopped the clock slept 8 hours added that to the 3 hours he slept previously,and started out with 11 hours of driving


Todd E. Adams - Comments 03/03/2008 PUBLIC SUBMISSIONS
General Comment:
yes the 14hrs of service.an the 34hrs.restart.are working.the only thing we do need is a way to stop are14 hr.clock to be able to take a break during rush hr traffic
thank you todd adams


Cynthia Martinez - Comments 03/03/2008 PUBLIC SUBMISSIONS
General Comment:
Please reconsider the split sleeper berth provision in the hours of service rules. The ability to split our time in the sleeper gave us so much more flexibility in getting the rest we need at the time that we need it. Some days you need a break in the straight 11 hours of driving. It gives you options of avoiding rush hour traffic in large cities. It gives you the option of taking a sleep or nap break during bad weather driving.

Not everyone sleeps the same every day. Some days you need more sleep. Some days you don't need as much sleep. Everyday is not a day that you want to spend 10 hours in a sleeper berth.

According to the letter of the law you can't even sit in the passenger seat and have a conversation with your spouse or codriver. That action requires us to log on line 4.

According to the letter of the law you cannot leave the truck for restroom breaks. This action could require you to break the straight 8 hrs rule. We ask you to please reinstate the split sleeper berth rule. It gives us so much more flexibility in a days work where no two days are ever the same. I have 19 years of driving over the road and am considering leaving the industry due to the sleeper berth rule. Staying in that sleeper for that length of time is very stressful. Also driving for 10 or 11 hrs. straight knowing that you have no way of stopping the clock if you need to is very stressful.

Respectfully submitted,
Cynthia Martinez
Fresno, CA

Marvin Koester - Comments 03/03/2008 PUBLIC SUBMISSIONS
General Comment:

sir,
i think that the eleven hour rule and thirty four hour rule has nothing to do with being safe on the road. the ones that want these changed just want to work less in a day or a week.

to make the roads safer we need to stop the fourteen hour clock when a driver needs a nap and the shipper has already used up the three extra hours we have and the load needs to get there but the driver is a little tired and has to keep a going. if the fourteen hour clock would stop for a nap then the driver would be more alert to drive.

thanks marvin koester


Anonymous - Comments 03/03/2008 PUBLIC SUBMISSIONS
General Comment:
I think the only thing that needs to be reworked is the split sleeper birth rule. At least the way I understand it. Is that you can not use it unless you take at least an 8 hour break then use what ever is left of you 11 Hr. of drive out of 14 Hr's. If this is true then if a person who has a dead line to make and needs a 2 or even a 5 our nap to make the trip safley they can't because they will be out of hour's. I mean think about it say a person get's a load at 11:00 AM and does a 1/2 Hr pre trid then travels an 1 hr. to get it then spends an 2 hr's to get loaded so now it's 2:30 PM, now they have to deliver the next day by 4 PM. Now they go 1/4 hr down the road to get fuel and weight there truck so there goes 3/4 Hr. Then travel 250 miles in 5 hours so it's like 8:30 PM. So they would like to get something to eat and take a nap what ever just get out of the truck. If they have 200 more miles to go they can't. Because with no break they will get there at 12:30 AM only 30 min. to spear on there 14 and if they take 8 for the split and and 10 for there next 11-14 rule they could not delever un till 6:30 pm. Now if they could split they could go eat, watch a little tv and vist with other driver, take a nap just get a break for up to 5 hrs. and still do there post trip and give them time for there 10 hr. break. Now you have a well rested less stressed driver who got to get something to eat other than what he had in his cooler. It's just a better for everone involved. The way it is now he's in that truck for 29 hr's. exept when fueling were's he going to go when getting loaded and were can he go for the 15 1/2 Hrs. waiting to get unloaded ? Like I keep saing with nothing to realy eat and now they have to do it all again day in and day out. I hope the math works out but I would think you could get my point. I agree that you should have to take 2 hour break to do this. but in some cases I don't see were you couldn't take 2 or more of these if it's what you need to drive safley. That's what it's all about