The Federal Motor Carrier Safety Administration is asking truck drivers to submit their thoughts and comments regarding the possible reform of Hours of Service regulations.

As of Friday, August 31st, over 1,100 people had left their comments but the Owner Operator Independent Driver Association wants ore drivers to participate so that trucker’s voices can be heard.

“We want all professional truckers to actively participate in the hours-of-service reform process. This is an opportunity to shape the regulations that impact drivers every single day,” OOIDA Manager of Government Affairs Mike Matousek said.

The potential HOS reform comes after several petitions submitted by the OOIDA asking the FMCSA to allow drivers to stop their 14 hour clock for up to three consecutive hours, allowing them a “nap time” during the day if needed without taking away from the 11 total hours they are permitted to driver per day. The OOIDA’s petitions also request that the required 30 minute break be removed from the HOS, as it may force a trucker to stop when he or she doesn’t truly need to.

Another petition submitted by Trucker Nation requested that the FMCSA allow truckers 14 total hours of driving time, not including breaks, instead of the current 11, and also asked that drivers be allowed multiple break periods of three hours or more per day, rather than a required 10 consecutive hours off the road, which can often be a waste of time for drivers.

Other petitions submitted include one regarding a two hour extension for drivers who encounter bad weather, traffic, or other adverse driving conditions.

Though anyone is welcome to submit their thoughts, the FMCSA says that they will only consider comments related to the following questions:

1. Short-haul operations.
*Do you have any data to show that extending the 12-hour period for the short-haul exception to the records of duty status/ELD requirements to 14 hours would change the safety performance of carriers using the short-haul provision?
*How specifically would a 14-hour period change your driver or carrier operations as compared to 12 hours?
*What would the incremental change be for your operations/business if the exemption was changed to 14 hours? For example, would your operations expand or would your drivers/carriers move from non-exempt status to exempt status. What would be the economic impacts of that incremental change?

2. Adverse driving conditions.
*Is there adequate flexibility in the existing adverse driving conditions exception?
*How often do you currently utilize the adverse driving conditions exception?
*What are the economic impacts of the current exception on your driver or carrier operation?
*Should the definition of adverse driving conditions be changed?
*Should the adverse driving exception apply to the 14-hour workday window, not just the 11-hour driving limit?
*How would the above changes affect the economic costs and benefits, and the impacts on safety and fatigue of the adverse driving conditions exception?

3. The 30-minute break.
*If the 30-minute rest break rule did not exist, would drivers obtain adequate rest breaks throughout a daily driving period to relieve fatigue?
*Are there alternatives to the 30- minute rest break that would provide additional flexibility to drivers while achieving the safety benefit goal of the current 30-minute break?
*If a rest break is retained, should it be taken off-duty or on-duty while the driver is not driving?
*How does the 30-minute rest break affect the efficiency of operations from a driver’s or a carrier’s perspective?
*How would your suggestions affect the costs and benefits of the 30-minute break?

4. Split-sleeper berth.
*FMCSA has announced a proposed flexible sleeper berth pilot program. Beyond the information that will be collected in the pilot program, do you have any information that would support changing the current requirements?
*Are there alternatives that would make the sleeper berth options more effective or less costly?
*How often do you use the sleeper berth option currently; how would this change with your suggested regulatory alternatives?
*What cost impacts and safety benefits would result from different split-sleeper berth options?

5. OOIDA Petition.
*What specifically would change about your driver/carrier operations by extending the 14-hour driving window?
*Is there a likely increase in safety risk from extending the 14-hour driving window? For example, would altering the current rule allowing 14 hours on duty and 10 hours off duty interfere with drivers’ circadian rhythm? Could driver health be affected?
*Would a potential increase in safety risk be lessened by the requirement that all the additional time beyond 14 hours must be off-duty time?
*Would allowing OOIDA’s request for an extended break during the work day improve safety by allowing drivers to increase the total amount of off-duty time during and immediately following the work from 10 hours and 30 minutes to 13 hours, without reducing the maximum driving time available within 14-hour window?
*Are there other flexibilities or other nonsafety benefits that could be realized if the 14-hour window is extended?

6. Trucker Nation Petition.
*Is there a likely increase in safety risk from eliminating the consecutive 14-hour driving window? For example, would the absence of a limit on the length of the work shift – the time between the driver coming on duty after accumulating the minimum of 10 hours off-duty and the driver being prohibited from driving – combined with splitting the required 10 consecutive hours off-duty into a number of segments, interfere with drivers’ circadian rhythm? Could driver health be affected? Please provide data on the costs and benefits of this approach.
*Are there other flexibilities or other nonsafety benefits that could be realized if the 14-hour window is eliminated?

To answer these questions electronically, you can click the link here.

All comments are due on September 4th and can be submitted electronically here, or mailed in to:

Docket Management Facility
U.S. Department of Transportation
Room W-12-140, 1200 New Jersey Ave. SE
Washington, DC 20590-0001

With the Docket ID number (FMCSA-2018-0248) included.

Comments can also be faxed to 202-493-2251 with the same Docket ID number attached or turned-in in person to the U.S. Department of Transportation building, Room W-12-140, 1200 New Jersey Ave. SE, Washington, D.C. Monday through Friday 9:00 a.m. to 5:00 p.m.