How to make effective comments on hours change

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Updated Sep 17, 2018

One of the minor notes struck by Ray Martinez about the exciting hours of service revision is that, in the end, there’s no guarantee anything will be revised. The Federal Motor Carrier Safety Administration chief at least has been clear that his agency indeed wants plenty of feedback.

Kevin Rutherford, a popular host of a satellite radio trucking program and longtime presenter of Overdrive’s Partners in Business seminars, makes a good point about providing exactly the kind of insights that will help FMCSA make smart changes.

Drivers shared their thoughts on changing the hours of service during a listening session at the recent Great American Trucking Show in Dallas.Drivers shared their thoughts on changing the hours of service during a listening session at the recent Great American Trucking Show in Dallas.

“It’s not the time to argue, or debate, or even discuss hours of service anymore,” Rutherford wrote to Overdrive. “It’s time to show the FMCSA that there are hundreds of thousands of professional truck drivers and business owner that know how to get the job done!”

He adds “that the agency will only move on hours reforms if it receives the feedback and data necessary to do so … Nobody wants to read long stories about your HOS problems.”

Rutherford offers these tips on submitting comments by the Sept. 24 deadline:

Be clear and focused on the four areas they are considering:
— Extending drivers’ daily 14-hour clock by two hours, should adverse conditions arise.
— Adding split sleeper berth flexibility to hours regulations.
— Nixing the 30-minute break requirement.
— Allowing short-haul drivers to operate 14 hours in a day instead of the current 12-hour allotment.

Take your time and craft a clear and concise comment:
— Check it multiple times for spelling, grammar, punctuation and clarity.
— Have someone else, even multiple people, read it.
— Use to help. It’s free.

For those not interested in commenting on each of the four areas Martinez says are under consideration, Rutherford offers a blanket statement to send, as is or modified:

“I feel strongly that the FMCSA should add split sleeper berth flexibility to hours regs. This will allow professional drivers to use their own best judgment in operating safely while continuing their mission of moving America’s freight in a timely and efficient manner.”

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The simplest way to comment is online.

Or, listing docket number FMCSA-2018-0248, write your comments. They can be faxed to 202-493-2251 or mailed to:

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

Though this is strictly an agency matter at this point, Rutherford also recommends contacting your representatives in Washington, D.C.

Working through Congress and FMCSA didn’t yield any results when the battle was on repealing the electronic logging device mandate. There was little to no support in D.C. for that, but there is for fixing the hours rule.

Martinez recognizes what the industry has also come to grasp: ELD use magnifies problems with hours, which is the root of ELD opposition. He appears genuinely interested in solving those problems. His agency set a 30-day comment period for the proposed rulemaking, which he calls the “very aggressive.” And it is, considering proposed rules’ typical 90-day comment periods.

“We’re doing that to send the message that we want to move on this,” Martinez says.

This could be the regulatory change that affects your daily life more profoundly than any other for years to come. Don’t miss the chance to draw upon your valuable experience and make your voice heard.

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