What are these?
A lot of commenters recounted personal experiences in explaining their reaction to FMCSA’s EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) proposal.  We’ve gathered those experiences here.  They are organized by the name of the issue post they appeared in.  The initial description comes from the commenter’s response to the registration survey.

Who would have to use an EOBR?

A long haul/short haul haz mat driver: “I drive for Wal Mart and use EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) it is a wonderful tool for the type of driving I do. However I think it will put a lot of hard working drivers out of business. Unless some rules are changed and enforced, The wait time loading and unloading will kill them. Also the time waiting for dispatch to give them thier next load will be a problem. You can not help with the latter but the loading and unloading is a major problem for drivers. I have sat a grocery store wharhouse for up to ten hours waiting to get unloaded, when I was on time and did my part. With EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) this would kill my driving hours…”

A long haul generally, >150 mi. from base for property carriers owner/operator leased to another carrier: ”I had a long conversation with an inpector at a Weigh station on I94 east of St paul Minnesota. I often request an inspection of my truck/trailer and this paticular day he and I had a long conversation about HOS.. It was really neat how he and i had the same Idea On the hos and what they are truly about.”

A long haul/short haul haz mat owner/operator leased to another carrier: “the company i am leased to has not come out with have not come out with firm numbers but estimates are in the 1200 to 2000 dollar range with a WEEKLY charge of 40 to 60 dollars. I have been an owner the company that owns the rights to repayment of the mortgage principal plus interest operator A self-employed commercial truck driver or a small business that operates trucks for transporting goods over highways for its customers for over 12 years now and have seen my bottom line drop to almost nothing.”

A long haul/short haul haz mat owner/operator leased to another carrier: “I have 5 csa points and they are over a paper work issue that I was told that I could have had erased but i didn’t appeal it in time but at the time that this issue came up there was no way to appeal it.  so it isn’t like I am not a compliant driver and not only do I resent being punished because of the few bad apples in this industry, I cannot bear the weekly cost of the monitoring but the cost of buying this monstrosity will take the money I have saved for a vacation for me and my wife,the fist we have been able to plan in over 5 years because of the slim profits that have been able to generate.”

An interested member of the public: “Anecdotally, I can say that the majority of HOS Hours of service (Regulations issued by FMCSA that limit the number of daily and weekly hours a CMV driver may drive) violations are not due to driving more than ten or eleven hours per day. Rather, the HOS Hours of service (Regulations issued by FMCSA that limit the number of daily and weekly hours a CMV driver may drive) violations I have been able to observe have related to time a truck spends sitting while waiting to load or unload.”

A long haul/short haul hazmat driver: “I have been using EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) for 5 years now, it took a little time to get use to. But now that I have gotten use to it, it’s like a lot of new technology you can’t live with out it. There is a very major down side to it though, in oder to make money you have to keep moving. You need to address the drivers time lost to loading and unloading.”

A long haul/short haul hazmat driver: “Like I said love using it and could not be without it now. The simple fact that everytime you change status you are not reaching for a log book. It figures your hours automaticaly, you just have to look at it and you know where you are on your 11 and 70. Ours is set so once you start your day any time you shut off the truck you go on duty, and once the truck starts moving again you go back to driving. You do have to manuelly change to off duty but that is no big deal. The only real down side is at the end of the day, last driving hour we have a count down timer. You want to drive as far as you can each day, but you can not go over so you need to start looking for a place to park. Many nights I have shut down with 40 or 50 min. of drive time left because I was 1 or 2 min. short of making the next safe place to park. With a log book you would get to that last safe place wink wink., but that is the only real down side. As I said I drive for Wal Mart now and 90% of our stops are drop and hook. Our dispatch is real good about giving you your next move before reach your last stop. So EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) works real well for us, but I can see drivers having to do live loads and unloads having major problems with it. Drivers will complain but they always due when something new comes out. But once they use it for a while I think they will like it. Really makes DOT Department of Transportation inspections easy, DOT Department of Transportation officer looks over your electronic records and sends you on your way. No questions about what this is, or these hours don’t add up. Everything is right and readable, I have never had one officer question anything on my Electronic logs.”

A long haul/short haul driver who has used an EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) or other similar device: “I work @ sunset logistics in FT WORTH, TX. We are already using the EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) but since we have a day and night crew, we are having to wait anywheres from 1 to 4 hours for an available truck just to log in to begin or daily HoS. The company says it is how it is done and we just have to “suck it up” as drivers and “grow up”. I have a friend that works for a major food supply chain that uses the EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) and they have one in the drivers room to log in when you arrive to start your HoS. I feel my company is abusing the rules by telling us we have to wait for a truck to log in and the wait time we use before logging in just doesn’t count towards any on duty time. And if i run a paper log, which they absolutely hate for us to do, i will not have enough time to complete my loads for the day. And for instance, one occasion i had a break down and my truck was broke down for several hours leaving me with exactly 5 hours of driving and on duty time left. When i finally got back to the yard, I was told to get in another truck, log into the peoplenet (EOBRElectronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road)) and i will have a full daily HoS to complete my run. I have asked the safety DEPT about this but got the usual “i will look into it” as he heads off to the break room…. I am sure it is not right but am just asking. Maybe somebody will see this and let me know who’s right and what steps i need to take to protect my lively hood.”

A long haul/short haul driver who has used an EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) or other similar device: “not necessarily, we run a 12/15/8 cause we are aggregate, intrastate. You can just as easily log out and move the truck. Some company’s do have the alarm that doesnt go off till the truck is shut down. but my point was, when we cross the state line, we go to 11/14/10 and the system doesnt change it from 12/15/8 or gives me the option to change it. What i do is go off my paper log when i cross the state line or when i have down time before i can log in or whatever and adjust my remaining time accordingly. my issuse is i am getting grief @ my job for doing so and am getting written up on some occassions cause my company is taking advantage of the rules and bending them in their favor.”

A long haul generally, >150 mi. from base for property carriers owner/operator leased to another carrier: “Ok here I sit tonight in reed point Montana. i am only driving part time, as i have a mining job that i am employed at full time awaiting these redicoulous rules.. If they are passed I will never drive a truck again but i love trucking so i am doing it part time.. Ok i just took a trip to red deere alberta canada.. I am sampeling AN e-log, as i said i am sitting on an exit ramp in Reed Point Montana, 16 miles from my home and I have to sit here for 10 hours before I can legally drive the 16 miles home.. I could legally unhook from my trailer and drive home, Personell conveyance.. but not with an electronic recorder.. so ill sit here on this exit ramp for 10 hours and then drive the 16 miles to my home.. makes alot of sence.”

A CMV Commercial Motor Vechicles owner/manager with ten units: “I harvest grain from Texas to Montana. Most of my trucking is on rural roads and exempt from HOS Hours of service (Regulations issued by FMCSA that limit the number of daily and weekly hours a CMV driver may drive) rules under 395.1k. However there are between 10 and 15 days a year where I operate under RODS. Requiring EOBRs Electronic on-Board Recorders (Devices attached to commercial motor vehicles that track the number of hours drivers spend on the road) for carriers that infrequently have to log hours will be a substantial addition burden in both cost and complexity of use than what over the road carriers will face under this rule. When I am moveing under RODS Record of duty status (A logbook maintained by CMV drivers to track driving time (i.e., duty status) for each 24-hour period) there is very low probability of violating HOS. I am moving in convoy with up to 10 units and pulling oversized loads which can only move in daylight hours. All of my RODS Record of duty status (A logbook maintained by CMV drivers to track driving time (i.e., duty status) for each 24-hour period) trips except one is less then 440 miles. The EBORs rule is a one size fits all rule. Motor carriers People providing motor vehicle transportation for compensation. The term includes a motor carrier’s agents, officers and employees are not all over the road haulers carrying freight everyday across the country. There are a lot of utility trucks, farm trucks, and pickups that will be swept into this EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) rule even though most of their miles do not require RODS.”

A long haul generally, >150 mi. from base for property carriers trucking business owner/manager who has used an EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) or other similar device: “I just talked to a Ms. DOT Department of Transportation officer who told me that a large carrier who allows 6 mo. old drivers to become trainers often come in with their EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) logs that are all messed up, ie both drivers on duty, wrong driver on duty ect. So I dont believe EOBRs Electronic on-Board Recorders (Devices attached to commercial motor vehicles that track the number of hours drivers spend on the road) will solve this problem.”

A long haul/short haul driver: “I’ve sat in a loading dock for 13hrs before and then I had to be at my delivery site in 10hrs. I couldn’t sleep while in the dock because the truck would shake everytime the forklift loaded another pallet.”

A long haul/short haul driver: “I’ve sat in the dock in Georgia, stuck because they were running their operations from my truck. Consequentially, I was down for a full day. Interacting with some shippers/receivers, I get the impression that they are concerned about putting in their time but not responsible for the stray driver that missed a pickup/delivery.”

An independent owner/operator: “I had a State Police Officer tell me to my face that he was ‘writing a many violations as possible to keep myself employed as a State Police Officer’…”

A long haul generally, >150 mi. from base for property carriers owner/operator leased to another carrier: “i admit to violating the hos rules at times but only to get to a safe place to park or to beat the storm. whats the point in stopping when its raining at 33 degrees and the forecast is for tempuratures to fall and everything to turn to ice in just a few hours when you are perfectally able to continue for a little longer and make your destination without driving in the ice etc. i have to add that our truck is a 1988 model peterbilt, non electronic. I recently removed all of the decals from it, as it sits beside of our garage waiting for the out come of these potential changes. do you know that as an rv i can drive this truck non stop. i am 37 years old and was homeless as a child for twenty years living with my family as transients, we are on page 44 of the book into the wild and kristen stewart plays my sister in the movie. as a child my only dream was to be an otr trucker and to have a home. in 2008 i lost my 2003 kenworth due to fuel cost and an ilness my wife had. now i own a 1988 pete and can not wait to be trucking again. but with these proposed rules it will all be gone.”

A trucking business owner/manager with 70+ units who has used an EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) or other similar device: “Most of our drivers accepted the change as no different than paper logs, understanding that this is the nature of the industry. We have drivers that have been with us from anywhere between 1 to 30+ years. A few at first refered to it as the ‘egg timer on the dash board’ – but after using it for a few months and learning the software I haven’t had a single complaint. In fact, when there are computer problems or a driver needs to go to temporary rental unit they complain that they have to keep paper logs again! Our fleet A group of motor vehicles owned or leased by businesses or government agencies is actually 100% EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) and have been for almost a year. We gradually introduced them to our team and we work with our entire fleet A group of motor vehicles owned or leased by businesses or government agencies so that they are fully capable of using them with confidence. There has been no issue in terms of safety either. We also have had a 100% satellite tracked fleet A group of motor vehicles owned or leased by businesses or government agencies for some time and this is a natural addition to this feature. Perhaps the difference is that we are deeply committed to our team and that’s why we have had success with EOBRs? I would like to think so.”

An owner/manager of a trucking business who has used an EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) or other similar device: “You are going to create a monster by expemting SH short-haul: generally, < 150 mi. from base for property carriers carriers. Large long haul generally, >150 mi. from base for property carriers companies will adapt to take advantage of the SH short-haul: generally, < 150 mi. from base for property carriers expemtion. Example, I have terminals nationwide. I take a load from California, move it to my terminal within my SH short-haul: generally, < 150 mi. from base for property carriers limits drop it and another truck picks it up and does the same thing. By doing this I can get a load across American faster than a LH long-haul; generally >150 mi. from base for property carriers company, Because some of my “short Haul” drivers will be able to cheat their logs. You have now created an unlevel playing field between the SH short-haul: generally, < 150 mi. from base for property carriers and LH long-haul; generally >150 mi. from base for property carriers companies.”

A safety consultant with one vehicle who has used an EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) or other similar device: “I work with these people every day in the capacity of a safety consultant. They do not need any more items that will cost them money or confuse them.
I have also seen the results from these items and they are confusing, and hard to audit. The system can be easily fooled and will just cause more problems than good.”

A long haul generally, >150 mi. from base for property carriers independent owner/operator: “I have been pulled over for various things and pulled in for inspections and have very rarely been asked to see my logbook. I had one DOT Department of Transportation officer in Texas say I don’t know how to read it so I don’t want to see it.”

A long haul/short haul driver: “Everywhere i get inspected, its a level 3, If you been out here long enough…”

A long haul generally, >150 mi. from base for property carriers owner/operator leased to another carrier: “I must add1 i Parked my truck in 2008 because my wife had a possible lifre threatening illness.. she is in good health now and I hope to soon be back on the road.. the problem Here is, we have a totally reconditioned 1988 peterbilt truck.. It is non electronic and will not support an EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) Thus making our truck worthless.. While I have been off the road I have been Mining in an underground Mine.. let me tell you about my day..I get up at 4:00am leave home at 5:00am drive an hour and fifteen minutes to work (one way) attend a half hour meeting. and then we work 12 hours underground, in heat and darkness like you have never seen..underground from 7;00am to 7:00pm then drive one hour and fifteen minutes back home usually in ice and snow.. and rotate days and nights every 7 days..about 16.5 hours per day I do this 24 days per month.. and I have no HOS Hours of service (Regulations issued by FMCSA that limit the number of daily and weekly hours a CMV driver may drive) or EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) to tell me I can not.. Between my brother and myself we have four Million miles with zero accidents. and i got my very first speeding ticket in october of 2010 coming home from hunting with my son, 40mph in a 35 zone.. Please No EOBRS. and if we must have HOS Hours of service (Regulations issued by FMCSA that limit the number of daily and weekly hours a CMV driver may drive) Leave them as they are..I Love my family first and trucking comes next.”

A long haul generally, >150 mi. from base for property carriers owner/operator leased to another carrier: “Truckers are treated like criminals.. I am a hard working family man.. Have adopted two children and been married 20 years.. I have been harrassed by Inspectors at scales! Been woken up at night and told by the Highway patrol that i had 10 minutes to move my truck or it would be towed! Thus putting my in Violation of the HOS Hours of service (Regulations issued by FMCSA that limit the number of daily and weekly hours a CMV driver may drive) rules.. I could write a book about this.. an eobr will never be in my truck.”

A long haul generally, >150 mi. from base for property carriers owner/operator leased to another carrier: “I hear and read alot about enforcement, everytime I have ever been pulled in to a scale or pulled over, and that has only happened three times in my two million miles i have always had my log book checked.. What is rediculous is that i was actually ticketed in south dakota at a scale for not having signed my log page for the day.. Now i had just started the day at Sioux Falls just a few miles ago, my log was current and everything was as it was supposed to be. I just had not signed it yet. I should not have to sign it untill the end of my day when my log is then complete!”

A long haul generally, >150 mi. from base for property carriers owner/operator leased to another carrier: “I have ran with electronic logs and many times when The HOS Hours of service (Regulations issued by FMCSA that limit the number of daily and weekly hours a CMV driver may drive) or the e-log said i could legally drive I had only been able to sleep a few hours because I ran out of driving time to early in the day to sleep.. so when the HOS Hours of service (Regulations issued by FMCSA that limit the number of daily and weekly hours a CMV driver may drive) and the E-log said I could drive my common sence told me to sleep a while longer.”

What about privacy concerns?

A long haul generally, >150 mi. from base for property carriers haz mat owner/operator leased to another carrier who has used an EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) or similar device: “i had an 18:00 appt., my 14 hrs were up at 21:30,i thought that would be plenty of time to unload,at 01:30 they were done and told me i could not stay on the property,the nearest safe haven was 1hr. away. i would like to know how i would put that into an eobr?”

A long haul generally, >150 mi. from base for property carriers owner/operator leased to another carrier: A driver “will have to stop when the eobr says times up rather then making it just a few more miles to a safe place, etc. I had this happen running elogs in bad weather i had to shut down 16 miles from home because my time was up.. i had to park in reed point montana i only live 16 miles from there, but due to weather conditions and the elog i could not drive home.”

A long haul generally, >150 mi. from base for property carriers owner/operator leased to another carrier: “I talked to a Montana highway patroll officer today and they can not even access an eobr they have no software for them and no means of even checking them.”

A long haul generally, >150 mi. from base for property carriers driver: “In Canada we get to claim a per diem of $54.00 for every 24 hours we are away from home and claim that amount against our total income at the end of the year. I currently draw this information from my paper logs. Will employers be required to give us an electronic copy or paper copy of log sheets monthly or at the minimum yearly?”

A long haul generally, >150 mi. from base for property carriers owner/operator leased to another carrier who has used an EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) or other similar device: “Yes I understand that DOT Department of Transportation cops are not suppose to brake the law in order to enforce the law. When is the last time you seen a dot cop parked on an over pass using lazier to catch speeders. Over passes have a no parking zone, so tell me they are not breaking the law to catch speeders. Or parking on the shoulder of the road in which is emergency parking only to catch speeders. They also have a way of stretching their heads in your window to take a look around your truck. Yes the EBOR to some is just away to enforce the HOS Hours of service (Regulations issued by FMCSA that limit the number of daily and weekly hours a CMV driver may drive) laws. It is the FMCSA Federal Motor Carrier Safety Administration (The agency proposing the EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) rule) distrust of drivers, and have totally lost the trust of owner the company that owns the rights to repayment of the mortgage principal plus interest operators Self-employed commercial truck drivers or small businesses that operate trucks for transporting goods over highways for their customers and the little guy. So you see moderator you see law enforcement as angles, I see them as a tax collecting arm of the government. And no I am not radical I have seen some real sad tickets to me and others, and the sad thing is they know that is easier and cheaper to just go ahead and pay the fines.”

A long haul generally, >150 mi. from base for property carriers haz mat owner/operator leased to another carrier: “I found the one I used, Peoplenet worked very well, and took alot less of my time keeping a paper log.”

A long haul generally, >150 mi. from base for property carriers owner/operator leased to another carrier: “…an eobr can and will be used to force a driver to drive when he or she is not rested.. using a qualcomm system i have in the past been awakened at night only to have my dispacher tell me my 10 hours is up and i need to get going. he has no idea how long i had been asleep or resting just that i had been sitting for 10 hours and woke me up at 2;30 am sayin i had to go ive sat my 10 hours.. now how will an eobr make this better.. as an owner the company that owns the rights to repayment of the mortgage principal plus interest operator A self-employed commercial truck driver or a small business that operates trucks for transporting goods over highways for its customers using no qualcomm and paper logs i slept as long as i wanted and they didnt know the difference.”

A long haul generally, >150 mi. from base for property carriers haz mat owner/operator leased to another carrier: “I had my dispatcher at Melton Truck Lines in Tulsa Oklahoma both send me a QualComm and Call me on the phone in the middle of my 10 hour break and wake me up to ask me how long before my break was over. I told here 10 hours from right now, because you just interupted my 10 hour dot break. Then I hung up on her, turned off my phone and unplugged the QualComm! I quit that Sorry job 2 weeks later. They don’t want drivers, they want robots”

A long haul generally, >150 mi. from base for property carriers haz mat owner/operator leased to another carrier: “the only way a driver makes any money is when the truck is moving. If the shipper or receiver holds you up, you’re not making a dime. So you either fix the logs, or go broke, It’s that simple.”

What will this cost?

An owner/manager of a trucking business with seven units: “As per the “cost savings” it is very badly estimated. $27 and $29 an hour savings is not a very realistic figure and you’ve already mentioned that some drivers are not compensated by the hour or compensated to complete their logs. That’s definitely true in my fleet. $27/29 is probably overestimated by as much as 17-19 dollars an hour in some places. You’re much closer on the RODS Record of duty status (A logbook maintained by CMV drivers to track driving time (i.e., duty status) for each 24-hour period) forms estimate.”

Long haul driver and employee of an equipment manufacturer/supplier who has used an EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) or other similar device: “I use the JJ Keller system for my EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) rules. It meets FMCSA Federal Motor Carrier Safety Administration (The agency proposing the EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) rule) rules for EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) use. it costs $199.00 for the GPS Global positioning system (A space-based global navigation satellite system that provides location and time information anywhere on Earth) tracker and $6.00 a month to use. the system uses a smart phone to log and compute your hours. whats nice is that you can use the phone as your cell phone. the system will not let you text while truck is moving over 8mph.”

A short haul generally, <150 mi. from base for property carriers independent owner/operator: “I am already contemplating getting out of trucking because all I can afford is a million mile truck and all I get paid is usually just enough to pay my bills. If the fuel goes up in price, like it did last week 18 cents in one week, my fuel surcharge takes 3 or 4 weeks to show up and if fuel goes down my fuel surcharge drops immediately. I’ve done this 44 years and I’ve never known anything but getting screwed by every entity that I have to work with. It appears to me that the US government wants American trucking to cease operating and be taken over by foreign interests that will work much cheaper and be much less safe. I’m old enough to not care anymore.”

An owner/manager of a trucking business: “We have eight trucks on the road. Keeping paper logs is a no brainer. What the regulators need to appreciate is that us smaller company have less flexibility in rates we charge. We, more than any other sector are subject to wims of the free market. This would be much more palatable were the federal government to treat us like the proposed law to allow Mexican truckers into the US and pay for the devices. JB Hunt, CR England, ETC can more easily hide the device expenses in the cost of doing business. We small guys can not.”

An owner/manager of a trucking business: “I, for one, did not understand the implications of CSA 2010 and did not appreciate the fact that every single violation on a log book would add to my company’s fatigued driving score. Hence, I was not as strict with my drivers as I should have been on things that were not out of services. As of December I found myself being hammered for fatigued driving for such things as not having a BOL listed on the form or not having total miles on the log sheet. I would bet that if FMCSA Federal Motor Carrier Safety Administration (The agency proposing the EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) rule) allowed a rollback of some, or all of the points for fatigued driving, that many companies would jump at the chance and voluntarily begin EOBR.”

A long haul generally, >150 mi. from base for property carriers owner/operator leased to another carrier: “i have seen ppl playing with these things when driving have talked to ppl that showed me that you can lie to them and they can show you moveing when you are not these things are a way for the OTR Trucker to go under.”

An equipment manufacturer or supplier: “Having implemented many GPS Global positioning system (A space-based global navigation satellite system that provides location and time information anywhere on Earth) solutions over the last several years I am aware of the investment numerous small and medium size companies have made. I work with businesses to find the solution that meets their objectives so I am familiar with several solutions. For the most part, businesses invested in GPS Global positioning system (A space-based global navigation satellite system that provides location and time information anywhere on Earth) to ensure efficient dispatching, monitoring activity, and provide accurate customer service. The objective was not regulatory compliance as it was not mandated at time of purchase. That now changes and in almost all cases my customers now have tracking devices that will become obsolete. Not in functionality, but in compliance.”

A long haul/short haul independent owner/operator: “the cost savings are incorrect. I buy 12 log books a year at approximately $1 each for a total of $12 per year. Since I fill out , file, etc., the RODS Record of duty status (A logbook maintained by CMV drivers to track driving time (i.e., duty status) for each 24-hour period) myself there are no other costs.”

An owner/manager of a non-trucking business with ten units: “I am a Custom Harvester with 10 units that fall under RODS Record of duty status (A logbook maintained by CMV drivers to track driving time (i.e., duty status) for each 24-hour period) requirements for less than 15 days a year. The rest of the year they are either not in use or do not have a GVWR requireing RODS Record of duty status (A logbook maintained by CMV drivers to track driving time (i.e., duty status) for each 24-hour period) or are operating from exemption of HOS Hours of service (Regulations issued by FMCSA that limit the number of daily and weekly hours a CMV driver may drive) under 395.1k. So requireing EOBRs Electronic on-Board Recorders (Devices attached to commercial motor vehicles that track the number of hours drivers spend on the road) on these units for 15 days a year of use under FMCSA Federal Motor Carrier Safety Administration (The agency proposing the EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) rule) estimate costs $785 per year would be $52 a day. This is a substantial cost over a paper log sheet costing cents a day. With the 10 units it will cost me $520 dollars a day to move. All but 2 days a year I have to use RODS Record of duty status (A logbook maintained by CMV drivers to track driving time (i.e., duty status) for each 24-hour period) I average less than 350 miles a day. So while moving my 10 units in convoy the use of EOBRs Electronic on-Board Recorders (Devices attached to commercial motor vehicles that track the number of hours drivers spend on the road) is going to cust me $1 to $1.52 a mile. To any reasonable person this is a highly burdensome cost.”

An owner/manager of a non-trucking business with ten units: “My employees are on salery so time for compleating RODS Record of duty status (A logbook maintained by CMV drivers to track driving time (i.e., duty status) for each 24-hour period) is not direct cost.”

An owner/manager of a trucking business: “Your cost estimates for paper record keeping are way high for smaller companies, where the owner the company that owns the rights to repayment of the mortgage principal plus interest does everything. It is a pain for me to keep paper logs, but I can do it between other things and keep up. And driver time submitting is a non-starter. They tear them out of the book and fedex them to me along with BOLs.”

A long haul/short haul independent owner/operator: “I own a one-man one-truck trucking company and I only spend about $12 a year on paper log books to comply with DOT’s Hours of Service (HOSHours of service (Regulations issued by FMCSA that limit the number of daily and weekly hours a CMV driver may drive)) regulations. Over a ten-year period, I will spend about $120, the DOT’s proposal requires me to spend $7850 over a ten year period. That is a 6442 % increase. Also, their figures have clerical staff (I don’t have any) making between $27-$29 per hour. Good work when you can get it, but I don’t know of any small trucking companies that are paying anybody those kind of wages. I have been inspected for hours of service Regulations issued by FMCSA that limit the number of daily and weekly hours a CMV driver may drive violations by DOT Department of Transportation 6 times in the past 18 months and have never been cited for being over my hours of service. My $12 per year program must be working.”

An owner/manager of a trucking business: “I have had drivers working for me who have told me that they have used EOBRs Electronic on-Board Recorders (Devices attached to commercial motor vehicles that track the number of hours drivers spend on the road) and that it is possible to cheat on them as well. EOBRs Electronic on-Board Recorders (Devices attached to commercial motor vehicles that track the number of hours drivers spend on the road) know when you are driving, but not necessarily when you are working and not driving.”

An owner/manager of a trucking business: “Here is the nature of the business today: The biggest companies control most of the freight. They don’t haul the freight, but they book the freight, and haul it with their trucks, or rake some off the top and pass the loads down to smaller companies.

“The reality is that there is little connection between the company paying for the hauling and the company doing the driving. What this means, then, is that smaller companies struggle to make ends meet in several ways. Smaller companies:
– Often must accept lower rates – the cmpanies booking the freight take 25% off the top for the joy of passing paper around.
– Are often abused at shippers and recievers. Because there is little connection between trucker and shipper – truckers are often unable to demand payment for extended delays at the shipper or receiver.

“The single biggest impediment — BY FAR — to drivers being able to make a living at trucking — is delays at loading and unloading docks. Freight brokers have no incentive to pay truckers for delays – which often can amount to a day or a night – because they don’t have a connection to the trucker. Imagine sitting at a dock waiting for a load for 6 hours and not getting paid for that. Imagine waiting even 2 – 3 hours to get loaded and then needing another 1 – 2 hours to rig and tarp a load. Shippers are not required, nor do they feel any compunction to pay for this time. As a result, drivers often refuse to log this time because they must turn miles. No miles, no pay.

“This is in my experience, is the biggest impedement to fatigued driving. If shippers take up 25% of a driver’s vailable work time – the driver must make up for it by pushing the limits of his or her endurance.

“If FMCSA Federal Motor Carrier Safety Administration (The agency proposing the EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) rule) were serious about fatigued driving, it would find the root cause of drivers driving too long and solve that. Drivers don’t want to driver around the clock – but often must do so to make a living.

“In this age of just-in-time logistics, companies ought to be able to forecast transportation requiremens and understand when to have trucks made available.

“Now back to the larger companies: larger companies sign contracts with customers that spell out such things as loading/unloading times, tarping fees and other special charges. When the big company can’t haul the freight with its own trucks, it brokers the load. However, contracts between drivers and brokerages that spell out delays and other assessorial charges generally does not exist. Some companies will pay a nominal fee – litterally nominal – and others either pocket the money, or refuse to charge the original customer.

“If a driver is working, he should be paid. Failure to pay for detention, frequently causes drivers to drive longer than they ought.

“So, an EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) can be seen as an impediment to drivers, who are barely making it now. EOBRs Electronic on-Board Recorders (Devices attached to commercial motor vehicles that track the number of hours drivers spend on the road) potentially punish the driver for doing what he has to do to make a decent living. What about the company that takes a driver’s time, but refuses to pay for it?

“In our small company I have dealt with this numerous times. The standard (if there is such a thing) in the industry is to give a shipper or receiver two hours of time to load and unload. But, if at the two hour mark I call the broker and complain, I usually hear something like: “I’ll call the shipper and see about detention.” This is a kiss-off. My choices are to wait or to pull the truck off the load and look for something else. If I choose the latter course, then I wast time looking for a well paying load and then fuel and time moving the truck to the new shipper and again, starting the clock.

“A signficant step toward ensuring that drivers don’t drive fatigued is ensuring that drivers can make a decent living during the legal hours available.

“And, by the way, this also includes numerous time that a company calls for a truck which sits from 2 p.m. to 5 p.m. only to learn that the load is unavailable. Some brokers might offer to pay truck not used of $150. This amount does not even begin to cover the expense of loosing an afternoon and night of production. (The problem is that by the time the company learns the truck has been ordered and can’t be used, it is too late to book another load.)”

What about supporting documents?

An owner/manager of a non-trucking business with ten units: “Private carriers like myself do not generate as many supporting documents as are required. My trucks transport my own equipment from farm to farm in the western US and rarely see urban areas or interstate coridors where more suporting documents can be generated. Most feuling is done a day or more in advance to a RODS Record of duty status (A logbook maintained by CMV drivers to track driving time (i.e., duty status) for each 24-hour period) trip and the trip is compleated before feuling is required again. We rarely stop at truck stops since they are not tipically on our routes. Most purchase receipts , port of entry permits, and scale tickets are only date stamped not time stamped. We travel in convoy so all expense receipts are recorded as one receipt for 10 drivers. What advantage we do have is the management responsible for the collection of documents and a compliance review is also travelling with all the drivers using RODS. So lack of mangement control of drivers HOS Hours of service (Regulations issued by FMCSA that limit the number of daily and weekly hours a CMV driver may drive) violations is imposible since our management is traveling with our drivers and in control of generating suporting documents. Most of these documents are for other operations in a business so copies will have to be made to keep them in a seperate file to be sure they are avalible for a compliance review. This substancially increses the size and cost of the file required for HOS Hours of service (Regulations issued by FMCSA that limit the number of daily and weekly hours a CMV driver may drive) duty records. I do not think the additional costs of maintaining these records have been considerd.

“In general the type and specificity of the suporting documents required are imposible to ubtain and out of the drivers power to require the details be provided. Once again this regulation assumes that the driver and motor carrier A person providing motor vehicle transportation for compensation. The term includes a motor carrier’s agents, officers and employees is guilty of HOS Hours of service (Regulations issued by FMCSA that limit the number of daily and weekly hours a CMV driver may drive) violations unless they prove without a resonable doubt they are innocent.”

Would penalties/enforcement change?

A long haul generally, >150 mi. from base for property carriers driver and employee of an equipment manufacturer/supplier who has used an EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) or other similar device: “I put my records on a dvd monthly stored at home. It is part of the service i get with my JJ Keller unit. the JJ Keller unit costs $199 for the GPS Global positioning system (A space-based global navigation satellite system that provides location and time information anywhere on Earth) sender, $6.00 a month to use on a smart cell phone. All the smart phones out there now can do the EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) thing and talk at the same time. You can not text while vehicle is moving with this system. It costs me $75.00 a month for everything on my phone.”

A long haul generally, >150 mi. from base for property carriers driver and employee of an equipment manufacturer/supplier who has used an EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) or other similar device: “You are able to use the cell phone and have it do the EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) thing at the same time. All smart phones are able to do that now. The new Iphone will be able to do 3things at a time. if im at a truck stop i go off duty and take my phone with me the unit only logs trk movement. there is an off duty driving on the system so you can move trk up to 20min if needed at trk, home, or you want to go to the movie. the rule is you can do this but it cannot be used to further commerence. (you must return to your start point or you will be charged the time driving. The system knows i’v tried to beat it and lost.) While not happy 100% with system it works great, DOT Department of Transportation likes it. The pnly problem with the system is the fact it is always legal as far as driving. if you are in a traffic jam in LA at rush hour you could loose 3hours going only 50 miles.”

An owner/manager of a trucking business with eleven units: “[T]he truck that delivers that will be shut down due to HOS Hours of service (Regulations issued by FMCSA that limit the number of daily and weekly hours a CMV driver may drive) because shippers hold them in docks for hours on [end] waiting on the product to be done to ship. I have worked as a Driver Manager and Account Manager for several large companies. They keep up with this stat and history of loading and unloading times. If we are going to enforce this EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) we have to change the log rules yet again to let drivers adjust their logs for this as well as many other delays. If my driver starts his clock at 8am. sitting at a dock and doesn’t get loaded till 1pm, and is supposed to be 500 miles overnight to deliver the next morning they have no time left to drive that. Causing the load to be delayed by a day and then the shipper cutting our rates for not delivering on time when it was their fault for not getting my driver out in a timely manner.”

A long haul/short haul owner/operator leased to another carrier: “These would only work in a perfect world where there isn’t traffic or weather or breakdowns or anything else that a driver has to deal with on a daily basis. What if for instance you go to a shipper who screws you a round for 6 hours while they load you and then you can’t make delivery you just lost a day of income who is going to make that up? What if that happens twice in one week there goes two days of income that you need to operate your business.”

When would this take effect?

A long haul generally, >150 mi. from base for property carriers truck driver who has used an EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) or other similar device: “Three years is too long. 1. Any and all carriers that do not have EOBRs Electronic on-Board Recorders (Devices attached to commercial motor vehicles that track the number of hours drivers spend on the road) have a distinct advantage over carriers that are already using EOBRs. I have a friend working for a company and his company can make promises to customers about delivery times that our company can not because those drivers still have more flexibility in being able to turn in log sheets that look legal even though they do not match the exact schedule that they operated. On the other hand, having EOBRs Electronic on-Board Recorders (Devices attached to commercial motor vehicles that track the number of hours drivers spend on the road) has taken all the pressure off the drivers where I work to meet impossible scheduled delivery and pick up times and put that responsibility back in the office where it belongs and has forced the company to talk to shippers and explain to them why we couldn’t run the way we used to and to get better flexibility from the shippers and then it was up to the office staff to run the trucks efficiently so the trucks would pay for themselves and as a result, more often than not now I am making bigger pay checks than with the old operating system and I am getting more rest than ever. My friend can not always say the same.”

A long haul generally, >150 mi. from base for property carriers truck driver who has used an EOBR Electronic on-Board Recorder (A device attached to commercial motor vehicles that tracks the number of hours drivers spend on the road) or other similar device: “I used to be a miss-used, used, and abused driver by several companies that I have worked for. And although I always passed every DOT Department of Transportation logbook inspection, I had many times been running so illegal it was ridicules. I did get fired from one job after I refused to run illegal anymore. Then I reported my getting fired to the Whistle Blower Program that turned out to be OSHA. A lot of good that did me. OSHA doesn’t do logbooks. So the next company I went to work for, it was business as usual. If you want to make a decent paycheck, then run. What ever it takes. Now I run out of hours for any reason: breakdown, traffic, construction, accidents, etc. not my problem. Amazingly enough, I still have the same problems on the road today but now I am not stressing over still making my pick ups and deliveries on time. And rarely does the company have to reschedule. It took them a while to acclimate themselves to a new way of doing business and some people had to be replaced because they could not adjust, but I would rather go to work for McDonald’s than go back to the old way of doing business.”