Comments on: Who would have to use an EOBR? http://archive.regulationroom.org/eobr/use/?utm_source=rss&utm_medium=rss&utm_campaign=use The Federal Motor Carrier Safety Administration (FMCSA) is proposing to require that electronic on board recorders (EOBRs) be used instead of paper logs for recording commercial motor vehicle (CMV) drivers’ hours of service (HOS). All long haul operations and some short haul operations would be affected. Carriers would have 3 years to comply. Also, proposed new standards would make clearer what supporting documents carriers must keep to back up drivers’ logs. EOBR-users would get a break on supporting documents. Wed, 10 Oct 2012 17:53:39 +0000 hourly 1 http://wordpress.org/?v=3.5.1 By: Millise1 http://archive.regulationroom.org/eobr/use/#comment-451 Millise1 Wed, 18 May 2011 17:38:28 +0000 http://regulationroomdevelopment.info/eobr/?p=1#comment-451 As a safety consultant/educator I am in contact with many small business operators using small CMV’s. Many of these operations use a CMV to transport their goods 5 or less times a month. It simply is unreasonable to make a universal mandate that would include a small business using a truck 5 times a month or one who travels within less than a 100 mile radius. Limiting the scope of the carrier type required to use the EBOR would make the most sense.

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By: Millise1 http://archive.regulationroom.org/eobr/use/#comment-450 Millise1 Wed, 18 May 2011 17:32:20 +0000 http://regulationroomdevelopment.info/eobr/?p=1#comment-450 The option that would best serve the short haul industry [in my opinion] would be to define thresholds, 2 or more out of 7 days on the road would be reasonable. That threshold would remove landscapers, farmers, septic system businesses, carpenters and other typical small businesses using trucks over 10,000 lbs but less than 26,000 lbs from the costly burden of EBOR requirements.

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By: virgil tatro http://archive.regulationroom.org/eobr/use/#comment-441 virgil tatro Fri, 13 May 2011 01:56:30 +0000 http://regulationroomdevelopment.info/eobr/?p=1#comment-441 after alot of reading and contacting numerious trucking companies and even trying elogs i still vote no to the eobr rule. NO EOBRS!!!!

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By: Chele http://archive.regulationroom.org/eobr/use/#comment-438 Chele Thu, 12 May 2011 03:54:21 +0000 http://regulationroomdevelopment.info/eobr/?p=1#comment-438 I feel that there is a place for EOBR’s. You are already using them where I feel they make the best sense! On drivers & company’s that have a very bad habit of disregarding the HOS & Safety Rules. To mandate them on Every truck is punishing (financially, morally,& ethically ) those who have already proven that we obey the laws the FMCSA have on the books.
This mandate will do less for safety , and more for the industry that produces and maintains the records! We DO NOT need more Big Brother!

The government & FMCSA are so busy regulating the DRIVER, that they are going to put us out of business at this rate!

Being a Owner-Operator I know trucking is NO 9 to 5 job! We have to be flexible in so many ways the average person could not believe. This is no dreamy job, no great adventure. We work long hours, do hard outdoor labor ( I run a Step Deck trailer) in every kind of weather, we have loads of paperwork to keep up to date. We also need to eat, sleep, shower, house keep, maintain our equipment, & relax, for we have a high stress job.

So you ask what can the FMCSA do for the Trucker? Well here are a few areas that the FMCSA, the government & states need to do some changing!

#1. We need safe places to park for our down time & rest periods!
People sure want their products BUT 85% of them DO NOT want the trucks in their communities. We are human being! When its 85* outside in the sun its 110* to 125* inside our trucks, there are times we need to idle! I am all for the end of unnecessary idling! Not only is it a waste of fuel & money, its just not smart! The solution is a APU unit, well have you ever parked next to one with your windows open?? They are vented to the passenger side of trucks, so the exhaust comes right into the truck next to them. Its really not easy to sleep with APU exhaust pouring into your truck. It brings fatigue to a whole new level.

#2. We need quit being a major source of revenue!
The laws & rules we have to abide by are left to interpretation. That means there is very little consistency in how & when they are applied. They need defined nation wide so everyone enforces the SAME Rules.

#3. There needs to be rules for detention time on the books!
No matter what kind of freight you move there is alot of sitting time both at the shipper & receiver that is basically unpaid time. Now you tell me your time is free?? If your at work you expect to be paid right? We rarely get paid for our detention time. It also can greatly eat into our available time for working.
Thus making it so we have to break the rules to get the freight where it needs to be, and pushing a 14 hr day is tough!

#4. Transparency of the shipping contract!
1. from point of shipment to the
2.carrier/driver to the
3.receiver/customer paying the freight bill
This would do a great deal to balance out the pieces of the pie. I know it would cut the costs of moving freight, and in due cut the cost of goods to the consumer! While the FMCSA is so busy regulating the driver of the truck they do nothing to support the drivers on a whole. Here’s a example: Say a shipper ( Caterpillar for example) has a order of 50 bobcats, he calls a Broker, the says ok I can move these 10 loads for $3.50 a mile including the fuel surcharge. Now these loads start in NC, they are all going to the state of TX., but various destination city’s in the state of TX. Now that Broker puts those loads out there on a load board ( ITS, GetLoaded, LoadMax, ect.) He posts these loads for say $1.75/ml. now out of the 10 trucks he hires or books these loads for @ $1.75/ml he is making as much as the trucks moving the freight ($3.50-$1.75= $3.50). Now I don’t know about you but I have yet to see a brokers office that meets or exceeds the overhead cost of operating a Tractor Trailer! We not only pay a outrageous cost on fuel ( on a average a Tractor Trailer gets @ 5.5 to 6. miles per gallon of diesel @ a cost of $4.20/gallon that is $.75 to $.82 per mile just in fuel costs) , highway tax, road use tax, repairs, leasing of/payment of our equipment, normal repairs, both Cargo & Truck/Trailer insurance ect. On a whole a driver that owns all his equipment, needs a average of $2.00 to $2.10/ mile to pay all costs, and have a paycheck for securing these loads, driving them to the destination in a timely manner , All the while living on the road, eating truckstop or fast food, being away from home and family!

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By: vganster http://archive.regulationroom.org/eobr/use/#comment-437 vganster Wed, 11 May 2011 01:05:13 +0000 http://regulationroomdevelopment.info/eobr/?p=1#comment-437 The fact that some drivers have grown to appreciate some of the benefits EOBRs have to offer has nothing to do with whether or not they should be mandated in every truck.
Every driver in the country could absolutely love them, and that still would not be reason enough to require them to be installed in every truck.
Personally, I am opposed to any mandate, but can see the benefits for requiring the carriers with a long history of HOS violations to use EOBRs. Outside of that, the choice of whether or not to equip a truck with an EOBR should belong to the carrier or truck owner.

Again, I have no personal experience using an EOBR since I am not a truck driver. Anecdotally, I can say that the majority of HOS violations are not due to driving more than ten or eleven hours per day. Rather, the HOS violations I have been able to observe have related to time a truck spends sitting while waiting to load or unload. This is not something EOBRs can effect any change in, since, again, they cannot tell what a driver is doing when the truck is not moving.
Another bigh cause of logbook falsification is to allow a driver a break that would not be doable under the regulations while still allowing the driver to meet any deadlines.

EOBRs would be effective against this type of falsification. However, I’m pretty sure I would rather they weren’t. If a driver is feeling ill, wants to avoid the stress of rush-hour traffic, or simply has an off day and needs a rest break, the EOBR will be there telling them that they’d better keep moving if they want to meet their appointment time.

I’ll take the driver who chooses to take the break and fudge the book anyday over a driver with the same deadline pushing through while remaining perfectly compliant.

Again, I cannot stress enough that the FMCSA cannot have it both ways. The reasoning behind revisiting the HOS yet again is that they cannot be conclusively proven to increase highway safety. Therefore, increasing compliance with those HOS CANNOT be for the purpose of improving safety.

Even if they could conclusively prove a correlation, fatigue-related truck accidents make up only a small percentage of truck-involved accidents. Nothing about a sweeping mandate of EOBR technology makes any sense.

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By: jbh249 http://archive.regulationroom.org/eobr/use/#comment-436 jbh249 Tue, 10 May 2011 21:29:35 +0000 http://regulationroomdevelopment.info/eobr/?p=1#comment-436 Vganster, another commenter whose company uses EOBRs says that drivers had some issues with them at first, but after using them for a while grew to like them (you can read the comment here). Do you have experience with EOBRs that leads you to a different conclusion? If so, what has that experience been like?

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By: vganster http://archive.regulationroom.org/eobr/use/#comment-435 vganster Tue, 10 May 2011 16:55:41 +0000 http://regulationroomdevelopment.info/eobr/?p=1#comment-435 Well, if the FMCSA cannot prove that the HOS increase safety, then it cerainly cannot prove that compliance through brute force ala EOBRs will do anything, either.

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By: vganster http://archive.regulationroom.org/eobr/use/#comment-434 vganster Tue, 10 May 2011 14:20:41 +0000 http://regulationroomdevelopment.info/eobr/?p=1#comment-434 Moderator,
You mention that the FMCSA does not have the authority to regulate haul rates. While that is true, you cannot neglect the fact that the regulations the FMCSA does implement have the potential to affect significantly the rates drivers and carriers receive.

You ask people to provide hard data to back up their opinions on EOBRs. That’s brilliant because when this is all said and done, the FMCSA will be able to say that no one could provide such data. Of course they can’t! They’re truck drivers not statisticians.

They know that EOBRs will affect their livelihoods negatively, but cannot show you in your “hard data” terms why that is. All they can do is tell you, and keep telling you, that they don’t want the darned things in their trucks. Part of that is because the results may not be measurable in dollars and cents, or even in safety statistics. Rather, the effect of EOBRs and other “safety” regulations can be measured mainly by the quality of life of the driver who has already seen their standard of living and their quality of life decline significantly over the last few decades.

EOBRs are intended only to increase compliance with HOS. Yet, in the proposed rulemaking and cost/benefit study for the HOS the FMCSA itself admits the Hours of Service cannot be considered the cause for the recent decline in truck-involved fatalities and injuries. The FMCSA also admits that it cannot reliably measure the impact of HOS regulations or compliance on highway safety.

The conversation should go no further. If we don’t know that the HOS save lives, then we CANNOT know whether or not increasing compliance with them will. As soon as we reach this realization, the idea of tracking the movements of every truck driver in the country should be taken off the table.

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By: crusin http://archive.regulationroom.org/eobr/use/#comment-433 crusin Tue, 10 May 2011 00:38:02 +0000 http://regulationroomdevelopment.info/eobr/?p=1#comment-433 I don’t need to or want to run for any more than the 11 hours….

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By: crusin http://archive.regulationroom.org/eobr/use/#comment-432 crusin Mon, 09 May 2011 19:14:47 +0000 http://regulationroomdevelopment.info/eobr/?p=1#comment-432 BOTTOM LINE…
YOU GOTTA BE AN IDIOT TO RUN FALSIFIED LOGS…1 ACCIDENT AND 2-5 HEAVY TRUCK INVESTIGATORS + ILLEGAL LOGS+ SERIOUS PROBLEMS…
WHO WOULD BE THAT STUPID?

Me personally…I drive for my allotted time…11 hours…rest the correct amount of hours…then `run the next day for 11…

I need to or want to run for anymore crazy hours..

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