Comments on: What about supporting documents? http://archive.regulationroom.org/eobr/what-about-supporting-documents/?utm_source=rss&utm_medium=rss&utm_campaign=what-about-supporting-documents 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: Trucking http://archive.regulationroom.org/eobr/what-about-supporting-documents/#comment-425 Trucking Tue, 03 May 2011 15:54:24 +0000 http://archive.regulationroom.org/eobr/?p=118#comment-425 Ok Mr moderator lets go to the world of if. In 2009 there were approximately 3300 lives lost related to CMV. Now lets assume that a lot of what I have read is right that 80% of all cmv accidents are caused by the passenger vehicle., so that makes at fault deaths at approximately 264 deaths tied to at fault with trucks. So now The FMCSA says the fatigue rate is 15% in which I do feel is BS however lets go with it that makes somewhere in the area of 40 deaths because of fatigue driving. Now I do under stand that 1 life is to many. But the FMCSA is more about ending a truckers freedoms then they are about safety.

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By: patrick http://archive.regulationroom.org/eobr/what-about-supporting-documents/#comment-323 patrick Mon, 04 Apr 2011 08:52:39 +0000 http://archive.regulationroom.org/eobr/?p=118#comment-323 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 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 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 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 is guilty of HOS violations unless they prove without a resonable doubt they are innocent.

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By: Truckdriversnews http://archive.regulationroom.org/eobr/what-about-supporting-documents/#comment-319 Truckdriversnews Sun, 03 Apr 2011 17:50:55 +0000 http://archive.regulationroom.org/eobr/?p=118#comment-319 Moderator, the keyword I am focused on is “believes” I can do the same thing. I “believe” that the number is lower than 10-15% – so who is right?

At any cost to the driver – without any “real hard evidence – is uncalled for. This is the whole entire problem with the FMCSA, DOT, NTSB, etc. they all believe that by adding another regulation on top of regulations – and making drivers buy these “magical EOBRs” that all will be safer on the already safe interstates and highways.

Adding EOBRs will do nothing but add expenses to under paid truck drivers and companies.

Drivers are not robots that you can program to sleep or get up when FMCSA says so. Here in the US we have advanced a little in technology but “Technology Can’t Detect a Tired Trucker”

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By: Moderator http://archive.regulationroom.org/eobr/what-about-supporting-documents/#comment-318 Moderator Sun, 03 Apr 2011 03:36:32 +0000 http://archive.regulationroom.org/eobr/?p=118#comment-318 Thanks for your comment, truckdrivernews. Check out FMCSA’s analysis of EOBR Device Costs to see what the agency thinks and whether you agree. You can also comment on what you think EOBRs will cost your business specifically here. Your comment will be most helpful if you draw on personal experiences or specific data.

The fatigue-related accident rate you mentioned came from slide #21 of a webinar by Ralph Craft of FMCSA. Here is what he has to say: “The NHTSA Driver Related Crash Factors are those coded by police at the at the crash scene. Everybody agrees that this number is severely under reported by law enforcement officers. FMCSA believes the real number for fatigue in large truck crashes is in the range of 10-15%. Industry groups claim the number is lower, and safety advocates believe it is higher.”

What do you think? You can read FCMSA’s analysis of fatigue-related crashes in detail
here.

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By: Truckdriversnews http://archive.regulationroom.org/eobr/what-about-supporting-documents/#comment-312 Truckdriversnews Mon, 28 Mar 2011 02:12:10 +0000 http://archive.regulationroom.org/eobr/?p=118#comment-312 Moderator: So, the EOBR does work automatic, it still does not change my view about the whole EOBR deal. Besides, I did not see anything in the comment about how it has made his driving any safer.

My primary concern is FMCSA falsifying its own information to make it seem that new regulations and such are needed. Plus, adding yet another COST to the trucking company or owner operator – without a positive reasoning.

FMCSA has said that only 1.4% of the trucking accidents were fatigue related in 2009.

So why are EOBRs needed? Seems like a complete waste of time and money, at a time that money is tight for everyone. And with the announcement of another Cross-border trucking program, money will be even tighter.

By the way – FMCSA announced they where going to pay (Actually tax payers will be paying) for the EOBRs for the Mexican trucks. Is FMCSA prepared to pay for the EOBRs for US trucks?

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By: Trucking http://archive.regulationroom.org/eobr/what-about-supporting-documents/#comment-281 Trucking Wed, 16 Mar 2011 20:37:59 +0000 http://archive.regulationroom.org/eobr/?p=118#comment-281 You ask how I feel that the EOBR will make the roads safer? They won’t, at best the accident rates will stay the same. A driver is going to be giving an ETA to the receiver that is going to be mathematically possible time wise with out much extra to spare, forcing a driver to be more aggressive in order to even have a chance of making it, and will constantly be detracted by stressing over time. The FMCSA are discussing making it illegal to handle a cell phone in a truck calling it a distraction. Now they are going to force another piece of electronics in your cab in stead. Also what is going to happen when a driver can not find a parking spot after searching for an hour for a spot and his eobr says you are now driving in violation what are you going todo park on a get on ramp and get a ticket. Safer we will see but I think it is away for somebody else to get in a truckers pocket.

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By: Rebecca http://archive.regulationroom.org/eobr/what-about-supporting-documents/#comment-278 Rebecca Tue, 15 Mar 2011 19:38:12 +0000 http://archive.regulationroom.org/eobr/?p=118#comment-278 According to grldbarnes, a driver who says he uses an EOBR for work, says that his EOBR “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.” You can read his full comment here.

What do you think about his take on how EOBRs work?

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By: aristo http://archive.regulationroom.org/eobr/what-about-supporting-documents/#comment-258 aristo Tue, 08 Mar 2011 00:02:18 +0000 http://archive.regulationroom.org/eobr/?p=118#comment-258 EOBR are costly in the sense that they offer no ROI for the operator. While they may reduce some of the administrative cost(s) for a large operation, they will only create an unnecessary layer of responsibility for the small operator; one that is already being adequately filled via log books and proper enforcement procedures. Tech providers and support personnel will be the true beneficiaries of an EOBR mandate, just like the input producers and retailers have been the true beneficiaries of the restrictions placed on the word ORGANIC by the USDA and Big Agri-Business – NOT THE FARMER. Reading your replies makes me wish that I could give you an in-depth, guided tour of this business that brings you your life each day. You would be surprised at how honest and efficient most people are in the face of nearly overwhelming odds, and how completely unnecessary the deployment of EOBR technology is for all but the most habitual offenders of the HOS rules. I refer you to my initial comment.

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By: Trucking http://archive.regulationroom.org/eobr/what-about-supporting-documents/#comment-237 Trucking Fri, 04 Mar 2011 16:46:47 +0000 http://archive.regulationroom.org/eobr/?p=118#comment-237 When we go to the EOBR, will we as drivers need to carry travelling papers to be legal the way a communist country If this wasn’t so serious it would be funny. How anybody can put a computer in your truck to make sure that one is doing what the government says is legal. And this is not a violation of the fourth amendment. Then those amendments only mean what the government says as long as it support them. SO drivers make sure you have your travel papers handy, who’s next the family going on vacation. Freedom in the united states is slowly disappearing, people had better look around it’s not only trucking that is being controlled by government.

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By: Truckdriversnews http://archive.regulationroom.org/eobr/what-about-supporting-documents/#comment-203 Truckdriversnews Mon, 28 Feb 2011 22:11:58 +0000 http://archive.regulationroom.org/eobr/?p=118#comment-203 While I could not agree more that “clearer rules” are very much needed. I do not agree with this EOBR rule.

FMCSA, NTSB, NHTSA, and DOT all have said that adding this pricey mechanical device will make the roads safer. How?

This device will only know what information the driver puts into it. It will not record automatically – it still requires the driver to manually put in information.

How is this different from paper logs?

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