Comments on: What will this cost? http://archive.regulationroom.org/eobr/what-will-it-cost/?utm_source=rss&utm_medium=rss&utm_campaign=what-will-it-cost 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: Communication: “Fear and Loathing over unnecessary phone calls.” | FreightCaddy.com http://archive.regulationroom.org/eobr/what-will-it-cost/#comment-515 Communication: “Fear and Loathing over unnecessary phone calls.” | FreightCaddy.com Wed, 10 Oct 2012 17:53:39 +0000 http://regulationroomdevelopment.info/eobr/?p=4#comment-515 [...] “On-Board Tracking” see http://www.qcarriers.com/news/nextcommunications.html & http://archive.regulationroom.org/eobr/what-will-it-cost/ which ( at some cost to the carrier ) should, can & does provide those fleets equipped with [...]

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By: The Great EOBR Costs v. Benefits Debate | Xata Blog http://archive.regulationroom.org/eobr/what-will-it-cost/#comment-499 The Great EOBR Costs v. Benefits Debate | Xata Blog Thu, 07 Jun 2012 12:03:26 +0000 http://regulationroomdevelopment.info/eobr/?p=4#comment-499 [...] an affordable option into the EOBR mandate cost equation In estimating the cost of the proposed EOBR mandate, the FMCSA has factored in an average fixed hardware per-unit cost of $1,675. However, as fleet [...]

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By: OMax http://archive.regulationroom.org/eobr/what-will-it-cost/#comment-484 OMax Wed, 03 Aug 2011 18:32:43 +0000 http://regulationroomdevelopment.info/eobr/?p=4#comment-484 I think that before the FMCSA forces the industry into using EOBR’s , they should wait and see what the impact of the CSA brings forth . Many companies are weeding out the bad apples already and improving thier over-all porformance ratings within the CSA guidelines . Before throwing trucking companies that are already having a hard time making ends meet with the high cost of operating , they should at least put this idea on the back burner for at least 2 or 3 years , and see what happen’s with the statistics then . I think the numbers will show from the CSA impact , that the system will work to reduce the numbers .

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By: ryanbarnett http://archive.regulationroom.org/eobr/what-will-it-cost/#comment-439 ryanbarnett Thu, 12 May 2011 22:12:17 +0000 http://regulationroomdevelopment.info/eobr/?p=4#comment-439 At Xata we see benefits to the use of e-logs daily. Here’s 20 reasons:

1. Paper work time savings: it’s simply a pain to keep track of paper logs. XATA often sees 15 to 30 minute improvements in time for filling out the logs in the proper form and manner.
2. Convenience: electronic logs are easier to use than paper through the level of automation provided.
3. Added time in a day: A minimum stop for paper log is 15 minutes; electronic logs can get down to the minute for an accurate stop. If you do many stops in the day, your drive time increases.
4. Detention billing: EOBRs as part of a performance management solution, especially if industry wide, give proof to location and time spent at a shipper’s yard. The biggest criticism to an EOBR is a driver having to start their day on duty while at a dock. In reality, drivers should be starting their day at the dock, and billing the detaining company detention time for lost hours.
5. Ability to prove adherence to Hours of Service laws: Legal truckers can be proud of their safety resume.
6. Interoperability of working with other fleets: an electronic system can help move an O/O from fleet to fleet based on hours available. Send an electronic report to a dispatcher to prove the hours available.
7. Ability to charge higher rates: by showing compliance with HOS laws, and having shippers understand what it takes to be a legal trucker, truckers can charge the rates deserved based on time and distance.
8. Keeping drivers on task: EOBRs can use as a productivity measuring tool. You can measure the time at stops, time on the road, and time in between. These accurate measures help show inefficiencies and time that is wasted.
9. Perception from the public that tracked hours are safe hours: e-logs may not keep you awake, but their use can prove you operate in a legal way.
10. CSA Scores: fleets that use e-logs have better fatigued management CSA scores (Look at XATA’s customer base for proof)
11. Keeping up with potential HOS changes: Based on the complexity of the new rules, and electronic system will help keep a driver straight on what is legal compared to being in violation
12. Proof in an audit: many small fleets will fail an audit. Electronic logs will give support to documentation that paper log books will not.
13. Proof in roadside inspections: Upon seeing the use of electronic logs, many enforcement officials may not go into the details on log books
14. Additional applications from a system: A device running XATA turnpike along side of other applications like ALK CoPilot Truck and email can give truckers tools needed when away from home. Truckers are consumers too – their tools should fit their lifestyle.
15. Reduction in supporting documents: there is an overall reduction in supporting paperwork needed to prove logs or fuel tax. The potential mandate for logs makes this a critical point for adoption.
16. Warnings if time is low: a paper log book doesn’t help a driver know if hours are low. EOBRs quickly show available time left when driving.
17. Ability to move rule sets (e.g. US to Canadian): it’s a flip of a switch and you can run a different rule set and understand how much time is left in what rule set you are in.
18. Document storage reduction: no need to keep old documents.
19. Give peace of mind to the at home contact – many O/Os work in a team – the husband may be driving, the wife keeping track of the books. EOBRs gives O/Os the tools to give visibility into mileage, time, and potential violations.
20. Form and Factor: Many current violations are from form and factor mistakes, which can be as simple as someone not writing down a line. These simple mistakes are virtually eliminated.

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By: dinsmoretransportation http://archive.regulationroom.org/eobr/what-will-it-cost/#comment-412 dinsmoretransportation Fri, 29 Apr 2011 20:22:33 +0000 http://regulationroomdevelopment.info/eobr/?p=4#comment-412 It is becoming apparent that there is no discussion of whether the EOBR should or should not be required and one can only assume that this means everyone will be required to purchase these units.
Providing any form of cost-savings calculations tends to be moot as those calculations are based on data that, if anything, can only be described as ‘generalized’ or ‘median’, with no real accounting for the myriad differences in carrier size, operating costs, or budget.
If this discussion truly is over and now we are simply trying to find a way to swallow it all in one gulp, I would have to believe that there is little or no point in any further discussion.

Let me be direct here:
Requiring EOBRs doesn’t make sense to the majority of CMV operators on the road. Not only doesn’t it make sense, but the costs associated with what many believe to be unnecessary and pointless are incredibly high.
There is an obvious connection between the forced implementation of the EOBR and Qualcomm and other device manufacturers, for the FMCSA based its calculations on the company’s product.

If anyone can provide evidence linking Qualcomm to any public servant, government official, interest group, or lobby, please let everyone know.

It can’t quite be accepted by the majority that they are to purchase something due to safety if the only incentives in doing so lay with the manufacturers and all disincentives fall into the laps of those most effected by the negative financial consequences of purchasing said devices.

That being said, can anyone out there see if we are essentially backed into a corner (those of us against the use of EOBRs) or if there still is a fighting chance to stop this?

I feel that what we are seeing now is the quieting down of discussion about whether or not we should use the recorders, and we are now moving onto how we will purchase specified units.

WHEN we are ultimately forced to buy these things, will there be any incentive, any immediate incentive, to the carriers and drivers in any form, and how quickly will Qualcomm see profits from this? How much profit will we see on the news at night while people struggle with the expense of these units?

Re: Digital TV Antennae
The government helped people buy television antennae. Will they also help people purchase these EOBRs?

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By: gordon http://archive.regulationroom.org/eobr/what-will-it-cost/#comment-409 gordon Thu, 28 Apr 2011 19:18:41 +0000 http://regulationroomdevelopment.info/eobr/?p=4#comment-409 I’ll try this again, this time without typos to make more readable.

Let me suggest a way to make this more palatable to the massess: Offer a reduction in safety scores if companies voluntarily go to an EOBR system. 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 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. The goal of any program should be compliance, not punishment. A score over 60 in the HOS acts as punishment. While I still think that the figures (safestat scores) don’t accurately reflect what is going on, I understand that fighting with the bureaucracy is futile. I think FMCSA could offer a carrot to get EOBR installed and would earn the FMCSA some good will with the industry. This program can’t be punishment only. Even in my company safety program I offer rewards and punishments. Maybe its time for FMCSA to take a page out company playbooks and reward those who are willing to play at a higher standard.

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By: gordon http://archive.regulationroom.org/eobr/what-will-it-cost/#comment-398 gordon Wed, 27 Apr 2011 13:08:13 +0000 http://regulationroomdevelopment.info/eobr/?p=4#comment-398 In response to your question about big truck companies: 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 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 can be seen as an impediment to drivers, who are barely making it now. EOBRs 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.)

I am retired from the Army, and I can tell you that in no other business have I seen such an egregious concern for those doing the work.

No driver would willing work long hours if he can make a decent living in a shorter time. Make sure that all their hours are compensated and they will stop violating HOS.

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By: virgil tatro http://archive.regulationroom.org/eobr/what-will-it-cost/#comment-393 virgil tatro Wed, 27 Apr 2011 00:42:22 +0000 http://regulationroomdevelopment.info/eobr/?p=4#comment-393 thanks patrick, your point is one i was trying to make, for not only small trucking companies and owner ops but for farmers and custom harvesters like your self. I am a former custom harvester as well..

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By: Rebecca http://archive.regulationroom.org/eobr/what-will-it-cost/#comment-390 Rebecca Tue, 26 Apr 2011 16:30:29 +0000 http://regulationroomdevelopment.info/eobr/?p=4#comment-390 Could you share more details about how big truck companies can affect prices and how this will impact small businesses?

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By: gordon http://archive.regulationroom.org/eobr/what-will-it-cost/#comment-388 gordon Tue, 26 Apr 2011 15:56:26 +0000 http://regulationroomdevelopment.info/eobr/?p=4#comment-388 Moderator – you have thrown the question back to rdb on how to self regulate. He gave you a real answer – use real science to develop real methodologies.

But I suspect the entire problem. Fatigued driving has been said to be a significant cause of accidents. We, the public have bought this. Merely because the government says so, does not make it so.

As rdt says, these are political decisions, not necessarily safety.

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