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jks38

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February 24, 2011 8:24 pm

Thanks for the comment, pkcamper! Do you have links to the articles you mentioned? Has anyone else found that the information collected by the EOBR could be easily changed?

February 24, 2011 8:26 pm

Have other commenters been stopped by officers who didn’t check their logbooks? If so, do you agree that having officers actually check the logbooks would increase compliance with the HOS rules?

5 culvers, do you think FMCSA made a mistake in calculating the costs, since for them the benefits outweigh the costs? Go back to the Costs post and let us know where you think there are errors.

February 24, 2011 9:57 pm

You raise an interesting point about how the proposed EOBR rule would affect carriers that use older, non-electronic trucks. Do you think the rule would be better if carriers with these older trucks were not required to use EOBRs, but drivers with newer trucks were required to use EOBRs?

It sounds like you might have something to say on a different proposed rule on HOS. You can let FMCSA know what you think on that rule here.

February 24, 2011 10:00 pm

It sounds like you agree with pfifreight and new creation transport that other key players involved in the shipping process (like dispatchers and receivers) should be held more accountable for their roles. What should the FMCSA do to address this problem? Could EOBRs help? If you think the best solution would be to change the hours of service rule you can tell the DOT that here.

February 25, 2011 8:39 pm

If anyone is interested in the article that pkcamper is referring to you can find it here: http://www.landlinemag.com/Archives/2011/Feb11/News/OPED-EOBRs.shtml

March 5, 2011 1:40 pm

Thank you for returning to Regulation Room grldbarnes. As an experienced EOBR user, could you explain what you feel the benefits of using an EOBR are? Besides your argument that loading and unloading time issues need to be addressed by the DOT, do you see any other downsides to using an EOBR?

March 5, 2011 3:00 pm

Motingator, FMCSA doesn’t have the authority to regulate haul rates. Do you have any specific suggestions regarding the proposed EOBR rule?

March 7, 2011 10:19 am

mikeakakrazy, do you think requiring EOBRs would make enforcement easier for officers and make enforcement stops shorter? You might want to go over to the Penalties & Enforcement post and see how the proposed rule wants to handle those types of problems.

March 8, 2011 1:25 pm

Trucking, smart phones are not at issue in this proposed rule. However, some commenters have suggested that smart phones are capable of doing what an EOBR does, but can do it cheaper. Are you suggesting that you agree or disagree with this?

The most effective comments explain why the agency should or shouldn’t do something. Providing new information or a suggestion can be helpful. To learn more about the rulemaking process and effective commenting click here.

March 11, 2011 1:12 pm

Thank you for your comment frns! We understand that you disagree with requiring this rule for all CMV drivers. We appreciate your research into the cost considerations and ask that you visit our cost post (http://archive.regulationroom.org/eobr/what-will-it-cost/) and comment again after looking at this additional information on baseline data changes: http://archive.regulationroom.org/eobr/agency-documents/regulatory-impact-analysis/#0.1__Toc283386171 And, more specifically, one of the baseline pieces of data that has changed since 2003 is the % of crashes that were fatigue related (now 13%, up from 7%… more »

…in 2003): http://archive.regulationroom.org/eobr/agency-documents/regulatory-impact-analysis/#0.1__Toc283386184.

Also, in response to your question about who supported expanding EOBR use, we suggest you look at the final rule published April 4, 2010 (http://www.fmcsa.dot.gov/rules-regulations/administration/rulemakings/final/On-Board-Recorders-for-HOS-Compliance.pdf) where FMCSA includes an overview of the responses they received during the comment period. They specifically mention the National Safety Transportation Board and you can read their comment here: http://www.regulations.gov/#!documentDetail;D=FMCSA-2004-18940-1164.1. « less

April 11, 2011 12:19 pm

packrat74871, the FMCSA has said that EOBRs are meant as a tool to increase HOS compliance and that increasing HOS compliance could increase safety by decreasing driver fatigue. Do you disagree with this argument? Do you believe that law enforcement officials alone could increase HOS compliance without the need for EOBRs?

April 12, 2011 10:44 am

Jdnutt, FMCSA has said that they are now proposing this rule in order to increase safety. Do you think that using EOBRs would increase HOS compliance and therefore increase safety?

If you are interested in the FMCSA’s cost/benefit analysis visit our Costs post.

April 19, 2011 9:08 pm

Thetruckingva, do you think that the training programs you discuss could work better than EOBRs to increase safety? What do others think about thetruckingva’s suggestion?

April 20, 2011 9:27 pm

Okcarhauler, it sounds like you want to comment on the FMCSA’s “Pilot Program on NAFTA Long-Haul Trucking Provisions.” In that proposal, the FMCSA discusses the issue with Mexican trucks that you discuss. You can comment on that proposal here.

April 21, 2011 9:36 pm

Crusin, you seem to be arguing that most truck drivers drive safe and follow the rules, so they don’t need EOBRs. However, do you think that EOBRs are a good idea for those drivers that have significant HOS violations?

April 21, 2011 10:01 pm

Vganster, you say that truck-involved accidents are at an all time low. Would it be possible for you to share where you got this information from? The FMCSA would benefit from having this sort of data.

Additionally, you seem to have some experience with EOBRs. You say that truckers are still allowed to input their duty status when using an EOBR. Could you explain how this works and what your experience with EOBRs has been?

February 25, 2011 8:39 pm

If anyone is interested in the article that pkcamper is referring to you can find it here: http://www.landlinemag.com/Archives/2011/Feb11/News/OPED-EOBRs.shtml

March 9, 2011 2:08 pm

moderator I am against any kind of device put in my truck, that government wants in there to keep track of me. A smartphone or EOBR, makes no difference. I guess the best thing to compare this to is somebody that breaks the law and gets put under house arrest and gets the ankle bracelet to make sure they do what they are told What is the difference. I broke no crimes but they want to watch to make sure I am being a good boy, and if their little black box tells them you did something wrong you have troubles, and this they say will make the roads safer. How I ask? by putting more stress on an already stressful job and making it more stressful having everything you do recorded. And one can not say that is what they are there for, if not why force them into one’s truck.

April 21, 2011 11:42 pm

The FMCSA would benefit from having it’s own data? Here’s one source http://www.todaystrucking.com/features.cfm?intDocID=24990

I have no experience with EOBRs. I am not a truck driver. However, I know that unless the EOBR has some sort of magic powers, it cannot tell whether the driver is waiting at a shipper or reciever or securing a load. It knows only whether the truck is moving or not moving. If the truck is moving, then it’s obviously going to be on-duty, driving time. If the truck is not moving, the driver certainly must have a way to input what duty status should be recorded.

Why not address exactly how the FMCSA believes that mandated EOBR technology is not a major invasion of privacy? Why not… more »

…address the fact that fatigue is an unquantifiable factor and that the statistics citing fatigue as accident causation are therefore unreliable? « less
April 29, 2011 6:57 pm

Mr moderator look up trucking stats and you will see that even on the FMCSA own web sight you can find this info. AND yes sir there are other neutral sights to see this info, it is out there for anybody who wants to know.

May 9, 2011 3:00 pm

what I’m saying is I’m an O/O…I keep correct logs… a stupid thing to falsify logs..
But the FMCSA IS GOING TO MAKE ME(force me to use them) USE EOBR’s….

because some dumb xxx’s falsified logs and got into an accident…and operated THEIR TRUCKS while fatigued..

we as (O/O’s, ) don’t operate that way..unsafe…safety is THE FIRST PRIORITY…I keep the equipment in good order…repair just about everything on the rig’s in order to keep the vehicles SAFE and mainly to ovoid breakdowns…

The pay scale has dropped significantly over the years…
..and FMCSA is going to force me to install that expensive equipment in my trucks…an expense I don’t need or want.

I’m really against the idea of… more »

…the FMCSA forcing me me to install this expensive equipment ,EOBR’s,
mainly because we
(my other drivers who haul for me) operate within the HOS now…I really do not need an electronic device to keep CORRECT, LEGAL logs…

IT’S ANOTHER EXPENSE I DON’T NEED AT MY COMPANY!

crusin
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May 9, 2011 3:05 pm

yes, for very repetitive offenders…drivers that purposely create false logs…not drivers that have been cited for a honest mistake on their logs over the years.

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”…

That’s non sense…

May 10, 2011 10:20 am

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… more »

…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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