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rdb, you have some clear concerns about the way that FMCSA is defining “fatigued driving”. You can read more about their analysis by reviewing parts of the Regulatory Impact Analysis here
What do you think about the way DOT is calculating this analysis?
Do other commenters agree that EOBRs should be made with additional features, like GPS technology? Do you think this could save money for drivers and owners? Is it possible to include more features without causing the price to rise?
Aaron, your comments on privacy concerns are helpful and will be incorporated into our summary to DOT, but would you be willing to re-post them in the privacy section? Commenters interested in that part of the proposed rule will have an easier time finding your thoughts and responding to them.
You bring up a lot of points about how difficult and expensive it is to be an American trucker. If you have specific comments about how requiring EOBRs will affect truckers like you, you can make them here and FMCSA will consider your concerns.
Your other general points about the trucking industry, and your comments about the Mexican trucking subsidies, are not part of this proposed rule. However, you may want to contact your local representative to let them know how you feel. You can write to your representative here.
Do you, and do other users, have recommendations for DOT to address this potential problem within the proposed rule? Can you imagine a way for drivers to self-diagnose fatigue in addition to what the EOBR says?
What do other users think about giving small businesses a subsidy or grant to pay for EOBRs?
Should businesses pay a portion of the cost or should it be completely subsidized?
Ok, thanks for the prompting and the providing the opportunity to further comment and expound upon the topic. In simple language, fatigue affects each person differently. No one has developed a way to measure it. For detailed information regarding this assertion about fatigue measurement, reference the legal decision regarding the Minnesota State Patrols flawed campaign against fatigue that was struck down by the courts in 2011. The testimony rendered in the trial by Subject Matter Experts regarding measuring fatigue is quite compelling. Can we all agree there is no method to measure fatigue that has been developed using the scientific method, peer reviewed and accepted by the courts? Probably not. Lacking any science to back their position, the US DOT has decided to attack the problem… more »
“If your strategy is wrong from the outset, no matter which clever tactics you use, you are inevitably doomed. Tactics without a good strategy are a waste of resources.”
As predicted by Sun Tzu in 500 BC, this Don Quixote like quest by the US DOT is a waste of resources, unfortunately they have decided to use the power of government to waste my resources instead of their own (the Mexican Government won’t put up with it, so DOT is using US taxpayer money to pay for their EOBR’s). Additionally, the untended consequences are dangerous. Under their current scheme they want us to use an EOBR to measure and govern how much we work. The inherent flaw in this strategy is that the EOBR is smarter and knows an individuals fatigue level better than the individual. Under the current rules, a driver can plan, schedule, and execute his routes based on his/her understanding of the route (driving in some terrains and weather conditions can be more fatiguing than others), equipment, type of load, weather, and other factors. Under the EOBR scheme proposed by DOT, drivers will essentially be required to drive even when they know they are tired. Since companies and the government will be monitoring ever aspect of their driving, companies will most likely only employ drivers that can “max out” the hours allowed by the Government, drivers will be forced to drive even if they know they are tired. By substituting the EOBR’s judgment for the drivers, there will be fatigued drivers on the road.
Recommendation: Prior to implementation of this rule, the US DOT institute a science based and peer reviewed study of the safety results of drivers being required to drive when they know they are tired, want to take a rest break, but due to financial and regulatory rules must continue driving. Any study that does not consider this dynamic of fatigue is flawed and once considered likely makes the whole EOBR scheme illogical, unless you believe the EOBR is actually more able to measure a person’s fatigue level better than the person, his/her self.