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patrick

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What's Happening Now

April 4, 2011 2:04 am

Sorry my comment was posted before I edited and comlpeted it. From the end:

What if a carrier has to do RODS for 5 days in one week and never at any other time of the year. I would suggest that the EOBR rule applying to short haul carriers needs to be based on number of miles driven per year per power unit or total number of days per year requireing RODS or Number of miles per year requireing RODS. This metric could be based on information provided in an MCS-150 and than the CSA data could state weather a carrier has to be compliant with EOBRs.

April 4, 2011 3:35 am

For my company the cost of useing EOBRs will be extremely burdensome. I am a Custom Harvester with 10 units that fall under RODS requirements for less than 15 days a year. The rest of the year they are either not in use or do not have a GVWR requireing RODS or are operating from exemption of HOS under 395.1k. So requireing EOBRs on these units for 15 days a year of use under FMCSA estimate costs $785 per year would be $52 a day. This is a substantial cost over a paper log sheet costing cents a day. With the 10 units it will cost me $520 dollars a day to move. All but 2 days a year I have to use RODS I average less than 350 miles a day. So while moving my 10 units in convoy the use of EOBRs is going to cust me $1 to $1.52 a mile. To any reasonable person this is a highly burdensome cost.

As… more »

…far as the EOBRs lasting 10 years I have heard that before. My trucks operate 2/3 of their miles offroad in hot dirty and rough conditions which often sees premature failers in electronics. The manufacturer only warranties them for 3 years so they have no confidence past that time frame.

The reduced overhead and administrative costs for EOBRs is moot when compairing a small number of unit used relatively few time a year. My employees are on salery so time for compleating RODS is not direct cost. The clerical time for submiting paper logs will be faster and cheeper than electronic logs when done in small quantities. The cost of storing electronic data could be substancially higher when considering the computers needed to collect and store the data collected from EOBRs. What about data backup, computer data does fail and small business do not generally have the best bomb proof data backup systems. Yes paper logs can be destroid in fire and floods but how often does that happen compared to computer failure. Do you get a large fine because your logs are gone due to a loss of data to electronic failure either in the EOBR, data loging, or data storage?

I dont think the cost of maintaining EOBRs has been fully thought out by FMCSA. I think it has been fully thought out by the EOBR manufactures and they see $$$. 2 million power units required to buy these systems are going to be paying $40 a month for subsription costs, that’s $80 million a MONTH! Everyone knows the best businesses to be in are subsciption based sales were the customer has to keep paying. All the better that the customer has to pay you by force of law. I’m in the wrong business. Even by FMCSA estimates of .3% to.5% of cost to trucking revinue that’s $1 billion to 1.7 billion a year. That might be chump change to the federal government but it is not to private industry. All this expense is because the government does not trust motor carriers to be truthfull with their HOS compliance. All of this cost does not even guarantee a reduction of fatigue related accidents. It just stiffens the reporting requirements of HOS. Most motor carrier’s fatigue related accidents occure with no HOS violations. « less

April 4, 2011 4:52 am

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… more »

…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. « less

April 4, 2011 2:04 am

Sorry my comment was posted before I edited and comlpeted it. From the end:

What if a carrier has to do RODS for 5 days in one week and never at any other time of the year. I would suggest that the EOBR rule applying to short haul carriers needs to be based on number of miles driven per year per power unit or total number of days per year requireing RODS or Number of miles per year requireing RODS. This metric could be based on information provided in an MCS-150 and than the CSA data could state weather a carrier has to be compliant with EOBRs.

April 5, 2011 11:36 am

Jmorris is another commenter on this post who worries about exempting short haul drivers at all. He feels that exempting these drivers would give current long hail carriers a loophole for avoiding the requirement. You can read his full comment here here. Do you think this could be a real concern? Is there a way to avoid having a rule that isn’t just one size fits all, but also doesn’t create a loophole like this?


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