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Recommend DOT remove the reference to Qualcomm. Federal Contracting rules normally require the Federal Government require capabilities rather than manufactures. If other vendors can meet the requirements they should be allowed to compete. Even if it is legal it creates an appearance of bias. Also, recommend a review of all DOT employees to ensure there has been no insider trading regarding interests in Qualcomm. Finally, since the regulation will cause a tremendous financial cost to the US Transportation industry and a financial boom for Qualcomm (i.e. forced income redistribution by the Federal Government from small business to Qualcomm) recommend a prohibition for all DOT employees to work for Qualcomm for at least two years.
the cost savings are incorrect. I buy 12 log books a year at approximately $1 each for a total of $12 per year. Since I fill out , file, etc., the RODS myself there are no other costs. If the big companies find the cost EOBR’s cost effective, they should use them. If Qualcomm made a product that was cost effective, I would buy it. Unfortunately, this is another example of a company using the federal Government to mandate use of a product they can’t sell in the free market to enrich themselves. Recommendation – rework the cost saving as they are unrealistic.
Since the EOBR regulation is being introduced as a safety initiative, it is appropriate to also consider driver safety. A wireless device that transmits driver stops is a truck hijackers dream come true. Even though the proposed EOBR does no record stops down to the GPS grid coordinate level, all a thief or theft ring needs to know is the city the truck stopped to have a good idea of what their cargo is. Shipping locations are well known within the trucking community. For example if a truck stops for more than a 1/2 hour and less than 10 hours in my home town there is a very high probability the truck is carrying bagged soil or bricks. The thieves know what towns the pharmaceuticals, electronics, precious metals (like copper, aluminum) and other high value loads are being shipped from.… more »
According to the purpose of the proposed EOBR regulation is to ensure Hours of Service (HOS) compliance. If I get in my truck and drive in a parking lot in a circle for 11 hours, at 11 hours and 1 minute, I will be over my hours of service (or whatever the DOT HOS regulation of the day is). If the DOT regulation is about Hours of Service all they need to know is how long I have been driving/working. Recommendation – A. DOT delete all the other requirements for EOBR recording of information that is not directly related to HOS.
B. DOT rewite the cost estimates based on the reduced costs to small business from not having to record information that is not required to track hours of service. Why should I have to pay for the collection and storage of information that is not required to track HOS compliance?
The electronic systems in modern trucks are delicate and expensive. The DOT regulation does not specify who is liable to damages to a trucks electronic system if a law enforcement officer causes damages to a system by not properly grounding or improperly accessing the data. This not with NAFTA precedent. A truck driver in Canada asked a law enforcement officer to sign a letter assuming damage liability prior to accessing his his limiter. The law enforcement officer refused and issued the truck driver a citation for non compliance. In court, the judge found the driver not guilty. Recommendation: Liability for damage by by law enforce needs to be clearly stated by DOT.
According to recent news reports, an agreement was reached between The US and Mexico that the US taxpayers would pay for the EOBR’s required in Mexican trucks operating in the United States. The next day a jubilant Mexican president announced that there would be no limits on the number of Mexican trucks allowed to operate in the United States. It is my interpretation the United States carriers will have pay the entire themselves. Recommendation: This is a disaster. Get rid of the EOBR requirement, don’t pay for Mexican truck EOBR’s, pay for all US and Canadian truck EOBR’s. This is what happens when politics trumps safety. Either pay for everybody or pay for nobody.
There is cumulative effect of the recent flurry of DOT regulations, 5% of revenue for EOBR’s, 5%-10% revenue reduction for elimination of the 11th hour of service, TWIC cards, cell phone prohibitions, no idling laws, mandated rest breaks, California CARB rules, new rules for fuel efficiency that increase equipment costs. How much money do you think we make? The shotgun approach for regulation hides the true amount of burdens the DOT is placing on private industry. As a former military person, I know some of the first objectives of any military plan is to disrupt and destroy the enemy’s lines of communication and supply. Someday we could have “star trek” like teleporation devices, until then the US trucking industry is this nations line of supply. No enemy could possible… more »
As a small trucking company owner, the the proposed EOBR doesn’t pass the cost/benefit test. To pay $785 a year for something I currently do for $12 a year when I get absolutely no benefit is unnecessary financial burden.
It is not clear what benefit the United States of America receives from this proposed regulation. All we are told is this regulation is necessary “to ensure compliance with hours of service regulations”. What does that mean? Since DOT decided to include log book “form and manner” and other trivial logbook violations as evidence of “fatigued driving” in CSA 2010. The information provided by CSA 2010 is useless for measuring actual fatigued driving issues. Also, since there is no way to actually measure fatigue, the DOT position becomes a mixture of subjective opinions and political agendas, all stuffed under the banner “fatigued driving” since no one can measure fatigue or refute assertions of opinion that are masqueraded as statements of fact.… more »
The availability of the information that will be mandated in the proposed EOBR rule is a treasure trove of information for criminal exploitation. Even though the information required does not go to the GPS grid coordinate level, all a criminal needs to know is the city where a truck got loaded. Shipping locations are well known within the transportation community. If you tell me the city a shipment came from I can tell you the most likely contents of the load. Truck hijackers will focus on trucks that have visited cities that ship pharmaceuticals, electronics, copper, aluminum, and other high value loads. Wireless networks and/or have an external access point are generally not considered secure methods of data transmission.
To protect sensitive information the Federal Information Security… more »
According to FISMA, the term information security means protecting information and information systems from unauthorized access, use, disclosure, disruption, modification, or destruction in order to provide integrity, confidentiality and availability.
As a private company, Qualcomm does not have to comply with FISMA when selling systems to private companies. When the Federal Government mandates the use of a system by Government to interact with private carriers, it now becomes subject to FISMA.
A. Prior to publication of any EOBR regulation, the US DOT must comply and document compliance with all aspects of the FISMA act to achieve system accreditation as discussed in the following paragraph:
“Once the system documentation and risk assessment has been completed, the system’s controls must be reviewed and certified to be functioning appropriately. Based on the results of the review, the information system is accredited. The certification and accreditation process is defined in NIST SP 800-37 “Guide for the Security Certification and Accreditation of Federal Information Systems”.”
B. Compliance with Federal Laws by DOT is not optional it is mandatory. Additionally, the reason for information security is to protect individual truck drivers from the violence associated with criminal activity associated with the exploitation of vulnerable information by criminals.
C. Once the EOBR has been certified, accredited, and documented as required by “Guide for the Security Certification and Accreditation of Federal Information Systems”, the DOT will need to republish the proposed EOBR regulation to include all the additional costs associated with information security.
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.
The 14 hour rule is the problem. Once it starts it can’t be stopped. Many have advocated for s split sleeper berth provision that would allow the driver to use his/her own professional judgment to determine fatigue. Under the current and proposed HOS provisions, the vehicle operator has no input regarding their own level of fatigue.
As a follow-up regarding the cumulative costs of regulations, I researched and found out Executive Order 12866 signed by President Bill Clinton in 1993 requires all Agencies to publish the cumulative effects of their regulatory schemes.
Recommendation: In compliance with the subject Executive Order, the US DOT publish a study detailing the cumulative costs of all the recent regulations. I tried to cut and paste the extract from the executive order but was unable to. The verbiage can be found in paragraph (11) of the Executive Order.
hours on-duty, off-duty, driving. o other information is required.
Location is not required, unless you of course you wanted to start a Vehicle Miles TAX using trucks as a guinea pig. If so, recommend going to congress as the constitution requires all bills requiring taxation to originate there.
The Congress passed and the President signed the FISMA Act of 2002 to require Federal Agencies to complete the required Information Assurance certifications prior to implementing an electronic information gathering system. If DOT would complete the required Information Security Assurance certifications required by law, the answer would be found during the certification process.
Creative trucker beats speed-limiter ticket in Canada
Persistence and creativity have paid off so far for trucker Lee Ingratta.
The one-truck owner-operator from Gravenhurst, Ontario, has captured the attention of the trucking community for the method he used to beat a ticket for an alleged violation of the provincial law that requires trucks to be equipped with speed-limiting devices.
A judge tossed Ingratta’s case out of court on June 4. Not surprisingly, provincial enforcement officials have filed an appeal.
During a stop at a scale house in July 2009, an inspector with the Ministry of Transportation of Ontario asked Ingratta for permission to connect an external device to a port on Ingratta’s Peterbilt to check for compliance with the speed-limiter law. Under the law, computerized… more »
Things got interesting from there.
“He came over with this little gizmo and wanted to plug it in to the computer,” said Ingratta, a self-proclaimed “computer guy” who even owned his own computer shop for 25 years before returning to trucking in 2004.
“I’m thinking to myself, if he plugs this in to one guy’s truck, and then he takes it out and tries to plug it in to my truck, what happens if there’s a little charge of static electricity in this thing? Is he grounding the thing out? Is he going to zap my computer? No, he’s not plugging it in until he signs this waiver.”
The “just in case” waiver Ingratta drafted and carried with him says that he will consent to a speed-limiter inspection only if the officer or agency takes full responsibility for any damage that may occur as a result. The officer disregarded the waiver and cited Ingratta for “refusal” to allow entry to the computer port.
The judge, however, said Ingratta did not refuse and tossed the case. It’s not over yet, however, as the province isn’t going down without a fight of its own.
“The Ministry is aware of the case and is appealing the decision,” MTO spokesman Bob Nichols told Land Line. “As the case is still before the courts, it would be inappropriate to comment further at this time.”
The Owner-Operators Business Association of Canada, of which Ingratta is a member, went public with the news of the case following Ingratta’s court decision.
“I think the fact that the province is appealing shows they’re concerned about that,” OBAC Executive Director Joanne Ritchie told Land Line.
Ritchie said OBAC began raising concerns several years ago about issues of driver privacy and the potential for computer-related problems resulting from port-data exchanges.
“This whole thing about warranty issues – they’re worried about that because they could get themselves into trouble because that tool they use is not licensed software,” Ritchie said. “Engine makers don’t give that to just anybody and it’s very expensive.”
Drivers Against Speed Limiter Legislation, a Facebook group operated by trucker Scott Mooney, was abuzz this week with the news about Ingratta’s case.
Mooney, a member of OBAC and OOIDA, is currently fighting a speed-limiter ticket of his own in Napanee, Ontario. His argument is about the safety aspects and speed differentials that speed limiters on one class of vehicles can cause on the highways. He also has concerns with privacy and the potential for the province to inadvertently void warranties.
“Dealerships do not want any unauthorized personnel tampering with a truck’s ECM,” Mooney said.
“If you as an owner-operator have problems with your computer, and you go in to your dealership and they find out that the last person that accessed the computer was MTO, they can use that to say somebody who wasn’t qualified was into this thing, and that voids your warranty.”
Mooney’s own case has been set for July 21 in provincial court in Napanee.
Meanwhile, Ingratta is gearing up for the appeal in his case, which has yet to have a date set.
“Either they’re going to keep shoving this stuff down our throat and we keep taking it, or we need to stand up for ourselves,” Ingratta said.
“It’s our equipment, and it’s our trucks. We have a right. We have some rights left, anyway.”
– By David Tanner, associate editor
firstname.lastname@example.org « less
Issue: US DOT’s proposed rulemaking regarding Electronic On-Board Recorders (EOBR’s) is not in compliance with The Paper Work Reduction Act of 1980 as amended in 1995, Regulatory Flexibility Act of 1980, as amended, and Executive Order 12866.
Discussion: The Federal Laws identified in the issue statement require Federal Agencies to consider Small Business in their rule making and mandate that federal agencies include flexibility and scalability for Small Business in their regulations to reduce the administrative and financial burdens from regulation on small business. The cost figures contained in DOT’s cost analysis for EOBR’s are horribly skewed toward a big business model. I own a one-man one-truck trucking company and I only spend about $12 a year on paper log books to comply… more »
1. DOT rework the regulatory proposal on EOBR’s to include small business as required by the federal laws identified in the issue statement.
2. As required by the Regulatory Flexibility Act, DOT provides small business with less burdensome alternatives.
3. My personal recommendation is use a scalable process, for example companies with over 100 trucks might find to economically beneficial to use EOBR’s. When DOT publishes the initial regulatory flexibility analysis (IRFA) for small business mandated by the Regulatory Flexibility Act discussing their efforts to create flexibility for small business, they should consider alternatives for small business that are closer to the $12 per year I currently pay.
4. As required by Executive Order 12866 paragraph (11), DOT conduct and publish an analysis of the cumulative effect on small business of all their proposed regulations combined.
5. DOT carefully review paragraph (8) of executive order 12866 with regarding to establishing performance objectives as opposed to the manner of compliance. In plain language, don’t specify a Qualcomm device as mandatory for all commercial vehicles. The regulation should tell people what they are going to do, not how they are going to do it.
References: Selected applicable extracts from the Paperwork Work reduction Act, The Regulatory Flexibility Act, and Executive Order 12866 that are relevant to the US DOT proposed rule making regarding Electronic On-board recorders (EOBR). Extracts of particular significance have been highlighted in BOLD text.
The Paper Work Reduction Act of 1980 as amended in 1995
The Paperwork Reduction Act of 1980, Pub. L. No. 96-511, 94 Stat. 2812 (Dec. 11, 1980), codified in part at Subchapter I of Chapter 35 of Title 44 of the United States Code, 44 U.S.C. § 3501 through 44 U.S.C. § 3521, is a United States federal law enacted in 1980 that gave authority over the collection of certain information to the Office of Management and Budget (OMB). These information policies were intended to reduce the total amount of paperwork handled by the United States government and the general public.
Standards That Must Be Certified in Paperwork Reduction Act Submissions AppendxiI
The 1995 amendments to the Paperwork Reduction Act established
detailed paperwork clearance requirements for agencies before
information collections are proposed to the Office of Management and
Budget (OMB) for review. The 1995 law required every agency to establish
a process under the official responsible for the act’s implementation, now
the agency Chief Information Officer,1 to review program offices’ proposed
collections and certify that they meet 10 standards.
These standards are
codified at 5 C.F.R. 1320.9. The standards read as follows:
“(c) reduces to the extent practicable and appropriate the burden on
persons who shall provide information to or for the agency, including
with respect to small entities, as defined in the Regulatory Flexibility
Act (5 U.S.C. § 601(6)), the use of such techniques as:
“(1) establishing differing compliance or reporting requirements or
timetables that take into account the resources available to those
who are to respond;
“(e) is to be implemented in ways consistent and compatible, to the
maximum extent practicable, with the existing reporting and
record keeping practices of those who are to respond;
The Regulatory Flexibility Act
The following text of the Regulatory Flexibility Act of 1980, as amended, is taken from Title 5 of the United States Code, sections 601 – 612
(The Regulatory Flexibility Act was originally passed in 1980 (P. L. 96-354). The Act was amended by the Small Business Regulatory Enforcement Fairness Act of 1996 (P.L. 104-121).) (
The Regulatory Flexibility Act is perhaps the most comprehensive effort by the U.S. federal government to balance the social goals of federal regulations with the needs and capabilities of small businesses and other small entities in American society.
In practice, the RFA has been an interesting and much-imitated attempt to “scale” the actions of the federal government to the size of the groups and The White House Conference recommendations lent significant impetus for the passage, in September 1980, of the Regulatory Flexibility Act (RFA). The intent of the act was clearly stated:
It is the purpose of this act to establish as a principle of regulatory issuance that agencies shall endeavor, consistent with the objectives…of applicable statutes, to fit regulatory and informational requirements to the scale of businesses…To achieve this principle, agencies are required to solicit and consider flexible regulatory proposals and to explain the rationale for their actions to assure that such proposals are given serious consideration.
The key requirement of the law is that federal agencies must analyze the impact of their regulatory actions on small entities (small businesses, small non-profit organizations and small jurisdictions of government) and, where the regulatory impact is likely to be “significant”, affecting a “substantial number” of these small entities, seek less burdensome alternatives for them. Both current and proposed federal regulations are subject to the RFA.
The process for seeking these less burdensome alternatives is three-fold. Agencies must:
· Solicit views of affected small entities
· Consider the views of the SBA Office of Advocacy
· Publish an initial regulatory flexibility analysis (IRFA) and/or a final regulatory flexibility analysis (FRFA) in the Federal Register, or provide a certification that the regulation will have no “significant impact”
Executive Order 12866
In September 1993, Vice President Al Gore’s National Partnership for Reinventing Government also urged that the Regulatory Flexibility Act be strengthened by permitting judicial review of agency compliance.
A few weeks later, President Bill Clinton issued Executive Order 12866, “Regulatory Planning and Review”, designed, among other things, to ease the regulatory burden on small firms.
The order required federal agencies to analyze their major regulatory undertakings and to take action to ensure that these regulations achieved the desired results with minimal burden on the U.S. economy. I couldn’t cut and paste paragraphs (5), (8), and (11) of the executive order. Just Goggle it.
Hey moderator! two questions. Is the request for comments regarding driver harassment by EOBR’s a separate process with comments made elsewhere or can we make them on regulation room. If so, under which category? Also, will all comments made on regulation room be included as public comment as written or do we need to repost our comments on the federal register to ensure they are heard? I like the regulation room concept and endorse it for future regulatory reviews. Thanks!
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?
rdb, thank you for taking such an interest in all aspects of the rulemaking process. It looks like you may have already read the RIA or the NPRM, but I want to show other commentors where to find them.
As rdb pointed out, agencies that engage in rulemaking are required to consider a number of factors before they make new regulations, such as the rule’s potential impact on small businesses. If anyone is interested, you can see FMCSA’s responses in the Notice of Proposed Rule Making (NPRM). For more in depth information, go to the Regulatory Impact Analysis (RIA). Just a warning: these documents get pretty technical in some places.
Do you know any more details about this Canadian case, or more situations where there have been problems with law enforcement officers damaging EOBRs or other devices? This kind of information could be really useful for DOT to know about, if we can get some more specifics.
Thank you for bringing up an important safety and security issue, rdb. Do you think having a wired EOBR during data transmission would lessen some of these issues? What are some ways that you think might help increase the security of EOBR data?
Hi rdb. Which specific pieces of information do you think the EOBR needs to record? You can find what they currently must record here.
RDB — Well said.
Agree. We provide income for eight families. These are eight families that might otherwise be on the dole. It is tough enough dealing with the avalanch of regulations without being saddled without one more expense.
The Regulation Room team summarizes the discussion that has taken place here on the site and submits it to FMCSA as a formal comment. We write detailed summaries, and the agency does address them in the final rule. (To see an example, you can look at the recently completed airline passenger rights rule here.) We’ll be posting draft summaries of the EOBR discussion this week so that users can review them and suggest improvements. Then we’ll make changes to the summaries, based on users’ comments, and submit the final summary to DOT on the last day of the comment period.
So you definitely don’t have to post your comments to http://regulations.gov… more »
I understand MODERATOR however you are thinking that the dot police are angles, you moderator I do not believe you have been in a truck and dealt with them. Yes I understand that DOT cops are not suppose to brake the law in order to enforce the law. When is the last time you seen a dot cop parked on an over pass using lazier to catch speeders. Over passes have a no parking zone, so tell me they are not breaking the law to catch speeders. Or parking on the shoulder of the road in which is emergency parking only to catch speeders. They also have a way of stretching their heads in your window to take a look around your truck. Yes the EBOR to some is just away to enforce the HOS laws. It is the FMCSA distrust of drivers, and have totally lost the trust of owner operators and the little guy. So… more »
1675 retail cost x 7= $11,725
100 installation x 7= $700
$480 yearly x 7 = $3360
$15,785 total first year cost for a small fleet of 7. (We’re assuming no repairs or anything else going wrong here)
$2255 total first year cost for 1.
My first question is “Who do you think is going to pay for this?” I’m assuming you guys sitting behind desks over there will say “You.” My second question is “Why?”
Why do you think we should have to pay for this? You present this as if this is some kind of miniscule cost for a small carrier. Maybe these big guys you’ve quoted can afford these things and they obviously can considering they’ve installed it on their entire fleet. Have you considered that maybe they’ve done this to simplify some of their bloated systems and utilize the government—by… more »
Being a small bus company in these economic times, we have NO extra money for more regulations. I am all for safety but this is going to put the small guys out in the cold!!!!!!!!!!!!!
this is a bunch of bs how do they expect us to support our family when all this happens these stupid rules will lead to more illegal stuff like drug dealing stealing and murders this isnt right everyone wants to make money off the driver fuel is already at a all time high brokers are trying to go down on freight and no one cares they think truck drivers are all ready at the bottom of every thing i have you know that this country runs off of truckdrivers people wouldnt have nothing no food no clothes no heat no energey no water no nothing so if they want to pass these stupid laws let them but i promise you the usa will be like egypt the people will take a stand and the people will get what they want just watch and see no wonder theres so many people on drugs and we have so many murders i think… more »
I work for a company that has four 3/4 and 1 ton pickups pulling trailers with a GVWR of under 8,000 pounds. We cross state lines occassionally. The costs involved in this rule would all but put our division out of business. I can somewhat understand the reason for this on an over the road truck, but there has to be more exemptions to account for the little guy like us. We may only need to drive CMV’s 3-5 times per month.
What about farmers and ranchers that haul cattle and hay a few months out of the year? What about the custom Harvestors who travel a circuit harvesting grain about six months out of the year? How are these guys going to afford this? what about personell conveyence.. We use our truck a couple of times a year to pull our fifth wheel travel trailer to races..
To the Moderator,
Cost is only one of the factors I’m speaking about. Violations of our right to work without being harassed at every turn of our step is also taken into my consideration.
How is it fair for our every move to be tracked, while every other working individual is allowed freedom of movement? If we have to have EOBR’s, then every motorized vehicle needs one as well.
My logbook works just fine. Although I don’t agree with all the little quirks which have been implemented merely as a result of some lobbyist group such as: MADD, Public Citizen, and many others.
Therefore, no I do not agree, as many others will not either.
When the public sees that the owners are not willing to foot the cost of “Self Law Enforcement,” they will also enjoy the greater cost of all delivered goods.
It is my understanding that I will have to pay for the EOBR that would go in my truck. $2255.00 for the first year. It is also my understanding that all of us American truckers will be paying for all of the Mexican truck’s EOBR’s because Obama has mandated it to be so. Now, in addition to me paying for my truck and the Mexican trucks, they will come up here burning cheaper fuel and charging cheaper rates and competing against me in an unfair way (mainly because the US Government is subsidizing them)and I am supposed to be supportive of this.
I have a suggestion. Why don’t you make it a rule that it is illegal to be an American trucker. We already are penalized by having to sit for hours at shippers without pay. We are paid by the mile but our miles are limited by hours of… more »
i dont know about anyone else but it sounds like our government is trying to put small fleets out of business with all these new rules and gadgets we have to buy and conform to
I operate 2 trucks under my own authority and to incur these expenses along with the lack of flexibility in the current HOS would probably force me to discontinue my operation.
We have 4 trucks and are a small company, having to pay for these would place a great burden on our company.
There is just no realistic reason for this..
FMCSA is using the most expensive system for the EOBR calulations. I use the JJ Keller system. $199.00 for the GPS and $6.00 a month. It requires you to use a smart phone and is very easy to use.
the JJ Keller system EOBR cost $199.00 for the GPS and $6.00 a month to use. It requires a smart phone to use but you can use this phone as your cell phone as it can do both items at the same time. I have a $75.00 everything cell plan and it works great.
The EOBR is a get rich in a hurry gift to the primary company that is making the unit is making a lot of money and on top of that we are forced to pay 40. dollars a month to stay compliant if that is not another way off letting government reach in your pocket to give it to there friends. And the FMCSA wonders why very few owner operators trust them.
You are exactly right.
Look at the TWIC Cards. Look at the criminal background checks. Look at the TWIC Reader. Look at cost to be qualified to haul coils in Alabama.
Who is the recipient of the profit behind that list?
No benefits at all. they are just an expence that is not necessary..
Follow the EOBR and drive tired that makes sence.. let an Electric onboard recorder tell me when i am tired.. REALLY?
Why cant I just write it down on my paper logs as we have been doing for years? an eobr will cause truckers to shut down in the middle of no where.. the HOS are enough do not add an EOBR to the mix.. as an owner operator who would get my EOBR data? my wife at home?
This is merely another phase of Big Brother. For all we know, they could have listening devices installed within.
One thing about it: If the door is opened even merely enough for someone to get their foot inside, they always tend to take more and more.
That is exactly how this government has grown so out of control.
Now they are financing their purses with more money which could have been better spent in maintenance of our vehicles or the payment of taxes we already owe.
If you just think about it: why did they just go through hiring so many new law enforcement officers?
Law Enforcement needs to focus more on those who PURSUE making money illegally, and let a person earn a fair income honorably.
i believe eobr’s would be a disaster for the small business trucker.case in point,i had an 18:00 appt., my 14 hrs were up at 21:30,i thought that would be plenty of time to unload,at 01:30 they were done and told me i could not stay on the property,the nearest safe haven was 1hr. away. i would like to know how i would put that into an eobr?
thank you for listening,alcanman
I understand that DOT isn’t going to require the EOBRs to record certain detailed information, such as vehicle speed and the vehicle’s exact location. But don’t many of the fleet management systems motor carriers currently use record this information? If a company chooses to use its current system as an EOBR, will an agency investigator have access to this more detailed information even though this isn’t the information he’s supposed to be after?
Follow the EOBR and drive tired that makes sence.. let an Electric onboard recorder tell me when i am tired.. REALLY?
I talked to a Montana highway patroll officer today and they can not even access an eobr they have no software for them and no means of even checking them..
“The principal use of EOBR Electronic on-Board Recorder data is to confirm HOS Hours-of-service (HOS) compliance, whether at roadside checks or on-site carrier reviews.”
FMCSA, DOT, NHTSA, NTSB, have all made claims that EOBR’s will make the highways safer… I ask again how?
Just by adding the mechanical device, even though the driver still has to manually add any change of duty status?
This EOBR just sounds like an overly expensive record keeper – like a paper log is.
What about this information? ATA announced that in an effort to rationalize a change in federal Hours of Service (HOS) requirements for professional truck drivers, the U.S. DOT’s Federal Motor Carrier Safety Administration (FMCSA) misapplied its own crash numbers so as to elevate driver fatigue… more »
Adding an EOBR will do nothing but add yet another cost to the trucker or trucking company.. « less
Driver fatigue is not a real problem according to an FMCSA webinar, that was publicly was communicated on September 30, 2010, hosted by the FMCSA titled: 2009 – Historic Truck Crash Declines. The number is 1.4% fatigue related accidents in trucking.
No, I do not believe the EOBR will be effective of reducing truck crashes – mainly because it will be on the wrong vehicles.
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 firm reasoning.
Justice could become out of control!
Just as George Orwell’s book revealed the possibilities of many things that have become a reality during our lifetime, our thought to be friend of the people: Our “Sovereign Government” could become the same as the subject of the book written by Attorney Gerry Spence.
Atty Gerry Spence wrote a book by the name of: From Freedom to Slavery, which spoke this following statement:
“But over the years, as a criminal defense attorney, my in-court experiences with the police forced me to the realization that police, like the rest of use, want to win. we are a competitive people who, from the earliest times, have donned a jersey of one color or another, and we have been taught that we should fight for that color jersey, and win. Many police,… more »
This could be the misguided use of this equipment. « less