Tips to Prepare for Hours of Service Changes
As the D.C. Circuit Court of Appeals prepares to issue a final decision in the American Trucking Assns.' (ATA) case against the Federal Motor Carrier Safety Administration (FMCSA) regarding the restart and rest break changes to the driver hours of service rules, the trucking industry should be preparing for the impacts those changes may have on their operations.
The industry finds itself in a "hope for the best and prepare for the worst" position concerning the litigation and the July 1 effective date of the new rules, according to the American Trucking Assns.
Start Now: Many trucking companies have already started explaining the potential changes to their drivers and customers. Operationally, the restart rule changes and the new 30-minute rest break requirement may cause significant disruption to your daily procedures. If caught off guard, unaware drivers may be confused about the requirements and potentially incur violations that could generate fines and that will affect carrier CSA scores.
Use a Personal Approach: Most find that drivers retain information better in a one-on-one or face-to-face classroom environment. If possible, integrate HOS training into your current training regimen. Sometimes, driver schedules may preclude attendance. Make training materials available to these drivers as soon as possible and be available for follow-up questions. Train early and often as it may take several interactions for full comprehension.
Use Real-World Examples: While FMCSA has provided examples on their website of how driver logs may change, most companies ATA spoke with did not find them particularly helpful because they didn't reflect the daily operations of their company. ATA recommends that you develop logbook examples based on a typical and/or exceptional driving week at your company. Provide those to the drivers and compare them to examples under the current rules. If time and resources permit, it may be a good idea to select a small group of drivers to operate under the new restart and rest break provisions for a week or two. If you're able to do so, use their logs as examples to other drivers and allow trainees to ask questions.
Update Route Planning Protocol: Whether you are using route optimization software or planning a route manually, it is imperative to update your protocol to reflect any HOS changes. With truck parking scarce, it may be challenging to find somewhere a driver can rest and it may have to come sooner, or later, than expected.
Key is for fleets to educate their entire organization and their customers: It is important that all parts of your organization are fully aware of the potential changes and their consequences.
This is especially the case if your drivers use the current 34-hour restart, ATA says. Driver managers will need to alter their procedures and the sales staff will need to work hard to adjust shipper and broker expectations. Flexibility will need to be built into business relationships to ensure continued efficiency and productivity.
Following are some recommended hours of service training resources:
ATA's Summary of HOS Changes: http://www.trucking.org/Safety/042013_ATA%20Summary%20of%20Final%20HOS%20Rules.pdf
ATA's HOS Comparison Chart: http://www.trucking.org/Safety/HOS%20comparison%20chart.pdf
FMCSA's Summary of HOS Changes: https://www.fmcsa.dot.gov/documents/hos/HOSComparenewruleto_current.pdf
FMCSA's Interstate Truck Driver's Guide to Hours of Service, Updated February 2013: https://www.fmcsa.dot.gov/documents/hos/Interstate-Truck-Driver-Guide-to-HOS_508.pdf
FMCSA's Logbook Examples: http://www.fmcsa.dot.gov/documents/hos/logbook.pdf
Other Potential Training Material Sources:
For additional training resources or ideas, ATA recommends that carriers consider reaching out to colleagues in the industry. "The industry is dedicated to safety and has a long history of collaborating to meet its unique needs," ATA says.
If you use electronic logging devices, your provider will also be able to provide useful insight and materials for HOS training and insurance carriers may also be helpful. Also consider reaching out to your state trucking association.