Common Sense Suggestions
1. Scrap CSA & its SDS methodology (particularly the Bell Curve scoring mechanism) -It’s not reliable or fixable
2. Recognize driver turn-over as the immense safety concern that it is. It’s obvious, - experienced CDL drivers save lives daily; window-foggers simply can’t!
3. ELD’s should not be mandated, but allowed. The marketplace will move carriers to that technology for those that need it to comply without forcing the other 50% of carriers to spend tens of millions on technology they don’t need nor can afford.
4. Whatever accident calculator you use to grade companies cannot logically input accidents that are not the carriers’ fault – 75% of the time!
5. Recognize that putting a company out of service for 30 days really puts them out of business.
6. Outsource the new entrant audit so you can actually perform this function as mandated. The various states and safety contractors should be considered as a resource for this with the carrier paying a
reasonable fee ($300.00 or less).
7. Recognize that it is the sole responsibility of FMCSA to determine fitness to operate.
8. Recognize that small carriers and owner-operators are an essential part of the distribution chain and are not the safety problem.
9. Eliminate undue discrimination at the scales, over-the-road, and in all regulatory jurisdictions.
10. Fix the HOS
- Every comment that I’ve heard over the past 15 years has included the word “flexibility.” This could be easily accomplished in our niche with an understandable and easily implemented split sleeper option that moves the 14 hour rule.
- Eliminate the forced thirty minute offduty break.
- Eliminate the 1:00 AM to 5:00 AM requirement in the 34 hour restart and allow a second restart within the 168 hour week. If one restart promotes driver rest, how can a second not improve the drivers’ ability to get rest even more?
11. Refrain from practicing medicine with your apnea rule. NASTC feels that our solution that includes a voluntary opportunity for a funded screening test for drivers who feel they have a problem is the way to go there. Our program protects the rights of drivers and yet gives them a path to individually address any sleep problems they may have and reiterates that the requirement for a clear medical card is their responsibility. Any rule should focus on narcolepsy and chronic fatigue not apnea, which we all have to some degree.
Respectfully Submitted,
David Owen
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