DOT hours-of-service: Comment extension


The Commercial Vehicle Safety Alliance (CVSA) wants more time to collect and analyze comments on the FMCSA’s proposal for changes to the hours-of-service rules.

The CVSA sent a formal petition to the FMCSA requesting a 45-day extension to the comment period regarding a notice of proposed rulemaking aimed at providing commercial motor vehicle drivers more hours-of-service flexibility.

In early August the FMCSA proposed five changes to the hours-of-service regulations:

  1. 30-minute break requirement: Changes will allow drivers to satisfy the required break using on duty, not driving status, rather than off duty.
  2. Sleeper berth exception: Changes will allow drivers to split the required 10 hours off duty into two periods.
    • One period must contain at least 7 consecutive hours in the sleeper berth.
    • The other period cannot be less than 2 consecutive hours, either off duty or in the sleeper berth.
    • Note: Neither period would count against the driver’s 14‑hour driving window
  3. 30-minute to 3-hour off-duty break: Changes will allow drivers one off-duty break of at least 30 minutes and no more than 3 hours, that pauses the driver’s 14-hour driving window
    • Note: Driver must take 10 consecutive hours off-duty at the end of the work shift.
  4. Adverse driving conditions exception: Changes will extend the maximum window during which driving is permitted by two hours.
  5. Short-haul exception: Changes will lengthen the drivers’ maximum on‑duty period from 12 to 14 hours and extends the operating distance limit from 100 to 150 air miles.

CVSA fully supports FMCSA in their request for comments, however, Executive Director Collin Mooney said that 45 days is not enough time to prepare and approve comments on such a complicated and important issue. Mooney stated that it is imperative that stakeholders provide more time.

The August 22, 2019 proposal opened a 45-day comment period allowing comments on regulations.gov using docket number FMCSA-2018-0248 until Oct. 7, however the extension would leave the comment period open until November 21, 2019.

Stay DOT compliant

Knowing these Hours-of-Service rules and regulations will allow you to stay compliant and plan your operations more efficiently.

All CNS services are geared toward keeping your trucking company safe and compliant.

If you have any questions, call (888) 260-9448 or email at info@cnsprotects.com.

US DOT seeks comment on Agriculture HOS regulations


The US DOT’s Federal Motor Carrier Safety Administration (FMCSA) is seeking public comment to revise the hours-of-service (HOS) regulations for agricultural commodity or livestock definitions.

The FMCSA partnered with the US Department of Agriculture (USDA) to provide clarity for the nation’s farmers and commercial drivers, eliminate confusion and align the agencies’ agricultural commodity definitions.

With the American agriculture industry contributing more than $1 trillion annually to the US economy, the FMCSA recognizes the importance of the agricultural industry.

The FMCSA is determined to find a balance that provides more flexibility to those hauling agricultural commodities.

Current regulations have certain restrictions lacking the flexibility that farmers and commercial drivers need due to the unique realities of hauling agriculture commodities.

Currently, during harvesting and planting seasons, drivers transporting agricultural commodities, including livestock, are exempt from the HOS requirements.

The HOS exemption is called a short haul exemption and applies when the destination of the commodity is within a 150-air-mile radius from the source.

Each individual state is currently determining HOS requirements for agricultural commodities.

The advanced rule (ANPRM) authored by FMCSA was prompted by indications that the current definition of these terms may not be understood or enforced consistently when determining whether the HOS exemption applies.

The FMCSA is encouraging all commercial motor vehicle stakeholders to provide feedback on how the current definitions impact safety, compliance, and enforcement. More specifically, the FMCSA wants to hear from those transporting agricultural commodities and livestock.

Canadian ELD mandate for commercial vehicles


Commercial driver fatigue is a long-standing road safety issue that the United States has addressed through the use of ELDs. Canada is following suit with the Canadian ELD mandate.

The Canadian government is committed to improving road safety for all Canadians and is falling in line with the US to address this issue through the implementation of the Canadian ELD mandate.

As a result of a longstanding collaboration among all levels of government and industry partners, this past June, the Honorable Marc Garneau, Minister of Transport, mandated the use of ELDs or electronic logging devices by federally regulated commercial truck and bus operators.

The Canadian ELD mandate requiring the use of ELDs will go into effect on June 12, 2021 and will replace paper-based daily logbooks.

What is an ELD or electronic logging device?

Electronic logging devices are tamper-resistant devices that are integrated into commercial vehicle engines. The devices track when and how long drivers have been at the wheel, and ensure they are complying with the Commercial Vehicle Drivers Hours of Service Regulations.

There are many advantages to using ELDs, but the main purpose is to ensure that commercial drivers remain within their daily driving limit and accurately log their working hours. If commercial drivers are not within the regulated limit, there may be fines associated with the violation.

The use of ELDs also reduces administrative burdens, such as eliminating the need for paper daily logs and reducing the time enforcement officers need to verify regulatory compliance.

These new electronic logs for truckers are aligned with the United States road safety regulations and will support economic growth, trade, and transportation on both sides of the border.

After extensive research and consultation, Transport Canada has implemented a third-party certification process will be put in place to ensure that the electronic logging devices will be accurate and reliable.

Other important facts about the Canadian ELD mandate:

  • Transport Canada is committed to aligning with vehicle regulations in the United States.
  • Aligning Canadian and US electronic logging device regulations will allow Canadian and US operators to use the same logging device in both countries.
  • Transport Canada estimates that requiring the use of electronic logs for truckers will reduce the risk of fatigue-related collisions by approximately 10 percent.

More driver flexibility after hours of service changes


5 major DOT hours of service changes

In an effort to improve safety and provide more flexibility to commercial motor vehicle (CMV) drivers, the Federal Motor Carrier Safety Administration (FMCSA) has released a notice of proposed rulemaking (NPRM) that proposes changes to the hours of service (HOS) rules.

In 2018, the FMCSA release an Advanced Notice of Proposed Rulemaking (ANPRM) on Hours of Service of Drivers and requested public comment on portions of the HOS rules to alleviate unnecessary burdens placed on drivers.

The FMCSA proposed changes focus on the five areas below:

  1. 30-minute break requirement: Changes will allow drivers to satisfy the required break using on duty, not driving status, rather than off duty.
  2. Sleeper berth exception: Changes will allow drivers to split the required 10 hours off duty into two periods.
    • One period must contain at least 7 consecutive hours in the sleeper berth.
    • The other period cannot be less than 2 consecutive hours, either off duty or in the sleeper berth.
    • Note: Neither period would count against the driver’s 14‑hour driving window
  3. 30-minute to 3-hour off-duty break: Changes will allow drivers one off-duty break of at least 30 minutes and no more than 3 hours, that pauses the driver’s 14-hour driving window
    1. Note: Driver must take 10 consecutive hours off-duty at the end of the work shift.
  4. Adverse driving conditions exception: Changes will extend the maximum window during which driving is permitted by two hours.
  5. Short-haul exception: Changes will lengthen the drivers’ maximum on‑duty period from 12 to 14 hours and extends the operating distance limit from 100 to 150 air miles.

The proposed rules are open for public comment and the FMCSA Administrator, Raymond Martinez, is encouraging all drivers and CMV stakeholders to submit thoughts and opinions on the hours of service changes within the 45-day timeframe they have allotted. There is potential for the comment period to be extended.

Pausing the 14-hour clock has been discussed since last 2018 and may now become a reality.

Stay DOT compliant

Knowing these Hours-of-Service rules and regulations will allow you to stay compliant and plan your operations more efficiently.

All CNS services are geared toward keeping your trucking company safe and compliant.

If you have any questions, call (888) 260-9448 or email at info@cnsprotects.com.



July Spotlight: Brownsberger Transport Company


This month’s CNS Spotlight is on Brownsberger Transport Company of Lititz, PA.

Andrew Brownsberger—owner and driver of Brownsberger Transport Co.—has been operating since 2010. As a car hauler for the thriving auto auction industry in central Pennsylvania, he has grown to a 4-truck operation with plans to grow further in the future. Andrew has watched the industry change in the last few years with a much higher focus on Hours of Service (HOS), especially after the ELD mandate took effect in 2018.

We sat down to ask him a few questions on how he manages his HOS scores, logs, and his drivers in an ever-changing trucking industry.

CNS: Andrew, what issues did you find regarding HOS rules prior to the ELD mandate last year?

Brownsberger Transport Company, ELD mandate, HOS

Andrew: I think the 30-minute break rule is unnecessary. I don’t feel like that creates safer roads or working conditions. I do agree with HOS; we don’t want people driving over 11 hours. I know from my experience that I would be tired after 11 hours of driving.

CNS: Do you find yourself having any issues after the HOS mandate?

Andrew: Yes, although I agree with HOS. Paper logs are easier to use for many reasons. But with the new technology it makes it harder to correct simple mistakes that happen.

CNS: What system do you have in place for checking logs for your drivers at your company?

Andrew: Pedigree for the ELD hardware and software and CNS for consulting.

CNS: How has the use of the Pedigree Technologies CabMate One helped you regarding staying compliant with the HOS regulations?

Andrew: It clearly lets you know if you are in or going to be in violation.

CNS: Do you have any suggestions for other carriers that may be struggling with HOS rules and regulations?

Andrew: Driver training and being able to manage your work time better is key. If you are having trouble with making changes within the culture, hire CNS.

Brownsberger Transport Company, ELD mandate, HOS