Report Examines Alternate Hours-of-Service Options

A report regarding a solution to the hours-of-service dilemma recently uncovered inadequacies in all of the federal government's proposed plans.

Released Sept. 10, the report was assembled by the Transportation Research Institute of the Regents of the University of Michigan.  It includes information from experts in truck and traffic safety, human factors, and sleep and fatigue.

"Potential Hours-of-Service Regulations for Commercial Drivers," prepared under contract for the Federal Highway Administration, states that none of the hours-of-service options examined met all of the criteria the expert panel deemed to be most important.

The group judged four alternate policies (lettered B through E) based on several criteria, including:  continuous time off duty, adequacy of recovery time at week's end, limits on total on-duty time, etc.

None of the four alternates adequately addressed the panel's concerns about split shift drivers, use of a sleeper, foreknowledge of work schedule, or limiting the amount of nighttime driving allowed.  They did, however, all adopt a 24-hour cycle.

The current 18-hour cycle received an extremely poor rating.  The report concluded that this cycle, "fails on every criterion identified by the panel as important for a reasonable hours-of-service policy."

All of the other options scored higher, but still received comments such as "not acceptable," and "includes many major short-comings."

The various options submitted for evaluation by the FHWA are outlined in the chart at the bottom of this page.

In addition to evaluating the current and alternate policies, the committee formulated an "ideal" by which all criteria were successfully met.   This "Option F" would allow for 12 hours of on-duty time (all of which may be spent driving), and 12 hours off-duty.  Drivers would have to limit their midnight to 6 a.m. driving to 18 hours in a six-day period.

While Option F did allow for extended driving time and sufficient resting periods, the panel acknowledges that restricting the amount of night driving could yield more accidents, because drivers would be forced to travel during daylight, when highways are more congested.

"We do not present this option as the one that should be adopted." the report states. "Rather, it is our attempt to translate the scientific evidence...into a workable policy."

George Reagle, associate administrator of the Office of Motor Carriers, declined to speculate on a specific date for Notice of Proposed Rule Making.   However, he says feedback on the study has been plentiful.

"We have received and are analyzing approximately 1,600 comments,"  he says.  "Hours of service remains a high priority for us and we are moving with all due speed."

Land Line asked Reagle if the options examined by the panel are the only options under consideration by the FHWA. "No, absolutely not," said Reagle.   "We're concentrating on the importance of rest cycles rather than work cycles.   We must have a cycle based on a 24-hour clock and al the scientific evidence relating to fatigue available to us.  And we must look at all the different types of operations within the industry.  What may be the safest solution for one operation may not be the safest option for another type of operation."  LL 

Jason Cisper        

Option B requires a minimum of nine consecutive hours off duty for sleep and one hour for personal time, and 14 hours of on-duty time (12 of which may be used for drive time).   Additionally, the cumulative on-duty time is limited over a two-week time frame to 140 hours with a 24-hour break every six days.

Option C differs slightly from option B.  It increased the minimum additional hours off duty allowed for personal time from one hour to two hours.  On-duty time is reduced from 14 hours to 13 hours, with 12 hours of drive time.  Drivers can accumulate up to 72 hours of on-duty time in a six-day period.  At the end of the six days, the driver will be required to rest between 36 and 84 hours (allowing two midnight to 6 a.m. sleeping periods) before starting over.

Option D provides for nine consecutive hours off duty for sleep and three hours of personal time.   On-duty time is a maximum of 12 hours, all of which can be used for drive time.   A maximum of 72 hours can be accumulated over a six-day period, followed by a minimum break of 36 hours, followed by 48 more on-duty driving hours, and a minimum break of 84 hours.   

Option E also calls for nine consecutive hours off duty for sleep and three hours personal time.   Twelve hours can be spent on duty;  a maximum of 10 hours can be used for drive time.  The policy is based on a two-week cycle, allowing 72 hours in six days followed by a rest period that includes two uninterrupted periods of time from midnight to 6 a.m.