In the news lately is the possibility of Hour of Service (HOS) reform once again. We often hear drivers and company owners talk about how FMCSA does not have a clue and how they are sitting behind desks making decisions for us. Yet for years our industry reported to them that we had absolutely no problems. You may ask what do you mean no problems? Just Imagine… you are the FMCSA, and you are auditing logbooks. How many traffic delays, delays at the dock, or weather-related problems would you be able to document back in the days of paper logbooks? Yet at the same time, we would complain publicly about the hours lost during traffic congestion, dock delays, and time spent searching for a parking spot for our rest period.
When log book audits were performed however very little of these problems were documented for the record. My question is how could the FMCSA create rules for us to operate under when as an industry we reported there was not a problem. From what I am reading in today’s headlines, FMCSA now has more accurate documentation than ever before. It should be interesting to see how the HOS are reformed now that they have “real” data. The data they are getting today is still not perfect as I am sure that all of the dock time is still not being recorded as on duty.
The question becomes, do we consider ourselves to be at work while sitting at the dock or do we have no value upon this time? The problem with this industry is that we are not a bunch of lazy people. There is no other industry that I know where the workers try to get themselves off of the clock as often as possible to preserve their time so that it is available for the task of driving.
Is the problem that we have in our industry that the majority of our wage and value comes from the task of driving and not the time we spent at a dock, securing loads, tarping loads, and any of the other tasks we perform in a given duty cycle.
So, the question is how can we expect FMCSA to create rules that reflect the tasks we perform in any given day if our record of duty service does not reflect the work we perform daily.