Thursday, February 17, 2011

CSA 2010 and HOS - The Perfect Storm for the Trucking Industry

New CSA regulations regarding the BASIC of Fatigued Driving and the proposed changes to the Hours of Service Regulations has the potential greatly affect many operations in the produce industry. This month, UWC reviews some of the primary principles of this topic.

A review
The Fatigued Driving BASIC measures the operation of Commercial Motor Vehicles (CMV) by drivers who are ill, fatigued, or in non compliance with the Hours-of-Service (HOS) regulations. This BASIC includes violations of regulations pertaining to logbooks as they relate to HOS requirements and the management of CMV driver fatigue. Example violations are: Exceeding HOS, maintaining an incomplete or inaccurate logbook, and operating a CMV while ill or fatigued.

Another important factor to note with regards to CSA in general - Whether a truck is passing through a scale or is cited for any infraction, there is immediate online access to their record by the agent, whether it be by a scale or a state trooper for example. Further, if there is an alert or high score on any one of the BASICs, it will prompt a further inspection (probable cause) of the truck and driver’s logbooks.

FMCSA proposed changes to the Hours of Service rule are as follows
Reducing the driving time from 11 hours down to 10, and reducing the entire on duty time from 14 hours down to 13. These changes are presently at Senate, with many groups lobbying for and against the changes. The FMCSA is required to publish a final HOS rule by July 26, 2011, and UWC will continue to monitor.

In a perfect world...
It would always be sunny and dry on the roads, there would be no construction or detours, and loading and fueling would be instantaneous. Unfortunately, those ideas are implausible. Weather, construction, detours, fueling and loading delays all compound the issues facing drivers under the new CSA 2010 and proposed HOS regulations. Weather delays are common, often unpredictable and can cause various delays and bottle-necks on the highways. Construction and ongoing efforts to improve the nation’s highways are necessary work that also causes delays. Detours, resulting from both weather issues and construction are typically a “long-way round” that take up more driving time. Fueling typically takes up to 1 hour, and loading at pickup sheds can sometimes take the better part of 6 hours.

As we can see, there are many external “on duty” issues that can affect a driver’s Hours of Service and logbook calculations. These issues add pressure to drivers to arrive at destinations when initial drive times are already tight. So now, let’s look at an example of how a driver would have to operate in order to be in legal compliance with the CSA 2010 Fatigued Driver BASIC measurement and the HOS Regulations.

Trip: Yakima, WA to Nogales, AZ: Approximately 28-30 hours of driving time (this includes the breaks and fuel stops). Driving time formula with legal HOS Regulations: 11 hours consecutive driving once loaded + 10 required hours off + 11 hours of consecutive driving + 10 required hours off + 6-8 hours of driving to arrive at final delivery = 48-50 hours from loading to time of delivery. Therefore, in order for a driver to make a 2nd morning 7am delivery to Nogales (a common request ), the truck would have to be loaded and on its way by 7am in the morning 2 days prior (7am loaded and gone on Monday for a 7am Wednesday delivery).

With expectations and competition for loads on the rise, some drivers will be willing to gamble . However, this is likely to be only for the short term, as roadside inspections and enforcement of the CSA 2010 are ramping up. Compliance is not only essential, but NECESSARY for truck drivers and carrier companies to stay on the road and in business. All participants in the supply chain (shippers, customers, transportation providers, drivers, and receivers) need to be aware of the changes, so that driver expectations can be realistic and met.

For more information on CSA 2010, contact UWC directly, or visit http://

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