On behalf of truck crash survivors and families who lost loved ones in truck crashes, the Truck Safety Coalition supports the Federal Motor Carrier Safety Administration’s (FMCSA) December 18, 2017 Electronic Logging Device (ELD) implementation deadline.
Updating the methodology by which truck drivers log hours, which dates back to the 1930s, has been long overdue. ELD technology will reduce the ability of bad actors to skirt federal regulations by modernizing the practice of logging hours. This mandate will also protect truck drivers from being coerced to exceed the hours they are allowed to operate because ELDs automatically record driving time, and therefore truck drivers cannot circumvent compliance by simply writing down false hours.
Additionally, the ELD mandate will enhance law enforcement officers’ capacity to enforce HOS restrictions and expedite the process of reviewing a truck driver’s logbook. The shift from paperwork to electronic logging will save not only time, but it will also produce a benefit or more than $1 billion, according to the FMCSA.
After working for more than two decades to produce a final rule that requires large trucks to be equipped with Electronic Logging Devices, the Truck Safety Coalition opposes any further delay. The ELD Final Rule will save an estimated 26 lives and prevent 562 injuries resulting from large truck crashes each year. We cannot fathom why anyone would direct an agency, whose mission is to promote safety, to consider a delay that would result in an estimated 52 fatalities and 1,124 injuries over two years.
Electronic Logging Device (ELD) Rule in Effect on December 18, 2017
Implementation of Electronic Logging Devices (ELDs) –The Moving Ahead for Progress in the 21st Century Law, MAP-21 (P.L. 112-141) required FMCSA to issue a rule mandating ELDs in all commercial vehicles within one year, by July 2013. The final rule for ELDs was issued on December 16, 2015 and requires compliance starting on December 18, 2017. TSC looks forward to the full implementation of this rule and opposes any calls for delays or exemptions.
Preventing Exemptions to HOS Regulations – Exemptions to federal motor carrier safety regulations compromise safety, erode uniformity and weaken enforcement efforts. Safety is not unique to certain types of commercial motor vehicles, carriers, cargo or routes. Allowing industry-specific exemptions to safety regulations is not only dangerous, but it also sets an unsafe precedent for other industries to request similar exemptions. TSC opposes exemptions to HOS regulations through the legislative process for these reasons.
Assuring Truck Driver Fitness – TSC supports rulemaking for sleep apnea screening to ensure medical examiners are testing for and monitoring this fatigue related condition. We urge the review and regulation of legal Schedule II prescription drugs and/or use of any substance that impairs cognitive or motor ability.
Supporting Changes to Truck Driver Compensation – A large portion of the trucking industry is paid by the mile rather than by the hour. Truck drivers work nearly twice the hours in a normal workweek, for less pay than similar industries. As a result of their pay structure and because they are not paid for all hours worked, there is an incentive to drive longer and faster in order to increase their earnings. Paying truck drivers for every hour worked will promote safer trucking by removing incentives to dangerous driving behaviors.
Truck driver fatigue has been recognized as a major safety concern and a contributing factor to fatal truck crashes for over 70 years.
A study sponsored by the Federal Motor Carrier Safety Administration (FMCSA) found that 65% of truck drivers report that they often or sometimes feel drowsy while driving and nearly half of truck drivers admit that they had actually fallen asleep while driving in the previous year.
In spite of the industry wide safety issue of truck driver fatigue, in 2003, the truck driver hours of service rule (HOS) was changed, increasing the number of hours a driver can be behind the wheel from 10 to 11 consecutive hours in a 14-hour work window.
Electronic Logging Device Final Rule