For-hire, over-the-road carriers

Most Impacted. Reason: Irregular routes and schedules, combined with the driver and carrier’s desire to maximize the driver’s productivity when the driver is on the road, leads to this segment using the maximums available under the hours-of-service rules. This segment also has to interpret and apply the rules to a new operational environment daily, making any change problematic (there is no “operation pattern” that makes compliance easier for these carriers and drivers).

Line haul terminal-to-terminal operations that operate under normal HOS rules (including §395.8) and have terminal spacing and/or routes established to match the hours-of-service limits

Moderately Impacted. Reason: These carriers may see an impact, depending on their infrastructure age. The impact will depend on when the terminal spacing was done (older terminal patterns are still structured based on 10 hours of driving, so impact would be minimal). These carriers may also be impacted because of non-driving work the carrier is having the driver do after arriving at the terminal.

Regional carriers (carriers with 300 to 500 mile regional operations)

Moderately Impacted. Reason: These carriers tend to have trouble with sitting time (due to having to do a load and unload cycle at least once per day), meaning that their drivers typically have problems with the 14-hour regulation (which is expected to see only minimal changes). These carriers may see a favorable impact from the 16 hours twice weekly provision. Sidebar Note: Many regional drivers have difficulty getting 11 hours of driving consistently, unless they are using “flexible logging practices.” Because of this, these are the carriers that will be the MOST impacted by the EOBR regulations.

Private/dedicated carriers that operate “routes”

Moderately Impacted. Reason: These carriers will see an operational impact in that most routes have been structured to maximize the driver’s potential, while staying in compliance with the hours-of-service regulations. The change will require shortening some routes and retraining of driver to realize what changes in route routine would lead to compliance problems. Also, many of the private fleets have laid out their distribution facilities based on the hours of service. As with the terminal-to-terminal operations, the impact on these operations will depend on when the distribution facilities were established.

“Non-freight carriers”

Moderately Impacted. Reason: Carriers such as repair companies, service companies, construction companies (other than their “transport” operations), railroads, etc. that limit their drivers’ hours for other reasons will generally be moderately impacted. If these carriers have a problem with the hours-of-service it is typically with the 14 hour rule, not the driving rule (these drivers drive out to worksite in the morning, take a lunch hour, and then drive back in the evening, total of 2 to 3 hours of actual driving). Therefore, any changes to the structure of the 14-hour rule will impact these carriers, but changes to the daily driving limit will not impact these carriers. However, these non-freight carriers may actually see a positive impact due to being able to spend more time at the job sites due to the increase from 14 to 16 allowed twice a week.

P and D (local delivery) and linehaul operations that operate under the 100 or 150 air-mile exception

Least Impacted. Reason: These carriers seldom maximize the driver’s potential hours under the hours-of-service regulations. Many are limited under contract to overtime after 8 or 40, motivating the carrier to limit their hours for economic reasons. Also, for operational ease and ease of compliance these carriers tend to self-limit their driver utilization at 12 or 14 hours (CDL versus non-CDL) per day to keep the drivers operating under the 100 or 150 mile exception as much as possible.