Hours of Service (HOS)

Regulatory Alert: ELD proposal officially published

The hours-of-service regulations place restrictions on when and for how long drivers of commercial motor vehicles (CMVs) may be behind the wheel. For more than a decade, change has been a constant with these regulations, with more revisions planned for the future.

The latest major revisions took effect on July 1, 2013, for drivers of property-carrying CMVs. These drivers now need mandatory 30-minute rest breaks and must deal with more restrictions on use of the 34-hour "restart" provision (a recent final rule exempts short-haul drivers from the break requirement). Other changes effective February 27, 2012, affected all CMV drivers, including those operating buses and motorcoaches.

View the final rule that contained all these changes, and take a look at some Hours of Service FAQs. Make sure you’re compliant or your CSA scores may take a hit!

J. J. Keller will help you stay on top of the latest HOS developments by informing you of the latest news and reference materials. As a top supplier of log books, training materials, and log auditing solutions, we can also help you comply with HOS regulations.

We also offer Canada-specific log books and training that addresses Canadian hours-of-service regulations, as well as logs for oilfield operations.

The U.S. federal hours-of-service regulations, with a few exceptions, apply to all motor carriers, drivers, and CMVs that transport property or passengers in interstate commerce. In-state requirements may vary.

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HOS Solutions

As a top supplier of log books, training materials, and other log auditing solutions, J. J. Keller has the experience to help you comply with hours of service regulations. See below for compliance solutions.

Hours of Service and CSA

Hours of Service plays a pivotal part in the CSA HOS Compliance BASIC. J. J. Keller offers a wealth of resources and solutions to help you address CSA and the HOS Compliance BASIC. Get more information.

New HOS Regs

The federal hours-of-service regulations for drivers of property-carrying CMVs changed as of July 1, 2013. The resources below can help give you insight into these new regulations.

How are you impacted? Select you operation type:

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

Impact of Hours-of-Service Changes

All carriers, with the possible exception of carriers that operate entirely under the 100- and 150-mile exceptions will feel some impact from any change to the hours of service. The impacts include …

  • Retraining all drivers.
  • Retraining dispatch, compliance, and safety staff.
  • Updating compliance software.
  • Updating dispatch and optimization software.
  • Reviewing operational routing and customer commitments.
  • Reviewing of infrastructure (company facilities, fuel stops, etc.) compared to driver limitations that new rules could bring about.
  • Reviewing revenue versus cost due to new operational model to determine if rates are still adequate.

EOBR/ELD Regulations

Visit our On-Board Technology page.

An EOBR / ELD is attached to commercial vehicles' engines to capture speed, distance and driver location (GPS) data. EOBR / ELD systems also typically require driver interaction — to provide duty status details (produce electronic logbook) or vehicle inspection information (produce electronic DVIR), for example. The data captured by an EOBR / ELD can provide critical assessments of fleet and driver performance, helping companies make decisions to improve operations.

On March 28, 2014, the Federal Motor Carrier Safety Administration (FMCSA) published a new proposed rule to require all CMVs operating in interstate commerce and subject to the federal logging rules in Part 395 to be equipped with EOBR / ELD technology. As mandated in federal law, the proposed rule would require affected drivers to start using EOBRs / ELDs within 2 years after the final rule is issued.

For more information on the EOBR / ELD rule, as well as J. J. Keller's ELD and electronic logbooks, visit our EOBR / ELD and E-Log Technology page.

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