I’ve created a chart to simplify this complex HOS amendment that highlights the specific HOS rule change, the existing and revised requirement, and the results.
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|HOS Rule Change||Existing Requirement||Revised Requirement||Result|
Short haul drivers must:
Short haul drivers do not have to prepare RODS, use ELD, maintain supporting docs or take a 30-min break.
Only need to keep timecard records for 6 months.
Drivers using the Non-CDL short-haul (150 air-mile radius) may not drive beyond the 14th or 16th hour on-duty, depending upon the number of days on duty.
Extends the maximum duty period allowed under the short-haul exception from 12 hours to 14 hours.
Extends the maximum radius of the short-haul exception from 100 to 150 air- miles.
Increases the number of drivers able to take advantage of the short- haul (150 air-mile) exception.
Potentially shifts work and drive time from long- haul to short-haul exception, or from driver to driver.
Those drivers will not need to prepare daily RODS, nor need ELDs.
Minimum or no change to hours driven or aggregate vehicle miles traveled (VMT).
|Adverse Driving Conditions||
Drivers get 2 extra hours in the 11-hour driving limit.
Adverse driving conditions does not currently extend the 14-hour “driving window.”
Increases the 14-hour driving by 2 hours to make it a 16-hour driving window.
This change applies both to drivers of property-carrying CMVs (14-hour “driving window”) and passenger- carrying CMVs (15-hour “driving window”).
Increases the use of the adverse driving condition provision.
Allows driving later in the workday, potentially shifting forward the hours driven and VMT.
Allows drivers time to park and wait out the adverse driving condition or to drive slowly through it. This has the potential to decrease crash risk relative to current requirements, assuming drivers now drive through adverse driving conditions.
No increase in freight volume or aggregate VMT.
|30-Minute Break||Drivers must take at least a 30-min break in off-duty status after 8 hours of being on-duty, which includes driving.||
Requires a 30-minute break only when a driver has driven for a period of 8 hours without at least a 30-minute interruption.
If required, the break may be satisfied by any non-driving period of 30 minutes (i.e. by on-duty, not driving time, off-duty, or sleeper berth time.)
Drivers are able to use on- duty time such as loading, unloading or fueling time to count towards the 30-min break.
If a driver starts a day with 2 hours on-duty and then starts driving, the driver will not need to take a break until having 8 hours of driving rather than after 8 hours of being on-duty-not-driving in the day.
Increases the on- duty/non-driving time by up-to 30 minutes or allow drivers to reach their destination earlier.
No anticipated fatigue effect because drivers continue to be constrained by the 11- hour driving limit and would continue to receive on-duty/non- driving breaks from the driving task.
Minimal or no change to hours driven or VMT, as the current off-duty break only impacts these factors if the schedule required driving late within the 14-hour driving window.
Drivers can use the sleeper berth to get the “equivalent of at least 10 consecutive hours off-duty.”
Drivers must spend at least 8 consecutive hours (but less than 10 consecutive hours) in the sleeper berth. This rest period does not count as part of the 14-hour limit.
A second, separate rest period must be at least 2 (but less than 10) consecutive hours long.
This period of 2 hours or more may be spent in the sleeper berth, off-duty, or sleeper berth and off-duty combined.
This period of 2 hours or more does count towards the maximum 14- hour window.
Drivers can split the 10 hours as 8 hours in sleeper berth and 2 hours in off duty; or 7 hours in sleeper and 3 hours in off duty.
Neither period counts against the maximum 14-hour diving window.
Allow one hour to be shifted from the longer rest period to the shorter rest period.
Allow drivers to pause the 14-hour window by a single off-duty rest of up to 3 hours.
Potentially increase the use of sleeper berths because drivers using a berth have additional hours to complete 11 hours of driving (by virtue of excluding the shorter rest period from the calculation of the 14-hour driving window).
No anticipated negative effect on fatigue because aggregate drive limits and off-duty time remains unchanged.
Hours driven or VMT may change for an individual driver on a given work shift (by increased use of the sleeper berth). Total hours driven or aggregate VMT would remain the same.
|Split Duty Provision||
Drivers must not drive past 14 hours of coming on-duty after a 10–hour rest.
The 14-hour window is consecutive hours and does not pause for any periods of off- duty except for the 8 hours or more in sleeper berth.
Drivers can pause the 14-hour window by a single off-duty rest of up to 3 hours.
Significantly more flexibility than the current rules by allowing drivers to take an off- duty rest without fear of depleting their available hours on the 14-hour clock.
Incentivizes the driver to voluntarily take
longer rest breaks as needed.