Hope L. Brown - Comments

I dont understand why FMCSA feels that it must keep changing the HOS to benfit PUBLIC CITIZEN? What about this for HOS Proposed Rules. Here is my proposed HOS RULE.. 1. Keep the 11 hour driving rule. 2. Keep the 34 hour restart rule. 3. Keep the 10 hour sleeper berth rule, but make it so that a 3 hour sleeper berth period will stop the 14 hour clock. Why make it so difficult that a driver will be in violation of the HOS Rules if he draws a .25 pre-trip/post trip line from sleeper/off duty to on duty not driving or on duty driving. I am the Safety Director for my company of 9 company drivers and 5 owner operators and I check and do all logs by hand, no fancy machine or scanner. I used to drive myself and logging or driver's daily log reports were and still one of my best areas. I can look or glance at log and see violations and alot of my driver's have the hardest time with the 10 hour sleeper berth rule and the 14 hour rule and they think that a 2 hour sleeper berth still stops the 14 hour clock. I also find that some of my older driver's flip between the old 10 hour driving and the new 11 hour driving rule. I just think we should try to make HOS Rules benfit the one it's is supposed to the DRIVER, not the carrier,shipper,consigne. The rules are to promote safety on behalf of the DRIVER, why not make some HOS RULES that actualy do just that, benefit the DRIVER and that will make him/her much safer on their travels with PUBLIC CITIZEN who is usualy the 99.9% reason why a rested safe driver is involved with a fatal or critical accident. It's not always the Professional Driver's mistake. Just this Safety Director's opinion.