Susan Gamba - Comments

Document ID: FMCSA-2012-0183-0002
Document Type: Public Submission
Agency: Federal Motor Carrier Safety Administration
Received Date: June 05 2012, at 12:00 AM Eastern Daylight Time
Date Posted: June 6 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: June 4 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: August 6 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 810358e0
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I work in the transportation industry servicing the Frac-ing industry in South Texas. My company runs approximately 60 trucks. I find that our drivers usually sit idle at well site for anywhere from 6 hours to 4 days waiting for mechanical issues to be resolved and/or excess trucks in line to unload. I feel that not allowing frac sand drivers to take advantage of the oilfield exemption is unfair to them - sitting in their trucks not working at all - not being responsible for anything for such long periods should not count against their 14 hours. Line 5 - oilfield exemption does not 'hit' their 14 but lines 1 and/or 2 do. There is no harm in allowing frac-ing carriers to use the oilfield exemption - the drivers are resting and relaxing while on 'stand-by' hence in better shape to continue driving after getting unloaded.

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