Anonymous - Comments

I am one of the principals in a small 40 unit frac sand carrier based in South Texas. Our drivers service well sites throughout Texas while primarily servicing South Texas. The amount of billed demurrage (waiting time to load and/or unload) is measurable; we have drivers sitting on-site waiting to off load their sand for hours at a time. We have had drivers sitting on-site for upwards of 4 days on a regular basis. Having our drivers comply with the 14 hour rule while not being able to use the oilfield exemption is to our/their disadvantage – here is an example: Driver #1 starts his day at 3am in Three Rivers, Tx – does his 15 minute PTI and begins driving at 3:15am. He drives 45 minutes to Whitsett, Tx to load a load of sand; this loading takes 45 minutes. At 4:45am, he leaves the loading facility to drive to Shiner, Tx to unload. This trip takes 2.5 hours. At 7:15am, Driver #1 arrives at the well location in Shiner. He is put in the staging area and told it may be a while. He then sits for 7.5 hours before unloading. 2:45pm he begins to unload and is finished at 3:45pm. Without the oilfield exemption, Driver # 1 is only able to drive until 5pm – an additional 1.25 hours. His total hours driving for this period is 4.5 hours and on-duty not driving only 2 hours. During the 7.5 hours waiting, Driver # 1 may have read a book, relaxed or simply slept. How can he be too fatigued to drive? Why should the 14 hour rule prevent him from driving past 5pm when he is refreshed, alert and his dispatcher has another load just like this example for him? If Driver # 1 were allowed the oilfield exemption – Driver # 1 could easily drive back to Whitsett (2.5 hours), reload (.75 hour) and then drive back to Shiner (2.5 hours); without being over the 14 hour rule. His total driving hours would be 8.25 and on-duty not driving would be 2.75 for a total of 11 hours working and being back to Shiner at 9:30pm.