Jay Shelly - Comments

As the defination clarification for what is considered "waiting time" at a well site for drivers of vehicles that are specifically designed for the servicing of oil, gas wells is still not clear in the proposed Regulatory Guidance for Oil Field Exceptions. As the clarification defines these drivers as being trained to operate the complexed equipment that the CMV trasnport to and from the work site of an oil or gas well tends to be "leased drivers" and have no expectations to complete additional work once at the site, and are considered "off duty not driving" while waiting on the site for their operations of the specialized equipment, pumps etc. The clarification leads the reader to beleive that the driver has no to little work role while waiting for the equipment to be released for further transport. If this clarification is to be clear it must state that the driver must be releived from duty and have no additional work that they are being paid to do, or required to do. If a driver takes a specialized vehicle to a well site and transitions from a driver to a well hand, or operates specialized equipment that is mounted to their vehicle in the course of the well service, then the driver / operator may limit the total available time in which to continue to drive the CMV. As a normal course of understanding the guidance as published does not fully clarify how a driver must report their time worked, and leads the readed to misunderstand that the driver might be able to report off duty not driving for all the time they are at a well site.