In regards to the oilfield exemption, I feel there is a huge potential for abuse of the driver. As this law stands, only those actually doing the work at the well sites with specialized equipment are allowed all of the exemptions. If this is changed to allow any drivers providing materials to a well site to utilize both exemptions it will allow transportation managers to push the drivers to crazy and unsafe extremes. I have witnessed this on a first hand basis, and this practice flies in the face of the fatigued driving that we all are trying to eliminate. There are a few companies that will try to ensure the drivers get plenty of rest, however there are far more that will put profit and productivity first, and some will punish drivers who complain or refuse to run if they are too tired. The other danger is that even though a driver is off duty at the well, he or she may not be tired or ready for sleep. If they sit for extended period of time, they may have plenty of hours to drive, but are now tired and fatigued. This creates a dangerous situation for the driver, the motoring public and those working around the driver such as well hands. We should protect the drivers from the kind of companies that will seek to exploit them and the laws to favor a bigger bottom line. With the current law, the drivers are the operators of the equipment on the well site and typically work 12 hour shift, although they too could find themselves working or even being on standby and then forced to operate when very tired. I propose 12 hour shifts with no more than 6 days of work before a mandatory 24 hour rest period before the driver is allowed to drive. If the driver is OTR then the regular rules should apply as they do for all other drivers. The only exception would be emergencies.
Tim A. Lester - Comments
This is comment on Rule
Hours of Service of Drivers of Commercial Motor Vehicles: Regulatory Guidance for Oil Field Exceptions
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