This comment is a response to the Oilfield exemption concerning waiting time for drivers of CMV that are delivering supplies (Sand) to an oilfield location. These drivers are delivering the main ingredient for "fracing a well". From time to time something on location may cause a delay with the process of fracing the well which delays the supply chain of delivering the sand to the location. At this time the drivers are not required or responsible for assisting in getting the operation started again so they are actually waiting on the well which requires no attention to the truck. The drivers can actually get some rest and log "waiting on well site" which will allow them time to offload their truck and leave location to return back to their home terminal as long as driving time permits. While waiting on location when something is shut down drivers of CMV transporting sand have more options for rest than any CMV operators working on well site.
Freddie Richard - 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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