Russell S. Gaillard - Comments

I support the Trailways bus companies request for an indusrty exemption to the Federal regulation (49 C.F.R. Part 395.8(c)) that requires drivers to log as off duty the brief stopsmade for boarding passengers and or baggage etc. I request that these drivers be exempted from the requirement to enter a change in duty status on the daily log for breaks in driving time of 10 minutes or less, for the limited purposes such as picking up or discharging passengers, baggage and or package express items. Such time would not be considered a change of duty status for the purposes of 49 C.F.R. 395.8(c) The "exemption" is a common industry practice that was approved and authorized in a rule making interpretation requested by Greyhound in 1996. According to FMCSA, this interpretation was somehow not included in its 1997 compilation, so it is currently no longer an exemption and has not been since 1997. The exemption became more important in 2011, when law enforcement and DOT agents began writing this practice as violations, which now affect drivers' system safety ratings, as well as the carriers system rating in FMCSA's public record. There are frequent occurances when it takes longer to actually log the stop than the actual time that the stop lasted, I am sure this is not what the FMCSA had in mind when it put the regulations in place.