The HOS rules attempt to cover every possible fringe case of driver fatigue at the expense of simple, easy to follow rules that every driver can understand. Where are the studies that show each type of accumulated fatigue and its calculated frequency on overall crash rates?
FMCSA may find that 95% of fatigue related crashes are covered by a simpler HOS rule set and that compliance with a simpler rule set would more than compensate for the fringe case scenarios covered by more complicate rule sets. Simple rules that are easy to understand will minimize confusion and stress and raise voluntary compliance.
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Agency Information Collection Activities; Proposals, Submissions, and Approvals Driver and Carrier Surveys Related to Electronic Onboard Recorders and Potential Harassment Deriving From Use
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