HOS: A Practical Guide to the New Rules

By Mark Montague

It’s now July, and the Federal Motor Carrier Safety Administration has started to enforce new hours of service (HOS) regulations for truckers involved in interstate commerce. Already, we’re seeing the impact on fleet productivity and driver work hours (and their corresponding pay). Some hauls simply take more time, increasing costs and causing schedule adjustments up and down the supply chain.

Consider how the new HOS rules can complicate a trip from Chicago to Houston, typically a two-day haul.

Day 0: Saturday, 2 a.m.

A driver returning from Grovesport, Ohio, pulls into his terminal in Chicago at 2 a.m., two hours late because of a delay en route. He parks his truck, retrieves his personal car, and goes home to sleep.

Ordinarily, the driver would pick up his next load on Sunday night to avoid Monday morning commuter traffic leaving Chicago. But because the 34-hour restart period must include at least two off-duty periods between 1 and 5 a.m., the driver isn’t eligible to drive again until 5 a.m. on Monday. That’s 51 hours away, which means the driver got a 17-hour penalty for that one-hour delay.

The restart period mandating two 1 a.m. to 5 a.m. periods has come under much criticism because it can make it more difficult for truckers to avoid rush-hour traffic. If there are no major delays, a 5 a.m. departure on Monday should give the driver plenty of time to reach Houston by 3 p.m. on Tuesday. The 1,088-mile trip usually takes about 19 hours of driving, and he has 34 hours to complete it.

Day 1: Monday

5 - 5:30 a.m. The driver arrives at the terminal in Chicago. He finds and hooks to his trailer and then conducts a pre-trip inspection. Although he departs at 5:30 a.m., his on-duty clock is already at 30 minutes.

5:30 - 6:45 a.m. As it turns out, I-55 is jammed. It takes an hour and fifteen minutes to run the 39 miles to Joliet.

6:45 a.m. - 1 p.m. The morning goes better until Mount Vernon, Ill., where construction has created a single lane of traffic and a half-hour is lost. The driver takes his mandatory 30-minute break; it's lunchtime, so he takes an extra 15 minutes to eat and stretch his legs.

1:45 - 2:45 p.m. The driver gets back on the road for an hour and then stops for coffee. He checks his email and phones his dispatcher.

3:15 - 6:15 p.m. Three more hours of driving. Now in West Memphis, Ark., the driver has maxed out for the day. Required to take a 10-hour rest, he refuels, inspects his rig, and then logs off duty at 7 p.m., which is 14 hours since he entered the terminal that morning. All told, the driver has covered 559 miles in 11 hours of driving.

Day 2: Tuesday

4:15 - 5 a.m. The driver wakes and is ready to go at 4:15 a.m., but he has to wait until 5 a.m. to start driving because his 10-hour off-duty clock didn’t reset until 7 p.m. the night before.

5 - 9:30 a.m. At 7 a.m., just outside of Little Rock, the Arkansas River bridges are choked with traffic. It takes half an hour to travel 22 miles. Later, an accident in Texarkana causes another delay. Now the driver is worried. Will he make his 3 p.m. appointment in Houston?

Let’s see. He has 5.5 hours to cover 295 miles, which would require an average speed of 53.6 mph and no delays. Plus, he’s required to take a 30-minute break before he has driven eight hours.

Houston, we have a problem. The driver knows that if he misses the 3 p.m. slot by more than half an hour, he will be rescheduled. He also knows that this particular dock only performs outbound loads in the mornings, so his next available appointment for unloading wouldn't be until 1 p.m. the next day.

Does the driver call his dispatcher and ask to be rescheduled? Should he just keep going and try to talk his way into a late drop-off at the dock?

I know that commercial truckers, brokers, and their customers face HOS-related scheduling dilemmas frequently enough, but the new rules have the potential to affect your supply chain. Carriers may be more inclined to charge customers for detention and delays. Drivers who regularly use the current 34-hour restart may lose productivity depending on what time of day they begin the new restart period.

These and other factors could add to pressure on rates. Alarm bells are ringing, and hitting the snooze button on HOS isn’t an option.

Mark Montague is the industry freight analyst for DAT, which operates the DAT® Network of load boards and RateView analysis tool based on the matching of more than 68 million spot (non-contract) loads and trucks per year. He holds an MBA in Transportation from Indiana University as well as a Bachelor of Science degree in mathematics and has applied his expertise in rates and routing for carriers, 3PLs, and shippers for more than 30 years. He is based in Portland, Ore. For information visit www.dat.com.