Open Season on GPS Records

In December, 2008, the FMCSA quietly issued a rulemaking in which it served notice that it could check GPS records during an audit without restrictions. In 1997, the FMCSA had set its previous policy on GPS, which was that they were off limits, except in certain limited circumstances. The present policy says investigators can check those records, if they wish.

The Midwestern Service Center for FMCSA, which covers from Ohio to Nebraska, is checking these records in every audit they conduct, no questions asked. For example, if you are a carrier in Iowa, and you get audited, the inspector is going to ask for your satellite records. If you use Qualcomm, Peoplenet, or any other type of satellite tracking for your trucks, you will have to turn over those records, and they will be compared against the logs.

This is a major deal. I’m sure many of you over-the-road carriers have been audited previously, and have passed. It is very likely if you get audited again, you will not pass. GPS records have dozens of timed locations of each truck per day. The chances of the driver matching all of those locations to his logs exactly are not good.

The rules are these: If a record is generated, you must retain it for six months. In other words, if your GPS is set up to ping the truck once an hour, you will have to produce for DOT during an audit 24 timed locations per day, for six months. If your GPS is set up to ping the truck once a day, you need to produce 1 timed location per day, for six months.

There is no requirement to utilize GPS. If you decide to turn off your GPS, no records are generated, therefore, you do not have to turn over any GPS records during an audit. If the record is created, you must give it to the auditors. All motor carriers who use GPS should prepare themselves for this type of audit, especially if you are in the Midwest. Your Satisfactory rating depends on it.

DOT Signals Change in the Hours of Service Rules

After defending the new hours of service rules since 2003 when they were implemented, DOT is waving the white flag, surrendering to the safety crazies. In late October, 2009, DOT Secretary Ray LaHood announced the agency was starting over in developing an hours of service rule. In exchange, Public Citizen and the safety crazies have suspended their lawsuit against the agency. Quid Pro Quo.

The DOT has said they will have a proposed rule in 9 months, and a final rule in 21 months. If they stick to this timetable, this means you will have a new set of hours of service rules to work under in 2 years. My guess is they will adhere to the timetable, since the rewrite is going to be relatively simple. I believe (and I have no inside information on this, it is merely my educated guess), the new rules will be a 10 hour rule, instead of 11, the 14 hour rule will stay the same, and we’ll lose the 34 hour restart of the 70 hour rule. That’s my guess, although it might be worse than that, since Joan Claybrook is writing the rule.

The new rule will not prevent any more accidents than the current rule. Bank on that. It will make transportation more costly and less efficient. These costs will be partially absorbed by the industry, although most of them will be passed along to the consumers. So prepare yourselves: in 2 years you will not be allowed to work as many hours as you do today.

Here We Go Again…….

Well, once again, do-gooder groups are suing the FMCSA. They are demanding the Courts force the agency to reduce the number of permissible hours of service. This has been dragging on for so long, I’ve basically lost track of the details. Please go to the link for accurate details. From my memory, in short, FMCSA changed the rules around six years ago. They eliminated the 15 hour rule, created the 14 hour rule which everyone loves so much, made it an 11 hour rule, instead of 10, and created a 34 hour reset provision for the 70 hour rule.

So FMCSA gave some, they took some. The 11 hour rule, and the 34 hour reset are good for the industry; it allows drivers to work longer hours. The 14 hour rule, not so much, it restricts severely the number of hours a driver can work. Nevertheless, that was the rule, and everyone found they could live with it. The FMCSA has determined the new rules have not caused carnage on the highways. In fact, they believe it has made the highways safer. Believe it or not, I think they are probably right, which is one of the few times where I can say, “I agree with the FMCSA”.

Then you have these “safety” groups. I put the word safety in quotes, because frankly, I don’t think their concerns have anything to do with safety. It’s all about control. These guys are NEVER satisfied. Ever. These are mostly the same people that want to do away with trucks altogether, because they emit hot air, make a lot of noise, and are scary looking to your average Prius driver. No, you can’t satisfy these people. If someone gets hurt in a truck crash, by God, there needs to be a Government regulation which prevents that from happening in the future. So they have been suing relentlessly, hoping to find a liberal lawyer-judge who will create a much more restrictive regulation. They have to go through the Courts, because Congress won’t give them what they want. Even the Democrats in Congress know their crazy demands are unreasonable.

This used to be a free society, and with freedom comes risk. There is a balance. But not to the “gooder” groups, oh no. All safety, no freedom. So they are suing yet again, demanding less hours. Will reducing the number of hours that can be worked reduce truck deaths? Probably not. All it will do is cost everyone more money in increased food, gas, and housing costs. If the truckers have to work less hours, it means they have to put more trucks on the road, to move the same amount of freight. More trucks, more traffic, more chance of them running into something. Yes, the “gooders” are the kings of unintended consequences. Then, again, their intention isn’t safety anyway is it? It’s control.

So that’s my rant on that, the bottomline is the rules are the same, and will stay the same for the forseeable future.

Chippewa Falls Bus Crash Story

chippewa-falls-busHere is the story of the Chippewa Falls Bus Crash, which happened early Sunday morning, October 16, 2005, on I-94 westbound, near Osseo, Wisconsin. At approximately 01:58, a tractor trailer overturned, blocking both lanes of the westbound I-94. About one minute later, a 55 passenger motorcoach, operated by Chippewa Trails, Inc., and carrying members of the Chippewa Falls High School Band smashed into the overturned trailer, blocking the highway. Five people in the bus, including the driver, were killed. This is their story.

If you want the whole story, go here for the NTSB report, dated September 16, 2008. The summary below is taken from the NTSB report.

Around 19:30 on Friday night, 22 year old Michael Kozlowski departed Munster, IN, in a Whole Foods Market, Inc. tractor-trailer, bound for Minneapolis, MN. At 01:58, Kozlowski was approaching milepost 85 on I-94 westbound near Osseo, when the tractor exited the road onto the right shoulder. Kozlowski steered to the left in an attempt to correct, but lost control on the rig, which then overturned onto its right side, sliding across both lanes of westbound travel. Kozlowski stated to the Wisconsin State Patrol (WSP) he then turned off the ignition of the truck, once it had come to rest, and that he was still belted into his seat.

chippewa-falls-aerialAbout one minute later, the Chippewa Trails bus, driven by 78 year old Paul Rasmus, came upon the Whole Foods trailer blocking the road. The Whole Foods trailer was on its side, so the reflective tape and other reflectors were not visible. It was the bottom of the trailer which was facing the lane of travel at the time of the accident. The WSP approximate that the bus was traveling around 70 MPH prior to braking. Witnesses from the bus state the bus did suddenly decelerate right before impact. In addition to the five fatalities, another five bus passengers were seriously injured. The helicopters began arriving 30 minutes after the crash, to airlift the injured to the hospital.

Kozlowski
At the time of the accident, Kozlowski’s Indiana CDL A was suspended. He received a speeding ticket on July 3, 2005 for driving 76 MPH in a 55 MPH zone in a car. He did not pay the ticket, and his license was suspended on September 21, 2005.

On Thursday night, October 13, Kozlowski took a load from Munster, IN at 20:45, delivering in Minnesota early on Friday morning October 14. According to written notes found in the truck (Kozlowski had not filled out his log book, as required), he slept in the sleeper from 09:00 to 16:30 on Friday October 14 in Minnesota. He then left Minnesota, and made the return trip to Indiana, arriving at 22:30.

Once arriving back home, Kozlowski went to a bar, where he drank alcohol with friends. Statements taken from friends establish that he arrived home around 06:00 on Saturday morning. Cellphone records indicate he began using his phone almost continually from 11:00 to 17:00. NTSB concludes that he was probably asleep from 06:00 to 11:00 on Saturday morning, which is 5 hours. They do not believe he slept during the afternoon period, due to the numerous phone calls he made.

He arrived at the Whole Foods Distribution Center at 19:00, and departed there, bound for Minneapolis at 20:00 on Saturday night, October 15. Except for a brief stop for a soda and bathroom, plus a 30 minute stop in Tomah, WI at 00:30, Kozlowski drove continuously until the accident.

Kozlowski’s statement to the WSP was that he was slowing the truck, looking for a place to pull onto the shoulder, in order to urinate. He stated once he eased the truck onto the shoulder, the wheels “grabbed gravel” and jerked the truck to the right, off the roadway. He was unable to regain control. The post-accident investigation indicated the truck was in 10th gear at the time of the crash, and going approximately 66 MPH. The NTSB does not believe Kozlowski was slowing the truck, or attempting to pull off onto the shoulder at the time of the crash.

Two witnesses stated the Whole Foods truck was driving erratically in the time leading up to the crash. One of them stated the truck was weaving, and driving onto the shoulder as little as 10 minutes before the crash. There was no evidence Kozlowski was intoxicated at the time of the crash.

Rasmus
Paul Rasmus was the 78 year old driver of the bus, who was killed on impact. He was required to wear corrective lenses. He corrected vision was 20/20 in the left eye, and 20/25 in the right eye. Without his glasses, his vision was slightly worse than 20/40.

On Friday, October 14, Rasmus reported for work at Chippewa Falls at 14:30. He left Chippewa Falls around 17:30. They unloaded at the Oregon Middle School at 21:30, drove to Middletown, WI, where they checked into a hotel around 00:01 on Saturday October 15. Rasmus and the other drivers had breakfast around 08:00 on Saturday morning. At 11:00 they returned to the Oregon Middle School where they had lunch with the band. After lunch, the driver rested in the motorcoaches. Around 15:15, they loaded the buses, and drove to Whitewater, WI, arriving at 17:00. They watched the band’s performance, loaded the buses around 22:00, and departed at 23:00, heading from Whitewater, WI back to Chippewa Falls, WI.

At the time of the crash, the weather was clear, and there was nearly a full moon. Rasmus was approximated to be traveling around 70 MPH before braking. He was not wearing his glasses at the time of the crash.

Trial
In April, 2007, Kozlowski was tried for 5 counts of homicide by negligent operation of vehicle, among other charges stemming from the accident. After a two week trial in Hudson, WI, Kozlowski was acquitted on all charges. The District Attorney attempted to prove that Kozlowski was fatigued at the time of the crash, and that is what caused him to turn over his truck.

Kozlowski’s attorney, Earl Gray, argued that it was bus driver Paul Rasmus who was at fault for the crash, in that he should have been able to stop in time. Gray argued Rasmus should have had with glasses on, which would have enabled him to have seen the truck in time to stop. Also, the bus had two brakes which were out of adjustment at the time of the wreck, increasing the amount of distance it took to stop the bus.

Trial, Part 2
Federal prosecutors tried Kozlowski this past week for making false entries on his logbooks in the days leading up to the accident. After a two day trial, Kozlowski was convicted on Wednesday, May 13, 2009. He will be sentenced July 24, 2009. Jurors were not told about the accident during the trial.

My Analysis
Ok, those are the facts, now what do we make of all this? The NTSB investigation determined that on the night of the crash, with his low-beam headlights on, the soonest Rasmus would have seen the truck in the road was when he was 227 feet from it. At 70 MPH, he would have covered the distance in 2.2 seconds to the truck. They concluded Rasmus could not have applied the brakes, and stopped the vehicle in 2.2 seconds. Furthermore, they concluded if he had his glasses on, he would not have seen the overturned truck that much sooner to make a difference.

I agree with their findings. It takes a long time to stop an 80,000 lb. truck, well it takes a long time to stop a loaded 55 passenger motorcoach, traveling at 70 MPH, too. There’s no way he could have avoided hitting the truck. This includes whether he had his glasses on, or if the bus had perfectly operating brakes.

As for the criminal trial, I guess Mr. Kozlowski’s lucky I wasn’t on that jury. Well, I guess I can’t say that, because I don’t know what level of proof was needed to meet the standard of “homicide by negligent operation of vehicle”. Plus, I don’t know how many years in jail he would have gotten if convicted. 20 years in jail, would that have been justice? I don’t know, that might be too many.

Still, there can be no doubt Kozlowski was negligent. To me, negligent means stupid and reckless. The witnesses who testified they saw the truck weaving onto the shoulder proved that for me. Kozlowski had been weaving for at least an hour prior to the accident, and was seen on the shoulder just 10 minutes before the accident. This should have told him, pull off at the nearest exit, take a siesta in the sleeper, feel better, get down the road in one piece. But he didn’t do that. Plus, the nonsense about pulling over to urinate, BS. They found the truck in 10th gear, he wasn’t slowing down, he wasn’t pulling over…. at least not intentionally.

As for Rasmus, some old truck driver way back when told me you should never “overdrive” your headlights, which apparently is what happened here. Still, I’m more willing to give Rasmus the benefit of the doubt. For him to have avoided this accident would have taken a sixth sense, or a miracle.

On the false log conviction, this proves what I have been saying for 15 years about the logbooks, and a driver’s hours of service. You can cheat all you want, and you’re probably going to get away with it 90% of the time. But if you screw up, and kill someone, they’re going to find out everywhere you’ve been for at least 72 hours prior to the accident. If they have to send out 50 cops interviewing all your friends, enemies, whatever, they’re going to figure it out. God help you if your logs don’t match where you actually have been.

That’s what happened here. Note: Kowlozski was convicted for falsifications which didn’t even happen on the day of the accident! He was convicted for logs he falsified days in advance of the wreck, which had nothing to do with the wreck.

One last thought, I was very surprised with some of the comments at the conclusion of the news articles regarding the accident, and the trials afterwards. A majority of people blamed the bus driver, including a good number of truck drivers. I don’t why that surprises me, but it does. The one responsible for this accident is Kozlowski, and I’m glad he was convicted on the false logs counts. He’ll probably do 1-3 years in jail, which is probably an equitible judgment for what he’s done.

DOT will start auditing GPS data


generic-truck
In November, 2008, in a very brief notice in the Federal Register, FMCSA notified the world that it was rescinding its policy on GPS data. In 1997, FMCSA issued a policy to its auditors, stating that they were only to use GPS data as a last resort in auditing logs for accuracy. This was done largely to keep the playing field level. An auditor checking GPS data against a driver’s logs will obviously find a much higher percentage of falsifications, than one who is just using paper documents like fuel statements and toll receipts. The policy was also done to encourage trucking companies to buy the GPS technology.

Now, by eliminating that policy, the FMCSA has signaled very clearly they will start using the GPS data to audit your logs. Any carrier who has GPS satellites could be in jeopardy during an audit. I imagine what will happen is many auditors will just do it the way they’ve always done it, and use the traditional EZPass statements, toll receipts, fuel statements, and scale tickets. However, I’m sure there will be some aggressive field agents who are going to use that mountain of GPS data as a hammer. And guess who is the nail?

This will probably lead to multiple levels of expectations during an audit. If you do not have GPS data, or if you’re lucky enough to get an auditor who is going to leave sleeping dogs lie, nothing will change. BUT, if you get a guy who wants that GPS data, for no reason other than he wants it, you and your drivers will be held to a much stricter compliance standard. In other words, your drivers’ logs will have to be precisely accurate and legal. No fudging an hour here, or an hour there.

If FMCSA wanted everyone to run strictly legal, they would have mandated that all new trucks are equipped with the on-board recorders a few years ago, but they didn’t do that. With the on-board recorders, everyone would have been held to the same standard. Now, a carrier without the GPS can cheat more than carriers with the GPS.

Stay tuned, and be forewarned. If do have GPS, you might investigate how far off your drivers’ logs are compared to your satellite data, especially if you are on FMCSA’s Safestat list.

How Many Miles Can I Legally Log?

truck_driver_log_book_exampleThis is a popular question in safety classes. Drivers want to know how far they can show themselves driving on their logs, without it being questioned. The short answer is, you are supposed to log it as you drove it. In other words, if you left Carlisle, PA at 8:45am, and arrived in Columbus, OH at 3:00pm, then that’s what you put on your log. If you log it as you do it, you don’t have to worry about miles driven, etc.

However, to answer the question, the DOT will generally allow you to log 5 mph below the speed limits in whatever states you’ve driven in. For example, if you are driving in states where the limit is 65, you can have 60 x however many hours you’ve driven, without arousing too much suspicion. Many drivers try to cheat an extra hour here and there by driving 12 hours, but logging 10.5 or 11. This is common practice, but just remember, if you are involved in a big wreck, the police and the district attorney are going to go over your logs with a fine tooth comb.

Crete Driver Gets 7 Years in Jail

met_2LakeButlerCrash.JPGLast week, a former driver for Crete Carrier Corp., of Crete, NE was sentenced to 7 years in jail for crashing his tractor-trailer into a car and school bus, killing 7. This wreck occurred on January 25, 2006.

This has been one of the worst truck wrecks in terms of casualties in the past few years. There has been much speculation and rumor about the cause of the crash. It appears somewhat settled now that the driver fell asleep, causing him to rear-end a car at highway speed loaded with children. The driver entered into a plea agreement with prosecutors. As part of that agreement, the driver described to them how he had been awake for 34 hours prior to the accident.

Prosecutors have stated that they are not finished with this case. The implication is that, with the help of the driver, they will attempt to bring actions against the motor carrier, Crete Carrier Corp. This probably won’t happen. Prosecutors always imply that justice will be served before the cameras, but then when their evidence doesn’t take them where they want to go, they quietly drop the case. That will probably happen in this case.

Nevertheless, this incident illustrates why the safety regulations exist. Every safety class I give, I go into my fatigue spiel, and I see eyes roll, and people tune out…. but I’m telling you, driving when you’re sleepy can be worse than driving drunk. You lose control of your truck at highway speeds, and you’ll be lucky to walk away. Of course, if you’re unlucky, and kill somebody else, like this poor guy in handcuffs, you’ll wish you were dead.

School_Bus_Crash__FL.jpgI don’t know this driver from Adam, but I would imagine he is just your normal, everyday, good guy truck driver, who used bad judgment, and paid the price. How many of you drivers reading this have done the same thing and gotten away with it? Learn from this guy’s misfortune!

Trucking Company Owner Goes to Jail for Log Falsification

This press release was issued recently by the Department of Justice. It illustrates that the government does take criminal action occasionally for safety violations.

FRESNO, Calif.—United States Attorney McGregor W. Scott announced today that SURINDER SINGH NIJJAR, 42, of Madera, Calif., owner of Nijar Brothers Trucking and NB Trucking, Inc., was sentenced to one year in prison by United States District Judge Anthony Ishii for making false statements to a government agency. He pleaded guilty on September 22, 2006.

This case is the product of an investigation by the U.S. Department of Transportation, Office of Inspector General.

According Assistant United States Attorneys Mark E. Cullers and Marlon Cobar, who prosecuted the case, NIJJAR and other employees of Nijar Brothers Trucking and NB Trucking falsified the Drivers Daily Logs of their truck drivers. These daily logs were supplied to the Federal Motor Carriers Safety Administration, the federal agency authorized to ensure truck drivers do not exceed the daily maximum number of hours driving allowable. By falsifying the logs and allowing the falsification to take place, Judge Ishii found that NIJJAR “created a conscious risk of death or serious bodily injury” to drivers using the roads and put the safety of the public at risk. In addition to serving a year in federal prison, NIJJAR was sentenced to three years of supervised release and ordered to pay a $5,000 fine.

New Entrant Rules to Get Tougher

I haven’t posted anything in awhile. Why? Well, let’s just say, if you’re not backing up your computer files, you should be. One day you’re going to push the “ON” button on your trusty laptop, and it’s just going to sit there. I was 80% ready for that awful day, next time I will be 100% ready.

Anyway, I came across this article on the Net about FMCSA’s New Entrant program. As you may know, I am selling a DVD training package, for $275 plus shipping and handling. It is designed for small companies who don’t know much about the safety regulations, such as logbooks, driver files, or drug testing. One of the main groups I market to are the ‘new entrants’, which are carriers who have just gotten a DOT number. FMCSA audits all new entrants within 18 months. According to this article, FMCSA is going to make the new entrant audit much tougher to pass. If that’s true, then you really should buy my DVD package.

Arnold Safety Training Package
Anyway, here is the article, from Traffic World, dated April 21, 2008:

“Never mind the record high diesel fuel prices, new trucking companies soon will have to face a barrier that until now hasn’t posed much of a problem for new entrants: The Federal Motor Carrier Safety Administration. The agency, under fire at times from critics who say the motor carrier regulator has been too friendly to business, is preparing stringent new requirements for trucking companies entering the marketplace. The FMCSA says it expects the demands, including tighter mandates for training, drug and alcohol testing and insurance, could cause some 30 to 40 percent of new applicants to hit the brakes.

The rules could tighten the lid on capacity as the sagging American economy is pressing larger trucking companies to scale back fleets and pushing many smaller truckers and independent drivers into bankruptcy or out of the industry altogether. “This is a much more thorough program and it’s got some teeth in it,” said Stephen F. Campbell, executive director of the Commercial Vehicle Safety Alliance. “Saying ‘I didn’t know,’ it will not be a defense.”

By the agency’s own admission, its past oversight of new carriers has been less than stringent. Under the current program, new trucking companies could operate without drug and alcohol testing program, although they would have to put one in place within 18 months. “Our entrant program was designed to be more of an educational format,” FMCSA Administrator John Hill said. “Carriers can tell [us] they are doing something and that is all we are required to do … we don’t really do a lot of our verification.”

All that is about to change. The agency is gearing up to complete its New Entrant Motor Carrier Safety Assurance Process in the next few months, the culmination of a process launched by the Motor Carrier Safety Improvement Act in 1999. FMCSA expects to issue final rules shortly that will govern the 18-month provisional period and the accompanying audits of new trucking companies. These rules will replace interim final rules issued in 2003. The new rules represent the biggest change in entrance requirements for new truckers since deregulation stripped many economic regulatory requirements from the books.

At the heart of the rule will be 11 regulations, including stringent requirements for drug and alcohol testing programs, insurance and use of records. Unlike the current system, a single violation would result in automatic failure. The new requirements – which were proposed in December 2006 – would be effective 30 days after the final rule is published. Hill says they will not make the entry process easier.

“We estimate through some early analysis that 30 to 40 percent of the new entrants will have difficulty” meeting the new standards, Hill told the National Industrial Transportation League’s Spring Policy Forum on April 8. Hill noted that safety audits required for Mexican carriers participating in the agency’s crossborder trucking program place stricter requirements on Mexican companies than on American operators. “We really ought to do that with the American companies as well,” Hill said.

The FMCSA’s strict new carrier requirements come in the face of mounting criticism from safety groups and others that the Bush administration has not taken a strong enough regulatory role. This new rule may be part of the agency’s answer. The agency has more than seven rule-makings coming out this year ranging from issues addressing intermodal container chassis to sleep apnea.

Although instigated by a lawsuit, the agency’s recently proposed entry-level driver training rules – which will require 120 hours of classroom training time – are another example of tougher requirements in the pipeline. The agency says its figures show highway safety improving in recent years. The large truck fatality rate has fallen to its lowest level since the Department of Transportation began tracking the figure in 1975, for instance, while traffic on U.S. highways has increased 22 percent over the past 10 years. And the FMCSA says since autumn 2007 it has published several rules and regulations ranging from fire extinguisher requirements to Unified Carrier Registration fees.

But many fear the new requirement on new carriers could end up harming the trucking industry and its shipper customers just as the freight downturn is expected to subside. “It’s becoming more and more onerous on small operators,” said Brigham McCown, an attorney and former general counsel at the FMCSA. “More and more regulations at some point starts to push the little guy out of business. … At some point you just say ‘To hell with it, it’s not worth it.’”

Small carriers make up approximately 90 percent of trucking companies, accounting for roughly 50 percent of capacity in the market, according to David Ross, a transportation analyst for investment firm Stifel Nicolaus. “These increased regulations will make capacity tighter in the upturn and will favor the large trucking companies already out there,” Ross said. Many large truckload carriers have parked hundreds of trucks over the past year in response to waning demand, but broad figures on trucking activity in recent months belie the negative reports about the larger economy and may even suggest an upturn is on the way. The American Trucking Associations reported increases in its trucking tonnage index in the first two months of 2008, including a 3.5 percent increase in February over the same month last year.

“You’ll get back into the tight demand environment; when that happens the pricing power goes back into the hands of the carriers rather than the hands of the shippers, where it is now,” he said.

“The agency has to balance the realities,” said Donald Schaefer, executive vice president of the Mid-West Truckers Association. “You can put regulations on the industry, but if you put half of them out of business then you’ve created an all-new set of problems.”

Not everyone thinks there will be a problem. The American Trucking Associations supports the new-entrant rule. “It does make sense from our standpoint to make this process tougher,” said Dave Osiecki, the ATA’s vice president of safety, security and operations. “What I hope it does is ensure a more safe company coming into the industry.”

And the Owner-Operator Independent Drivers Association, whose smaller companies would most likely be the ones affected by the rules, supports the new regulations as well. “Generally, we don’t have a lot of problems with it,” said Rick Craig, OOIDA’s director of regulatory affairs. He said new trucking companies that fail one of the requirements can always reapply. “I don’t think they are going to give up,” Craig said.

But Craig, and Todd Spencer, OOIDA’s executive vice president, also have their concerns, questioning the accident data used to develop the rule and whether the rule emphasizes paperwork over safety operations. “While most of the new carriers have shortcomings,” Spencer said, “they weren’t crashing trucks.”

Logbooks…. Can I Abbreviate?

Many drivers ask, “When I’m filling out my logbook, can I use shorthand when putting in the locations in the ‘Remarks’ section?” Instead of writing, Cincinnati, can I write Cincy? Or NYC? Or STL? The rules do not provide for that. They say city, town, village, and the State abbreviation. They even say you’re supposed to write down the mile marker of the highway, followed by the nearest city and State, if you are not in a city when you stop.

In reality, most DOT cops will not give you grief if it’s clear where you are. For example, I’ve never seen a DOT person complain about something being logged as Ft. Washington, rather than Fort Washington. No doubt someone will post a comment within 15 minutes saying they got a ticket for just such a case, but I’ve never seen it. If you are only marking MM 68 on the log, that’s a problem. Which highway? Which way to the mile markers run? 0-300 or 300-0? DOT uses the cities and States to determine where you were, and whether or not your log is an accurate document. If they can’t figure out where you were, they can cite you for a false document.

_______________________________________________________

Eric Arnold is a Former Enforcement Agent with the Federal Motor Carrier Safety Administration, and a leading expert on USDOT compliance for small businesses. Do you have a question for Eric Arnold? Email him at eric@arnoldsafety.com.

Arnold Safety simplifies D.O.T. Compliance for commercial vehicle operators. Get Eric Arnold’s USDOT Compliance Guide, DVD, & Regulations at ArnoldSafety.Com.

Learn more about Arnold Safety compliance consulting services at ArnoldSafety.Com.

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