What is HOS?
For a heavy truck driver who drives long hours and works long shifts, ensuring safety is a big responsibility. This is why the Federal Motor Carrier Safety Administration (FMCSA) has put together a set of regulations, referred to as HOS (Hours of Service), that governs driving and working hours in order to ensure overall road safety.
Who do the HOS regulations apply to?
HOS regulations apply to any driver who drives a commercial vehicle. A commercial vehicle (or CMV) is basically a truck (with or without a trailer) which satisfies the following conditions:
- Does interstate commerce and weighs 10,001 lbs. or more (including any loads) or has a total weight rating of 10,001 lbs. or more.
- Does either interstate or intrastate commerce and transports hazardous material that require a placard.
What exactly is interstate commerce?
A big misconception is that interstate commerce refers to trucks that travel between different states to transfer goods, passengers, or perform a service. For the commerce to be considered as “interstate”… it is the goods that you are carrying that would need to move between different states, even if your truck never crosses state borders. If you are not involved in interstate commerce at all times, you must continue to comply with Federal Hours of Service regulations for at least 7 or 8 days AFTER you stop performing interstate commerce, depending on what exact rules you operate under (rules discussed later in this article).
Intrastate commerce, however, refers to goods that do not leave their home state. The only intrastate commerce vehicles that must comply with Federal Hours of Service regulations are those that transport hazardous material in large quantities, even during times in which they are not carrying any load.
11-Hour/14-Hour Limits: The regulations are categorized into the 14-hour duty limit, 11-hour driving limit, and 60/70-hour duty limit. After being off-duty for 10 or more consecutive hours, you are permitted a period of 14 consecutive duty hours which commences as soon as you begin any kind of work. This is not based on a 24-hour period and is known as the 14-hour duty limit. Within those 14 hours, you are only permitted to drive your truck for a total of 11 hours after which time you are restricted to 10 consecutive hours of off-duty. This limited driving time is known as the 11-hour driving limit. Additional provisions related to being in the sleeper berth also exist resulting in minor variations in the 11-hour and 14-hour limits when used.
60-Hour/70-Hour (7-Day/8-Day) Limits: In addition to the 11-hour and 14-hour limits, there is a weekly limit that also applies. This is known as the 60/70-hour limit. This limit is based on a rolling 7-day or 8-day period. If your vehicles operate every day of the week, then you may follow the 8-day (or 70-hour) weekly rule. Otherwise, you must follow the 7-day (or 60-Hour) weekly rule. The way it works is that the oldest day’s hours do not count anymore at the end of each day, so if you operate under the 7-day rule, your current day would be your newest day, and hours worked 8 days ago no longer account towards your 60-hour limit. The 60/70-hour limits will reset after you have taken 34 hours of consecutive off duty status.
Sleeper Berth Provision: The sleeper berth provision allows you to achieve your consecutive 10-hour off duty period, or reset your 11-hour driving limit in multiple ways. Instead of going off duty for 10 hours, you can change your status to SB (or Sleeper Berth) for the time you spent in your sleeper berth. Or, you can go into your sleeper berth for 8 hours, which won’t count towards your 14-hour limit, thus extending the time period within which you may complete your 11 hours of driving. Finally, with at least 8 consecutive hours in sleeper berth (but less than 10), as well as a second rest period of at least 2 consecutive hours of either sleeper berth, or off duty, or a combination of both, you can have a new point from which to calculate your available hours, starting with the time of completion of the first of the two rest periods.
Exceptions and Exemptions: There are a few situations in which you are allowed some extra driving time, if necessary. One of the exceptions is Adverse Conditions. If, for instance, a crash on the highway causes traffic to stop suddenly, you may exceed the 11-hour driving limit and remain in “Driver” status an additional 2 hours (for a total of 13 hours). However, you still may not exceed the 14-hour duty limit. A few other exceptions also exist, and they vary in type and conditions that must be met. You may read more on the exceptions on the FMCSA website: http://www.fmcsa.dot.gov/.
The Logs: The logs must include a 24-hour period grid, the starting hour of which is optional (e.g. 12 am to 12 am, or 3 am to 3 am, etc.). The log must also include a date (day, month, and year), total miles driven during the same time period shown in the grid, the truck or tractor and trailer numbers, name of the carrier, main office address, driver’s certification that the logs are correct, name of co-driver, time zone used, remarks or comments, total hours spent in each duty status within the same time period, and finally, shipping document number or name of shipper and commodity.
- Paper-based logs: pre-printed forms that are manually completed by drivers, and copies are submitted to carriers, or
- Using automatic on-board recording devices (AOBRD)
Note that in an earlier version of the regulations, an electronic on-board recording devices (EOBRD) option was added. This meant that all drivers would have to move to AOBRD’s and those drivers/carriers that had low compliance scores would be obligated to install and use EOBRD’s. Future regulations, planned for 2013, are likely to follow this model but for now the EOBRD option has been removed.
AOBRD’s (Section §395.15): An AOBRD is an electronic device that allows a driver to record HOS. The AOBRD device must be integrally synchronized with the vehicle and must record engine use, road speed, miles driven, and date and time of day. The vehicle derived data is only used to determine when the vehicle is being driven. The device must not allow the driver to make status changes while driving.
If requested by law enforcement, an AOBRD must report:
- Total driving hours
- Total distance driven on any particular day
- Total on-duty hours for 7 days, including the day the report is requested
- Times and locations of duty status changes
For more information on HOS, and how it works with telematics, please contact Geotab: http://www.geotab.com/contact.aspx