I had no idea when I was asked to do this blog that there would be so many topics to talk about this year that relate to one thing: more regulations and more government intervention. I agree that some action was needed, and as painful as it was going through the last round of HOS changes, I will even agree that it did a lot of good and was a huge factor in reducing injuries and fatalities in collisions with commercial motor vehicles. Let's not forget that advances in equipment and driver training were also factors in these improvements.

When do we decide enough is enough? Not only have new HOS regulations been proposed, but we may have cell phone use bans, regulation changes to EOBR's and even a possible EOBR mandate, and last but not least, CSA.

In reality, we all knew these days were coming. We've all said, "I will adopt when I have to". But did anyone think that we would have to adopt so many things in such a short period time. Would it be so bad to bask in the success of the lowest accident rate in over 20 years and see if CSA will continue to deliver these results? The enforcement agencies are not even fully deployed and trained in CSA themselves, and they'll be tasked with enforcing all these additional regulations that will affect the new SMS scoring system. The fact is, the way the new proposed HOS reads, it will create more problems for everyone than it solves. Carriers will have to add tractors to continue with current volumes. It's been reported that the new prosed HOS could reduce capacity by as much as 30% based on the operational design of the carrier. So at the same time the industry strives to reduce emissions, it will be adding more trucks to offset the capacity loss. I don't care how many particulate filters you have, if you have more trucks on the road, you have more emissions.

With all the research and all the data available pointing to safer roads and fewer accidents, why would regulators take such a drastic approach to altering the regulations before they even have a chance to gather and analyze the results of the current CSA? How many unsafe carriers will that process get off the roads? Most of the responsible carriers are trying to make the right decisions, albeit some slower than others, so what's the point of piling on the changes all at once. Some of the factors I think regulators should be considering are:

• Reduced capacity will put more trucks on the road, increasing congestion and emissions.
• Still more changes to the HOS regulations could lead to more interpretation by drivers, carriers, enforcement officials, and 3rd party providers like EOBR's, log audit companies and software providers. More subjective interpretation would lead to a less consistent system.
• Increased costs for all stakeholder, due to:
  • lower productivity
  • more tractors and trailers to meet same demand
  • "systems development costs" for all stakeholders
  • driver training
  • increased marketing & educational materials to educate the industry about the changes
  • I could go on and on...

I don't see anybody coming forward to tell the public that they'll be paying more for everything that touches a truck and moves to their store shelves. Read this summary of the HOS issue from safedriverhours.com, make up your own mind and then visit regulations.gov to make your voice heard on the Proposed Rule for Hours of Service of drivers. The regulators are biting off more than the industry can chew and the results will be bad for everyone.

Sorry I'm so grumpy on this one, be safe everyone. Out.