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FMCSARulemakingFMCSA-2004-19608

Hours of Service of Drivers

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American Frozen Food Institute filings
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American Frozen Food Institute filed 3 comments on this docket between Mar 10, 2005 and Jun 21, 2011. 197 other organizations filed here. The comment window closed 5529d ago.

What American Frozen Food Institute filed (3)

Jun 21, 2011· American Frozen Food Institute (AFFI) - Comments· FMCSA-2004-19608-28196

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Mar 4, 2011· American Frozen Food Institute and American Trucking Association - Comments· FMCSA-2004-19608-20809

March 4, 2011 SUBMITTED ELECTRONICALLY U.S. Department of Transportation Federal Motor Carrier Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590-0001 Docket No.: FMCSA-2004-19608/RIN number 2126-AB26 RE: Department of Transportation's Federal Motor Carrier Safety Administration Proposed Rules on Hours of Service The American Frozen Food Institute (AFFI) appreciates this opportunity to respond to the Federal Motor Carrier Safety Administration's (FMCSA) request for comments on the proposed rulemaking for "Hours of Service" (HOS), Docket No.: FMCSA-2004-19608/RIN number 2126-AB26. AFFI is the sole national trade association representing all sectors of the U.S. frozen food industry. AFFI's more than 500 member companies are responsible for approximately 90 percent of the frozen food produced annually in the U.S., valued at more than $60 billion. AFFI members are located throughout the country and are engaged in the manufacture, transportation, distribution and sale of products nationally and internationally. AFFI members would be greatly impacted by FMCSA'S proposed rule change given their reliance on commercial truck transportation to ensure safe, timely and cost-efficient delivery of frozen food products. Executive Summary AFFI believes FMCSA's proposed changes will impose severe and costly restrictions on the delivery of frozen food products without any corresponding increase in road safety. The proposed changes pose a particular hazard to the short-haul commercial truck operations that the frozen food industry relies on for delivery. AFFI believes that FMCSA relied on outdated data and false assumptions in recommending changing the 34-hour restart period and reducing drive time from 11 to 10 hours. These changes will greatly reduce logistical and distribution system efficiencies, disrupt delivery of frozen foods to grocery stores around the country and result in added costs for consumers.

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Mar 10, 2005· American Frozen Food Institute - Comments· FMCSA-2004-19608-1754

U.S. Department of Transportation Docket Management System Facility Plaza Level 400 Seventh Street, SW Washington, DC 20590-0001 Re:Notice of Proposed Rulemaking: Hours of Service of Drivers; Request for Comments; Docket No. FMCSA-2004-19608 Dear Sir or Madam: The American Frozen Food Institute (AFFI) appreciates this opportunity to comment on the Federal Motor Carrier Safety Administration's (FMCSA or the agency) proposed rule regarding driver hours of service. AFFI is the national trade association representing frozen food manufacturers, their marketers and suppliers. AFFI's more than 500 member companies are responsible for approximately 90 percent of the frozen food processed annually in the United States, valued at more than $60 billion. AFFI members are located throughout the country and are engaged in the manufacture, processing, transportation, distribution, and sale of products nationally and internationally. AFFI member companies are dependent on interstate trucking operations to ensure that their products reach retail customers and consumers in a timely and efficient manner. Regulatory changes that affect trucking operations, therefore, affect frozen food producers. AFFI associate members include companies that provide warehousing and distribution services to frozen food manufacturers, as well as companies that own and operate refrigerated commercial motor vehicles or contract for their use with individual owner/operators. The proposed rule would have an even more direct and substantial impact on their operations. AFFI shares the agency's interest in highway safety and understands its concern for the health and well being of commercial motor vehicle (CMV) operators. Safer highways mean more "on time" deliveries, greater customer satisfaction, and lower per-mile transport costs. AFFI is concerned, however, that FMCSA's proposal regarding hours of service regulations applicable to drivers and operators of property-carrying CMVs would have a deleterious effect on the drivers the agency is seeking to protect and on frozen food processors' ability to transport their products in a timely and safe manner while also retaining the quality of the food. The frozen food industry, as well as other sectors of the food industry, must deliver its products in a timely fashion to consumers. Therefore, the proposed constraints on drivers' hours of service impact not only the safety of American drivers, but also may impact the industry's economic health and the nature of the product being shipped. FMCSA's 2003 final rule replaced the so-called 15-hour rule with a 14-hour rule and prohibited driving beyond the 14th hour after the driver came on duty, with no extensions for off-duty time. AFFI believes this lack of flexibility in driving times could be dangerous to the health and safety of drivers and, in some instances, result in damage to frozen food products during transport. Most would agree that driving for long periods of time without rest not only negatively impacts a driver's health, but also is dangerous to those sharing the road. The lack of flexibility in the proposed 14-hour rule will mean that drivers will be pressured to avoid taking breaks in order to complete their routes on time. AFFI believes this unintended consequence of the proposed rule will actually make driving conditions less safe for all drivers. Also, from time to time, it is possible that driving times may be longer than expected due to circumstances beyond a driver's control. If a driver is required to stop driving prior to completing a frozen food delivery, that failure could result in a thawing and refreezing of the load. It is imperative that frozen foods remain frozen. If frozen foods are thawed and then refrozen the integrity of the product will suffer as large ice crystals formed during long freeze/thaw cycles will degrade the quality of the food. In the extreme, product which is thawed may have to be destroyed. AFFI strongly encourages FMCSA to…

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Abstract

Hours of Service of Drivers

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