Hours of Service; Pilot Program to Allow Commercial Drivers to Split Sleeper Berth Time

August 7, 2017 U.S. Department of Transportation Docket Operations Room W12-140 1200 New Jersey Avenue, S.E. Washington, DC 20590 Submitted via www.regulations.gov Re:Hours of Service Drivers: Pilot Program to Allow Commercial Drivers to Split Sleeper Berth Time Docket No. FMCSA-2017-11642 Dear Docket Clerk: Pursuant to the Federal Motor Carrier Safety Administration's (FMCSA) request for comments published in the June 6, 2017, Federal Register regarding the Pilot Program to Allow Commercial Drivers to Split Sleeper Berth Time, Docket No. FMCSA-2017-11642, the Truckload Carriers Association (TCA) hereby submits these comments. The Truckload Carriers Association, with offices at 555 East Braddock Road, Alexandria, VA, 22314, is the national trade association of the truckload segment of the trucking industry. As a major part of an industry that has over 524,000 companies within the United States operating millions of power units, TCA and its trucking company members regularly comment on matters affecting the national trucking industry's common interests and the potential impact these matters could eventually have on our operations. With that in mind, TCA and its members are vitally interested in the FMCSA's objectives and strategies to improve highway safetyin particular, as they relate to fatigue and compliance with the hours of service regulations. TCA supports compliance with Hours of Service (HOS) rules, but recognizes the need to reevaluate the approach to the required 10 hour off-duty work status. Giving drivers the opportunity to break up sleeper berth time into 3 and 7 hours, 4 and 6 hours or two 5 hour periods will give drivers the flexibility to sleep when they are tired and stop their 14 hour on-duty clock. If a driver is forced to use their off-duty periods in a single 10 hour block, they may be pushing through their on-duty period fatigued, since they are not able to stop the clock and rest. Our driving force has iterated time and again the importance of stopping the 14 hour clock so that they can gain the ability to take a break or nap when they are tired. Giving fatigued drivers the confidence to stop driving, by providing them the option to stop their on-duty clock, will lead to safer and more alert operations of commercial trucks. In other words, TCA believes that making the option of obtaining restful sleep more attractive to our driving community would further enhance their ability to safely operate in an environment where the value of rest has been placed at a premium. The Truckload Carriers Association's number one priority is safety and we believe that enhanced sleeper berth flexibility will result in safer roadways. For these reasons, we ask that FMCSA proceed with a pilot program to allow commercial drivers to split sleeper berth time. As always, we wish to thank the FMCSA for the opportunity to comment on this important issue. Sincerely, John Lyboldt President