01/29/16 by Egor Korneev.
LoadTrek works with a large number of fleets that choose to use Hours of Service exemptions. Some fleets are specialized carriers such as agricultural fleets. Others are common carriers that switch between intrastate and interstate rules, or US and Canadian rules. Others may have a mixed fleet of Class 8 trucks and passenger coaches.
Running under different HOS profiles in each fleet segment is straightforward. However, if companies use the same drivers, on the same days, to run under two different HOS rulesets, the complexity quickly rises. The possibility of unexpected Hours of Services violations escalates.
In this post, we discuss viable approaches to ensure HOS compliance, despite the complexity of multiple HOS rulesets. We also discuss how the proliferation of Electronic Logging Devices (ELDs) impacts fleets that use multiple HOS rulesets.
When is it a good idea to use multiple profiles?
There are scenarios that justify or necessitate the use of multiple HOS profiles by drivers. Here some examples from actual fleets.
There are many other examples. If your fleet practices another approach, please leave us a comment below with a description and / or a question. We would love to hear from you.
What are the common problems when switching profiles?
The most frequent issue is when drivers receive a retroactive violation after a profile change. Let’s consider an example from a trucking / bus company.
A driver finishes the previous day on the Passenger Carrying profile. She parks the bus, and takes the required eight hours off. The next day, she logs back on duty and drives the motorcoach three hours to her destination. Then, she is scheduled to execute a postal route in a Class 8 property carrying vehicle. As she switches to the US Federal Interstate rules, she receives a retroactive violation. Why? The bus rules require only eight hours off duty time to reset the daily hours of service, whereas the Federal Interstate rules require ten hours. The driver was compliant in the morning when she started with the bus rules, but, after changing to the Federal rules at mid-day, she is now in violation of the 10 hour reset requirement.
We could discuss similar examples in agriculture, oilfield services, and for short haul-exemptions. But in a hope that the previous example was clear, we will move on.
The second common issue is improper selection of the profiles. We can use an example from the agricultural case that was previously highlighted. A driver operates under an agricultural exemption while delivering from farms, then switches to transporting grain between vendor plants, but neglect to change the HOS ruleset. During a roadside inspection, the driver may be ticketed for a violation.
The third common issue is the violation of the weekly hours. Some industry exemptions allow for a duty status to pause the daily clock, but not pause the weekly cumulative hours.
Impact of Electronic Logging Devices
ELDs do not introduce changes to the rules about using multiple HOS profiles. However, ELDs may expose violations that previously went unnoticed.
Not all ELD providers support dynamic profile switching. We are aware of only two other companies that allow for a driver-based profile selection. Please contact us with questions.
Best practices from our customers
We are including a short list of practices that our customers employ to minimize a chance of HOS violations when using multiple HOS profiles.