Here are some additional recommendations to consider when posting your comments:

  • Note your support for Docket ID No. FMCSA–2018–0237;
  • Describe your company’s history/type of activities associated with trucking and continued vigilance on safe trucking operations; and

Identify how current HoS regulations adversely impact timely completion of concrete paving projects. The petition seeks relief from 30-minute rest break and 12-hour on-duty limit.

To support these exemptions:

  • Note that concrete pavement mixtures are highly perishable and must be delivered within a certain time frame to meet DOT specifications;
  • Mention if you typically use central mix plants, which are typically located within 3 to 10 miles of a paving site due to the perishability of the product.
  • Note that while the vehicles transporting the wet batch concrete are making trips from the plant to the paver throughout the paving day, a substantial amount of that time is spent waiting to load or unload.
  • Mention drivers are tasked with performing a pre-trip and post-trip inspection and washing out the vehicle throughout the day, and as a result drivers typically operate their vehicles less than 50% of their on duty hours, and only within a very narrow radius of a few miles.
  • Include any other information that might be helpful based on your experiences with drivers, whether your own or contracted companies.

In closing, please note that drivers of ready-mixed concrete trucks (outfitted with rotating mixer drums) and drivers engaged in the transportation of asphalt and related materials and equipment, both currently benefit from these exemptions, and that, due to similarities in the driving and trucking assets associated with concrete and asphalt, it is logical for drivers to follow the same HoS regulations regardless of material carried.

  • Click here if you are ready to submit comments now.
  • Click here to return to our Call to Action page.

If you have any questions or need additional information about this request for comment, please contact Leif Wathne (lwathne@acpa.org).