Here is more perspective from Jay Thompson on the Department of Transportation's recent hours of service trucking regulation.
From Jay Thompson, president and general manager of Transportation Business Associates, Denver, Colo.:
The good news is that they left the 11-hour work day alone (thought it would go to 10). That has that productivity issue staying the same. A bigger issue for the “fresh” industry (produce, meat, dairy and floral) is the 34-hour restart being limited to once per week. The 34-hour requirement also requires 2 rest periods between 1-5PM. What this means is that truckers who run across the country to pick up produce will not have as much time available to drive as they had before.
Here is how the math works. Truckers are limited to several work / logbook rules. One for over-the-road truckers is the daily rule that says they can be on-duty (driving, loading, unloading, etc) 11-hours within a 14-hour window. They must then be off-duty for 10 hours (including sleeping) to make up a 24-hour clock. Another rule in concert with the daily rule deals with work over time, where most use the 8-day / 70-hour rule (there is also a 7-day / 60-hour rule). A third rule is the 34-hour reset, which says that if a trucker is off-duty for 34 consecutive hours – they can show they have worked zero of the 70-hours in the past 8-days. A trucker must keep a rolling total of hours run and that available to drive. Of course, a trucker wants to tell shippers that they have plenty of hours. so if you are running hard – you can only work 8.75 hours per day. If you take advantage of time off, you can do 11-hours per day when you are working. All of this is in a perfect shipper-receiver world – which is not the real world in the fresh sector .
The real issue is matching to shipper-receiver needs in the real world within those limitations. Even though it may not be necessary, many truckers took advantage of the 34-hour reset because it added flexibility for the future. So a trucker coming across the US would start with zero hours because they were home and had used the 34-hour reset then. They would deliver their positioning load in the produce area and then go to load veggies. If loading allowed for a 34-hour wait-time (scheduled or not), it was used again - which really helped with delivery of the produce. The 34-hour rule will only be able to be used once a week, so it’s expected to hurt the most productive entities.
Shippers / receivers need to make sure they discuss this with their truckers and brokers – as this will slow down their supply chain speed by up to 20%. The other good news is that it doesn’t take effect until July1, 2013 – so maybe the next administration will pull the plug or Congress will pull funding for implementation.
TK:Thanks to Jay for providing more insight on this technical yet critical issue to the industry. Sounds like this issue is far from settled.