By Mac McQueen
Safety and Compliance Manager
Wyoming Casing Service
This Opinion piece appears in the March 21 print edition of Transport Topics. Click here to subscribe today.
As the latest round of hours-of-service regulatory change plays out in Washington, I have come to the realization that the trucking industry is broken. With taxes and fees that leave companies and individual owner-operators barely able to continue operations and a regulatory environment that seems determined to drive the last nail into the coffin of small business, one could be forgiven for the cynical conclusion that trucks are unwelcome on our nationâ€™s crumbling roadways.
The current HOS rules were well-conceived, well-written and logical. Their success is reflected in the industrywide improvement in safety performance. Having read the study of environmental effects that accompanies the proposed HOS rule, I have to wonder where the assumption that rail can and will take up the bulk of displaced freight capacity originated? The study itself fails to cite a source, and the numbers, at least on the surface, appear to have been conjured from nothing more substantive than wishful thinking.
The process itself is flawed. As a safety manager, if I were to respond to a perceived safety issue simply by writing new policy, my employer would be fully justified in dismissing me. Before adopting a sweeping reform of a regulation, it would be wiser to conduct a root-cause analysis and determine what truly is at issue here.
For those unfamiliar with the process, root cause is simply a matter of asking questions until the real issue is exposed. Only when that issue is dealt with does the problem become manageable. In this case, the issue, real or imagined, is driver fatigue. So what drives that? Does the problem truly exist? If so, how do we address it without turning the economy on its head?
One underlying cause I can identify through personal experience â€” and anecdotally through a recurring theme in written responses to the proposed rule â€” is uncompensated time lost at shipper and receiver loading docks. One study I recall from several years ago asserted that the average truck driver donates 30 hours to his or her employer every week. In any other industry, this would be a scandal of massive proportions.
Â© 2010, Transport Topics Publishing Group. All rights reserved.
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