The press has begun to take notice of the impact DOT's new hours-of-service rules could have on the economy. But their initial analysis touches only the tip of the iceberg.
Let's start with the premise that the roads will be safer under these new rules. After all, that was the primary reason for changing them in first place. Of the accidents reported involving trucks over 33,000 lb. GVW and automobiles, nearly two-thirds are the fault of the automobile driver. Even automobile safety group AAA admits that nearly half involve some error on the part of the automobile driver. AAA should be praised for its recognition of this fact, as well as its efforts to educate passenger-car drivers about the dangers of misbehaving around large trucks.
No one in the trucking industry wants accidents involving large trucks — or any truck for that matter. The safety of the motoring public and the truck drivers themselves are a primary concern. But let's be candid about the fact that the economic consequences are onerous. The loss of $140,000 worth of equipment, revenue that's lost when a truck is taken out of service, the value of the load, and on-site accident recovery costs can easily push the amount close to $1 million per serious accident. And that doesn't include the cost of accident-related litigation.
Over the past decade, miles driven by combination vehicles have increased by 38 billion, while passenger-car miles have increased by about 87 billion. If no progress had been made in safety, this travel growth alone would have resulted in a sharp increase in accidents.
However, just the opposite is true. Our highways have actually been getting safer each year. Making them even safer is an admirable goal — I'm just not sure the new HOS rules are going to get us there.
Remember, the more freight delivered, the more revenue a combination vehicle can earn or save, depending whether it's part of a for-hire carrier or private fleet. Consequently, the driver needs to put on as many miles as possible during the allowed working period.
At one time or another we've all seen these combination vehicles parked on highway on-off ramps or under bridges. Often it's because the driver has run out of hours and has had to park the vehicle or face a substantial fine. Why didn't the driver stop earlier — and at a more appropriate place? Because he would have lost pay (miles=money) and the company would have lost revenue. That's not an acceptable alternative in a business as competitive as trucking.
Under the new rules, you can expect to find more vehicles parked in more unusual places. Why? Because the mandated 14-hr. workday is consecutive, not cumulative. A driver who takes a two-hour nap during that 14-hr. period, for example, can't extend his workday by two hours. The workday ends 14 hours after it starts, regardless of how much time was actually spent “working.” So being held up in traffic or at the loading dock will put eve n more pressure on drivers to increase revenue-generating miles. Unless, of course, shippers or receivers pay for the privilege of having the load available at a time that's convenient for them. Carriers need to do more to try to get fair compensation for the delays caused by shippers and receivers.
If the trucking industry cannot make headway in reducing waiting time, I estimate that under the new rules it will take more than 200,000 additional combination vehicles to move the same amount of freight.
If this additional $28 billion in equipment investment doesn't grab your attention, maybe the increased vehicle exposure and parking problem will. A jump in out-of-pocket expenses and exposure to accidents seem like reason enough for fleets to plan for adjustments — and soon.