30-day Federal Register Notice Comment 0065

Steven P. Norbeck - Comments
This is a Comment on the Federal Motor Carrier
Safety Administration (FMCSA) Notice: Agency
Information Collection Activities; Proposals,
Submissions, and Approvals Driver and Carrier
Surveys Related to Electronic Onboard
Recorders and Potential Harassment Deriving
From Use
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Comment Now!
Due Jun 27 2013, at 11:59 PM ET

ID: FMCSA-2012-0309-0065
Tracking Number: 1jx-85v1-h9ds
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Document Information
Date Posted: Jun 13, 2013
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Comment
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I have been in the trucking industry for over forty
years. During that time, I worked my way through
driving, driver training, and now safety
management. I have worked with various forms of
the hours of service regulations and with both
paper, and electronic logs. Electronic logs are
probably one of the best advances in transportation
that I have seen in my career. Our entire fleet has
gone to electronic logs and our drivers love them.
They were, like most, sceptical at first. However,
that quickly changed once they learning curve was
passed. If they were offered a choice today as to
whether they could stay with the electronic logs or
go back to paper, they would opt for the electronics
overwhelmingly.
The fear that some drivers or organizations have
that these devices can be used to harass a driver is
unfounded in my opinion. Quite the opposite, these
devices can be used to support a driver in
determining how many hours that driver has
available to work and/or drive. They make a
permanant electronic record of duty status that
clearly indicates how many hours the driver has left
in a particular duty cycle. Any and all editing done
on a duty status must be annotated with a reason
and the driver cannot edit driving time.

Submitter Information
Submitter Name: Steven Norbeck
Mailing Address: 15 Riverhurst Rd.
City: Billerica
Country: United States
State or Province: MA
Postal Code: 01821
Fax Number: 866-695-8297
Organization Name: Boyle
Transportation

On the other hand, the use of paper logs can result
in harassment of a driver, the driver can be coerced
into manipulating his/her log to suit a carriers
perceived needs resulting in a clearly unsafe
practice. Drivers can be forced to run more than
one log, not fill them out until the end of the day,
etc., all of this is impossible with electronic logs.
In order to end any harassment of drivers,
electronic logs are what should be mandated
throughout the transpotation industry.