February 28, 2020

FMCSA-2019-0277 Large Truck Crash Causal Factors Study (LTCCFS); Notice of Guidance

Large Truck Crash Causal Factors Study (LTCCFS); Notice of Guidance


Request for Information: Large Truck Crash Causal Factors Study


FMCSA seeks information on how best to design and conduct a study to identify factors contributing to all FMCSA reportable large truck crashes (towaway, injury and fatal). Methodologically, the Agency seeks information on how best to balance sample representativeness, comprehensive data sources, ranges of crash types, and cost efficiency. The methodology should also address the use of on-board electronic systems which can generate information about speeding, lane departure, and hard braking. The study should be designed to yield information that will help FMCSA and the truck safety community to identify activities and other measures likely to lead to significant reductions in the frequency, severity, and crash rate involving commercial motor vehicles. As practicable, the study shall rank such activities and measures by the reductions each would likely achieve, if implemented. This RFI supports a two-part process to gather information for the development of a Large Truck Crash Causal Factors Study (LTCCFS) and to promote transparency and innovation by enabling the public, academics, experts, and industry to comment on how best to conduct this study. This study will help improve FMCSA and its State partners' ability to:

  1. Evaluate crashes involving large trucks and identify emerging trends;
  2. Monitor crash trends and identify causes and contributing factors; and
  3. Develop effective safety improvement policies and programs.


Jim Parker - Comments


As a truck driver for over 25 years and now a truck insurance specialist for 25 years I have a unique perspective on truck crashes. Well over 40% of all truck crashes are caused by or involve much smaller vehicles. It has always been known that no one want to be behind a truck. This means pulling out from a side street in front of a truck that can't slow down in time to stop from rear ending the smaller slower vehicle. We see many accidents where a small vehicle comes of a merge lane into the side of or just in front of the truck.

Another problem we have today is unsafe and inexperienced drivers. I have never seen so many BAD MVR's. I am now afraid to driver beside a large truck be it a straight truck or a tractor, even when I can see the driver in his mirror.

I am glad the DOT Officers are checking trucks for safety even though some violations they ticket are absurd. That is another subject to talk about.


Bennie Keyes - Comments


The Hours of Service are causing the ELD to rush the drivers into driving faster and to be unsafe to get more time. Drivers want flexibility, not to micro-managed by trucking companies and the government.

Armel Behrem - Comments


Maybe a new change 11 hours’ drive ,8 hours (minimum in Sleeper Berth) rest on & off duty.

Truck drivers drive to fast to get on time to deliver or pick up, because at the shipper & receiver drivers spent a lot of time getting unloaded/ loaded.

Nowadays no one appreciates what we do & go through out a day.

I have dash camera & 90% the cars don't give the truck drivers enough space to stop/brake because they don't have enough education how much space a truck needs to come to complete stop. Many time cars drive recklessly cutting in front of a semi-truck, road rage and on and on.

Fix ELD give us more on & off duty time, shipper & receiver need to find the way to cut down on loading/unloading time. Remove 30 min mandatory break, we stop for breaks when our body tells us not the ELD

This might help us all to be safe on the road.


Santiago Texidor - Comments


Automatic trucks in the hands of new drivers is a big contributor to crashed. They feel like you are driving an automobile until it’s time to stop it. Unlike knowing how to upshift and down shift a standard transmission in an emergency stop.

Jack Lyons - Comments


These are due in part to ELDs and driver inexperience as a three plus million miles safe driver I see these everyday drivers trying to get places as fast as possible because of time restraints. a new hours of service policy is needed asap.


Alex Anonymous - Comments


Time constraints due to eld are heavily effecting fatal crashes due to the inability for a driver to actually take a break or slowdown in hazardous environments as well as giving drivers a race against the clock feel which requires them to push their truck as fast as they can possibly go and simply hope for the best if simply changed to a 700 mile in a 24 hour period system which is already easily be monitored by authorities then tractor trailers could slow down nap and take their time instead of pushing themselves and their trucks as fast and hard as possible which would also help in the untimely death of truck drivers that simply pass away sleeping in their trucks from exhaustion

Sincerely, a truck driver


Mike Durst - Comments


It is plain to see that the increase in driver fatalities is an unforeseen consequence of the ELD mandate. In addition to creating billions in unnecessary expense for trucking companies it has created the opposite of safe driving behaviors: rushing, traveling at the highest speed possible, driving tired/hungry because stopping would mean running out of clock.


James Epling - Comments


To whom it may concern,

It's very simple. Drivers are driving fatigued due to the ELD mandate. The hours of service regulations, and the ELD mandate do not "fit" within the time requirements of the industry. You continue to place blame on the transportation side of Logistics. However, you impose no regulations on shippers and receiver's causing the delays. Due to the way the industry has become "on time" shipping. With cross docking and expedited shipping. You force drivers to drive at odd hours, in order to keep their job or their contract. You refuse to force warehouse shippers or receivers, loading yards, ports or anyone who uses FMCSA sanctioned equipment to move their raw materials or finished products. To a MANDATORY detention rate. A good forklift operator, with freight lined up. Can load or unload a 53ft trailer with a max weight shipment in 20 minutes. Yet Walmart distribution centers, Giant Foods, US foods, Sysco foods, CNS warehouses and a host of others. Can take 4 hours before they are willing to pay detention to a carrier. It's my honest opinion if the FMCSA, would impose stiff fines and penalties to shippers and receiver's. For egregiously holding up shipments from being loaded or unloaded. You would eliminate a MULTITUDE of accidents. They are the cause, not the carrier. Not to mention the literally "billions" of dollars, and greenhouse gases that are wasted into the atmosphere from equipment sitting idle waiting to be loaded or unloaded. If you're not going to impose a mandatory detention rate. At the very least, you could make an example out of one of the big players. Walmart Distribution in Pageland SC. Would be a great place to start.


Dwight Williams - Comments


Aside from the distraction of mobile devices and in cab electronics, we also face other challenges that contribute to crashes.

  1. Insufficient legal parking. Leading many of us to park on ramps or side roads. This is stressful and causes a lack of restful sleep or forces us to drive tired trying to find parking.
  2. Nutrition. Most of the food available to us contains non nutritional fillers that are rejected by the body.

2B. The healthy food we do find is much more expensive and requires being parked to consume. (I.e. salads and fruits)

We have a required 30 minute break. Due to schedule requirements, we simply do not have time to park, wait in line, eat at a reasonable pace, and finally make our way back to the road.

There are many closed rest areas and weigh stations. Open them for us to park safe and legal.

We, as an industry, have the power to change if we stand united.

What you don't see is the driver of the car/pickup truck that cuts off a cmv causing the cmv to hard break, possibly swerve to avoid contact. The cmv ends up in the ditch with driver fatigue being listed as the cause when in fact, the driver avoided one accident only to be in another.

The drivers of non CMV vehicles need to be held accountable. A good law would be to ticket those that cut us off by less than 100 feet. Dash cameras that capture these events should be considered the same as traffic cameras in court.

Make them accountable for their actions.


Orville Baty - Comments


It's the HOS! We must be able to stop the clock when we get tired and sleep, not when a machine tells us we're tired. You people have made our highways extremely unsafe and dangerous!!!


Chris Miltz - Comments


It would be helpful that 4 wheel drivers renewing their license have mandatory training including pictures of accidents "How to operate a motor vehicle around big trucks

Never pass on the commercial vehicles right

Yield to a commercial vehicle signal for lane change

Never break check a commercial vehicle

Ensure the vehicle has taillights (See too many with headlights but no taillights)

Drive in the right lane when going less than speed limit i.e.: heavy rain

Don’t ride the dotted line when passing Big rigs take up most of the lane One chuck hole, bad seem in the road bounces the big rig know in their lane

I can keep going but somewhere common sense and courtesy is gone It's all about "me" when it comes to driving

Else's are forcing truck drivers to rush and push their drive time past safety

Not enough truck stops or rest areas


Christina Bruhn - Comments


The increase of crashes involving truck must be seen from different prospective cause it's an accumulation of multiple factors. It looks like the changes in our society makes people unable to share the road as it's supposed to be. That leads to aggressive driving. Second the increasing traffic makes it even more necessary to share the road and following rules and regulations. But there is the next factor - the missing proper training in all classes creates a huge leak of knowledge when it comes to rules and regulations. Third too less enforcement makes even more room for free play on the roads. And if all this isn't even worse enough - missing the basic - distracted driving makes it even worse. Within all this are now the truck driver - with the mandate of the ELD they have now to race the clock ticking beside them what leads to speeding and aggressive driving caused by the higher stress level. It would have been better to fix the basic in all classes first before making ELD mandatory.


Jared Gordin - Comments


I've been driving forty years so I have a few miles. With the 14 hour rule I find myself much more stressed than o used to be. If you spend too much time at a dock, traffic jam, wreck or anything that holds you up it's going to impact your 14 hours and possibly make you late. Your awareness has been heightened because cars are travelling faster speeds and I've noticed the majority of them have a phone in their hand so they are distracted. You plan your day not only around where you are going but knowing if you don't reserve a place at a paid parking truck stop that you will fight to find a place. Everyone is on the truck stop much earlier than what used to be. This adds to the stress. Rates in my case are spot and are determined by capacity so rising costs, for instance my insurance has risen 240.00 per month and I have no way to pass that cost along. I point out all these items because it used to be just a normal part of operating but with stress heightened it becomes a fatigue factor. Yes, I get my rest and take a nap during the day if needed but my body is tired, the stress is tiring and it only takes a moment for your mind to wander and you can find yourself in a situation. Traffic is much heavier and getting worse link that with a public that has become impatient with truck traffic and this is a toxic mix. What's needed is more infrastructure for us to travel and park, places we can park near our pickup and deliveries, rates that will pay all of us a wage that makes us feel good about the job we do. I don't see any of that happening so let's at least get rid of the 14 hour rule. Think about it from a commonsense platform. I'm supposed to get unloaded, reload, fuel, eat, shower, take a half hour break and drive a days’ worth of miles in 14 hours. We know when we are tired and need a break, everyone's different and works different. Let us decide how to best manage our workday instead of having to micromanage. Drop the half hour break, you've turned 14 hours into 13.5 which is furthering our stress. Just because I sit behind the wheel for several hours doesn't mean I'm fatigued.


Donald Lister - Comments


Part of the problem is these kids going to trucking schools and companies that provide training aren't teaching them things and turning them out after 4 weeks to drive on their own. No inclement weather training and the like. Something needs to be looked at on that perspective.


Jeff Gohsman - Comments


Truck crash increase comes from 3 items

  1. Road volume has not kept pace with vehicle regulations.
  2. The general public treats road rage as a game
  3. Driver training has lapsed in order to generate crisis


Kirk Bowman – Comments


Bottom line stop letting anyone who has a cdl drive most drivers out here now are here for a pay check they drive down the interstate one hand on the wheel other has a phone or iPad in it and a foot on the dash been out here 36 years driving the last 20 have been getting worse people don’t care about anything other the number 1 bigger companies have trainers with 3 months driving how can you teach someone to drive with no experience yourself. everyone says eld is the problem that is crap it is the drivers in these trucks you want to get the safety back get rid of the pay check drivers stop the 90 day training most of us is our life we learn something every day might be little maybe big but it is there it's to a point us older drivers are hitting out before one of them takes us out if pay attention was worth a million bucks most of them would be broke some say speed has something to do with it wrong it is the ability to drive that truck whit out watching you tube on your phone and foot on the dash driving 10 to 15 mph under the speed limit and pull out to pass someone 1 or 2 mph faster than they are going when you are going the speed limit use common sense but that is gone too.


Muhammad Haris – Comments


  1. I am a trucker myself. I see main reasons are when drivers are trying to rush things. Companies need to train driver of stop rushing while driving. Main motive of truck driving should be arriving home safely no matter if you late by one day or 1 hour.
  2. Second is very obvious distracted driving. Main cause is using cellphone.
  3. Driver fatigue can be third. If you are tired, avoid driving anytime.
  4. Take regular break for stretching or for restroom
  5. A truck driver should be health conscious. You have to keep yourself underweight as this will allow you to get less tired and you will be more active.


William Henson – Comments


The ELD I have hauled livestock with paper logs the 150 miles radius have you an 18-20 hr. day. If it took 2-3 hours to load didn't count against you, the 150 miles gave you 2-2.5 hours before are drive time would even start. Then if you got within 150 miles of your destination time was not an issue, because it related to live Animals. The fact is the eld treats us like robots get up go to bed not tired we don't care can't sleep oh well get up and drive. Companies like swift prime etc. have horrible training programs and these drivers are basically racing the clock, they run thru construction areas at full speed 65-67 governed in a 55 even a 45mph cause again they are racing the clock and looking for a place to park, training plays a part but the ELD IS THE PROBLEM JUST AS MUCH AS HOURS OF SERVICE. Livestock drivers have it the best they are treated like humans to do a job with live Animals we are treated like robots forced to wear an ankle bracelet that says stop go to sleep wake up take your break NOW OR GET FINED. we get paid by the mile not to sit around and watch our clocks and paycheck get smaller and smaller by the minute MY IDEA VOLUNTARY ELD big companies want it great their choice but we are not all the same. DO A STUDY I WILL BE #1 to sign up run an ELD VS PAPERLOG and see that the #s go down company's running eld will have a higher ratio then paper log that's a fact.


Anonymous Anonymous – Comments


ELD regulations, also the fact that someone who has only had 2-3 weeks of school then 4-6 weeks of training otr get to go on their own. Most drivers don't drive in any adverse weather or thru the mountains. They might not even drive in a major city during rush hour while in training. All the enhancements like lane stability, auto braking when too close has got people lazy. Those features are meant to help but new drivers rely on them.


Brigitte Belton – Comments


Stop crashes is very simple


1st mandate the time click stops on the eld. If you’re not rushing against a clock you can finish your work.

2nd limited trucks are no longer allowed on roadways that go above their governed speed limit. If the roadway is 70 and they are set at 65 they are not allowed on that roadway. This will help stop the general driver and faster trucks to travel without being impeded.

3rd all carriers who run speed limited trucks must pay their employees a fair hourly wage.

4th all carriers must pay 100 percent of any and all waiting time.

5th any new truck driver needs to be in a graduating system unless they have verifiable farming experience within the country. All others follow below and are governed at 65 mph until year four.

Year one local only 100 miles or less if no accidents or injuries move to level two after another government run pretest and must be with a trained driver trainer at all times.

Year two regional only 200 miles from home terminals no accidents or injuries move to level three

Year three regional runs no more than 2 days away from terminals.

Year four accident free truck is opened up to highest speed limit driver will travel in. And receives unrestricted vdl. if in the next 2 years this driver has any infraction for speed or an accident his cdl is decreased.

Any carrier entering from another state or province must also follow the rules set out by fmcsa or lose their authority to run. Only one 2nd chance.

I just fixed your crashes all done but I know you won't listen.


John Wilson - Comments


Heard a study just in the city of Houston a few years ago that 4 out of 5 wrecks involving 18 wheelers and cars were the fault of the cars and not the trucks. There needs to be more involved training and just more plain common sense on behalf of the general driving public. When you have people disregarding traffic laws and driving like idiots you have accidents.




Robin Workman - Comments


Elog is the number one contributor to these accidents along with the constraints of the 14 hour rule. Drivers should have flexibility in driving hours so not to be driving at the most congestive times of the day.


Thomas Marlowe – Comments


The restrictiveness of ELD combined with no speaky engly combined with piss poor training combined with NO attempt whatsoever to address the other half of the equation and bring lazy and incompetent shippers and receivers, that bog our day down, to task. NO attempt whatsoever to make sure drivers are compensated properly. NO attempt whatsoever to listen to our warnings that this would happen when you idiots were cooking this mess up behind closed doors. Just rammed it down our throats and now people are DYING. I hope it was one of YOUR loved ones


Lisa Mitchell - Comments


My opinion on the cause of big truck crashes!

  1. Is being micromanaged force to run until your time for the day is gone rush rush!!
  2. Lack of training 3 weeks’ worth of school isn't enough. Plus, the driver trainer in these big companies have lack of experience to be doing the training of new drivers.
  3. Most company going to a load board where you have to be on your phone in order to get loads to keep moving to make money!!!
  4. Plus a CB radio does help to let you know what going on ahead if a pile up has happen already!!


Jim Adams - Comments


The inflexibility of the hos alongside the eld ticking away time has created a "race against the clock mindset". Drivers are rushing over safety and that creates a dangerous situation for commercial drivers and the motoring public alike.


Robert Perkins - Comments




Marty Carroll - Comments


Data on The experience level of drivers needs to be looked at closely. There is very little or no regulations on the schools that put a driver with no previous experience on the road in 3 or 4 weeks. It takes much longer to develop the skills and instincts needed on the highways today.

The government has to take the reins on this as many of the schools are company sponsored, companies who need drivers. Just like a plumber who has to do an apprenticeship to unclog a toilet, a lot more training should be required to maneuver 80,000 pound vehicle on public roadways


Adrain Evans - Comments


More truck crashes are happening because Fmcsa are making too many rules that causes trucker to be behind the 8 ball too much. This ELD junk if you have a load that need to be somewhere and you sit at the customer 4 hours trying to get loaded you behind the 8 ball you don't have enough time to get where you trying to go. If the FMCSA want to help try and get the time, they have to load a truck change


Keith Hamblin - Comments


You have forced all of us to ignore common sense and only obey the clock. If we get held up by traffic or weather or slow docks that ridiculous clock never stops so you take chances and speed when you can to make destination or safe haven. We feel drowsy and need a short nap? Too bad, the clock is ticking so if you run out of hours 25 miles from home, sucks to be you. Shut it down and sleep on the side of the road. Ridiculous!


We told you before Elog was implemented that this would happen and you ignored us. On top of all that you have low time, inexperienced drivers training the newest ones. CDL mills cranking them out like crazy then naming them a trainer after 6 months. What did you expect? After all that you have all these slow governed trucks blocking traffic and making people mad everywhere, they go and people like to show truckers how mad they are by cutting us off, brake checking us, refusing to allow us to change lanes. An inexperienced driver racing your clock and warding off vengeful four wheelers. Gee, what could go wrong?

Keith Hamblin

42 year safe trucker

Layton, UT


Anonymous Anonymous - Comments


The majority of these crashes were caused by elogs. Drivers on elog say are being pushed by Dispatchers to drive fast when tired. Which they are not given the possibility of taking a nap when needed. Also, there are not adequate parking spot available. Elogs were supposed to help with detention time at shippers also, there has been nothing done to shippers! Drivers are now driving faster through towns & parking lots try to push the clock now also it is so unsafe to walk into a truck stop.


Timothy Beek - Comments


well let's see, I've been driving truck over the road for over 22yrs, been in a truck since I was a baby

My dad has driven truck for 52yrs, and it's one simple answer to the increase in crashes. ELECTRONIC LOGS!!!!


See when I watched my dad drive when I was little, there were no appointment time for pickups or deliveries, customers were just happy you were there, it was all paper logs and the way my dad taught me was "you drive until you're tired, and when you're tired stop, sleep and don't set alarm and let your body wake you" and that's from someone with 52yrs accident free.

Because drivers were rested on their time not a computer, they get the rest their body needs and there's no rush because there was less pressure with appointments.

Customers and companies now expect drivers to go from point A to point B non-stop until they run out of hours. Driver fatigue kicks in because they're pushing themselves beyond what they feel that day, rushing, speeding, and cutting in and out of traffic just to get there so they can get some rest.

Some days drivers can go for hours nonstop but there's days where after 2hrs of driving you just need a quick nap because of stress from traffic, the flu or even just exhausted.

The old hours of service made sense where you could split 5/5, 6/4, 8/2, 7/3 as long as you had minimum 2hrs on the split and total of 10.

I also find that drivers had more rest, more time to exercise, more patience because they weren't rushed and told when to sleep by a computer. Sometime on my current 10hr break I'm up for 2-3hrs because I'm not tired. Sometimes I go to bed right away exhausted but wake up after 6hrs wide awake but have to sit for 4hrs watching my computer waiting for the 10 to end then rushing to get down the road only to drive 5hrs tired because now I've been up 9hrs.

We're not robots, and every person is different. We need paper logs back with more highway enforcement, not computer enforcement.

Hope you understand what I wrote and God bless all the fellow drivers.


Robert Blackwin - Comments


1 major factor in my opinion is the mix of professional drivers and inexperienced drivers and faulty equipment sharing the same roads. Meaning you have regulated and non-regulated drivers sharing the same road and following different rules and at times having no rules or real training to join the motoring public. For example. The 1st thing any1 is taught in driving school is proper merging techniques. This is the 1st thing most drivers abandon. I myself has been the victim of road rage by auto drivers that failed to properly merge. Since they do not remember the rules they feel as I offended them, they quickly gain on me, jump in front of me, and apply their brakes very hard. In this scenario I would be cited, unless I have dash cam footage to support it. Second would be passing. Auto drivers complete their pass and immediately merge in front of me, taking away my 6 to 7 second following distance I had with the vehicle in front of me. 3rd. I find a lot of accidents happen during merging. I've always felt commerce should go thru any metro city in the extreme left lanes. Most drivers instinct is to get on the highway and make their way to the left lanes as no one wants to deal with other motorist entering or exiting the highway. As trucks mostly are passing thru the city it stands to reason they should use the left lanes while local traffic uses the right lanes to limit merging from right to left by 3 lanes. Instead local traffic would enter and exit which I feel would result in more seamless transitions as well as create better opportunities and open gaps for those merging on or off. Far too many times I see drivers dangerously cross 3 lanes of traffic so they do not miss their exit. So already being in the right lanes and allowing commerce that has no intention of entering or exiting can move thru quicker and potential lower incidents. 4th I believe enforcement in improper mergers should be a focus the lower road rage and collisions. This will also educate people on the seriousness of the responsibilities they have the privilege to use. I believe a segment weekly focusing on certain driver characteristic and info on how to properly conduct one’s self on the roadways should be a news segment. Kind of like the segments with officers speaking about how to not be a victim of particular crimes. A lot of motorist will be at fault because their ignorant to their responsibilities to the road and rules of sharing the road with others. Attitude is a big part of driving and a bad attitude to the respect and space of others will definitely make you a bad driver. One truck can tailgate another because we understand what the driver in front is trying to do and that's keep momentum because trucks are heavy and geared differently than cars, so I pretty much know what he is going to do and why. I know he’s not going to slam on his brakes for no apparent reason. It's a technique we've developed and execute very well. To someone else its reckless and dangerous, however they do not drive 3k miles a week at 80k lbs. There are different driving characteristics to different equipment. Now I'm not defending this technique but it's used so both drivers can maintain speed get over a hill and clear the lane. I would be happy to elaborate more on other factors but I cold heartedly believe these changes and real changes are simply going to be ignored because of money. In a society that money is the focus for everything and the greed and love of it prevents any real substantial change and real safety takes a back seat to it. Prove me wrong.


Anonymous Anonymous - Comments


We are not a machine that can switch on and off like an ELD. The rules need to be more flexible.

A lot of the accidents are caused by four wheelers. I've been driving for over 10 years and 3/10 cars are distracted with their phones. These four wheelers need to learn how to merge correctly and stop tailgating.


Tim Walker - Comments


I think a lot of the problem is everyone is in a rush trying to fit 16 + hours in a 14hour window things probably would go a lot smoother if we had more time to take naps and still have plenty of time to get to or destination on a safe Manner


Lucas VanWoert - Comments


I blame the money. Brokers take a large chunk of loads, and mega carriers go for the lowest price, which means drivers are getting paid less and have to run harder to make ends meet. Plus, the fact that some days I could drive for 20 hours and be fine, and some days I can't drive for an hour, but because I have time on my clock I'm expected to and running out my clock.


Running in my schedule where I'm out months on end gets annoying running recaps. Like today I only have 6 hours on my 70 dues to an issue with my shipper last week. I could have delivered my load today if I had a full clock. I'm losing out on another load and a good chunk of miles cause my clock is screwed up, and my company runs on hard work so we try to limit our 34 to home time.

Travis Heikes - Comments


As a truck driver for 22 years I have never seen drivers so poorly trained and in such a big hurry everywhere they go. Since eld mandate everyone is constantly racing the clock making up time where they can. Most of their tricks are governed at slower than highway speed limit so they speed through towns! And in parking lots instead. That and not being able to stop the 14 hour clock is a real issue. Another major factor is driver training. These drivers have a severe lack of training and whether you'd like to admit it or not there is a lot more to trucking then driving the truck. These people drive trucks like it's a Honda civic. Fill throttle to go full brake to stop. They drive bumper to bumper because all their trucks go the same speed and with eld all of their ten hour brakes are up at the same time kicking them all out on the highway at once. No one shows respect for anyone but themselves because they are miserable. They have been away from their families for weeks or months. Not allowed to go home by some dispatcher in a cozy office somewhere needing one more load delivered 1000 miles away from everything they love. They are broke underpaid and forced to eat bad food served in truck stops making then not feel well. All those factors combined are leading to increase in crashes.


Anonymous Anonymous - Comments


There are too many regulations drivers are stressed out and always in a rush, especially with the new ELD update now drivers are rushing to make their time than ever before. Being an east coast Canadian driver even before I leave my yard I am put into "driving" status because the second the wheels start turning your time is being recorded and clock already starts before I am ready to go. After about 45mins I start rolling with less time than I thought and get to the border now I have to wait in line and even if I creep up the line I am in "driving status" and wasting time again. If I do make it to my delivery in new jersey or new York I sleep at the customer because it is impossible to find parking anywhere else due to everyone is needing to shut down right away at the same time. In the morning if I have a 7am appointment but I got to my delivery at 11pm last night I cannot move the truck until 9am to get a reset. So even though I am there I cannot move and the load is late then once I get my hours and start to proceed to the dock I am in driving or yard move status and clock has started. If it takes 2hrs to unload there is time lost, keep in mind I still have to go to the port of Delaware, switch out containers which could take up to 2-3hrs then go back to Canada. At least 80% on the time I am very tight on time and am forced to rush and this type of driving is not good nor safe and I maybe tired and want to take a nap but o cannot because I am rushing to get back. This is just part of the reason why there are so many accidents but there a lot more you guys need to look into to keep this industry afloat. If all these ELD and other regulations keep up drivers won’t be able to do their jobs. Thank you


Anonymous Anonymous - Comments


In my opinion is due to the ELD mandate. We as drivers are forced by the clock to go go go why we have the hours. You have taken all discretion away from good truck drivers. We used to have the discretion to stop and go as we were tired and needed rest that. ELD has his foot on truck drivers neck.


Bradley Skinner – Comments


Truck drivers have 2 many things 2 look at & play with!! GPS online computer tracking from their company, not 2 mention cell phones! @ auto transmissions have a lot 2 do with it the driver never feels the weight he’s pulling because there is no shifting. The biggest thing is a lack of training they need more with experienced drivers & learn this is not a vacation. You are not a tourist you have a job 2 do just pay attention & do it!!another thing is no one wants 2 be a truck driver anymore, the only people who are just don't care a bunch of fat lazy none educated drones that think this is all shits and giggles!! I drove 47 years accident free no award's because I worked for many companies so I could learn about all trucks not just one!! I'm glad I retired what's out there now scares the hell out of me


Craig Plumley - Comments


My name is Craig and I have been in trucking since 1995. Contrary to what these lawmakers want us all to believe, every one’s body is not the same. Some of us cannot just lay down and go to sleep in the middle of the day. I see more drivers hurrying and rushing on the road and even see drivers rushing thru the truck stop parking lot at 30-40 MPH which is crazy. With the non-flexible clock we have now, if you get caught in a traffic jam or back up because of an accident then you are screwed. The good drivers take this with a grain of salt but then you have the guys who are always trying to make up time. Several years ago I could stop and eat breakfast or take a nap during rush hour and wait until the traffic died down but now we have absolutely no flexibility whatsoever so now all the drivers must press on in the heavy traffic and try their best to stay on schedule.

Why not let some people with real world experience and some commonsense help with these rules instead of a bunch of bureaucrats who have never a hard day’s work in their lives?

People we elect these men and women to go to DC and do our will but unfortunately that doesn't always happen. Some of them get up there and get caught up in their 20-30 career and all the sudden do what is right for them instead of what's right for we the people! Watch the folks you vote for and if they aren't doing what you think is right then vote their ass out!!

Thanks for your time

  1. Craig Plumley

Plumley Trucking Inc.


Nicolas A. - Comments


In my personal consideration and experience I believe that the causes of the increase in accidents are several.

1- Inexperience of professional drivers, large companies employ drivers without sufficient knowledge.

  1. Need to implement more drug and alcohol controls, I believe that these controls should be prioritized first than vehicle inspections.
  2. Increased stress due mainly to ELD, it is not practical for an electronic equipment to control the person, they are forced to drive when they do not want or cannot because of fatigue or sleep, in addition to the fact that everything gets worse with the waiting times in warehouses and factories, traffic, weather conditions, etc.
  3. The electronic equipment, telephones, GPS, ELD that affect the concentration of the driver

5.The recklessness and indiscipline in the way of the majority of drivers who do not respect the trucks, do not keep the proper distance and brake abruptly in front of a truck, in most occasions disrupt the power and danger that a vehicle of such dimensions and weight represents. There are more conditions or problems that affect peeo accidents, I think these are and in that order are the fundamental ones.

Thank you.


Robert Breeze - Comments


I have been a professional truck driver for 30 years. Now more than eve you see big trucks drifting in and out of lanes. many times, as you pass them (in a hurry) they are looking ahead and you can tell they are tired. If you run 500-600 miles day after day after day, it can become extremely boring and exhausting. Drivers are given the minimum amount of training in schools and pumped on the roads like herds of cattle these days because the industry has an overwhelming shortage of drivers. Everyone thinks they want to be a truck driver but I tell you this, not everyone can be a driver. It takes a lot of metal health to be a professional truck driver. You are working 14 hour days, every day and racing against a clock, shippers, receivers and dispatchers that don't care about excuses why things are late. They say you have 10 hours off at the end of your shift...well let's take into consideration the time it takes to unwind at the end of your shift. Finding a place to park is sometimes just impossible, it can take a long time to find a safe and legal place to park especially in the northeast. Massachusetts along route 90 from Lee to Boston has about 6 rest areas in each direction with room enough to park less than 100 trucks in total the whole way across. Reasonable truck rest areas need to be built and made available throughout the eastern U.S. Next, finding a restaurant to eat, not to bad most of the time but it does take time, figure an hour. Shower- has anyone making laws ever showered at a truck stop? I have waited up to 1.5 hours just waiting to get a shower room. When you finish your shift and get back to your truck you have only have 7 hours left of your 10. I personally can fall right to sleep but I know many can't.

Onto the ELDs. The 14 hour rule is the most ridiculous rule that has ever been implemented, if drivers get tired in the middle of a shift the are racing against a clock every minute of the day. They can't stop the 11 or 14 hour rule for anything therefore if they are tired, they are forced to keep driving in order to get the job done that has been assigned.

In conclusion, in my opinion make it easier by making room and not laws for truck drivers to get the adequate rest we all so desperately need.


Keith Terry - Comments


Unrealistic regulations such as HOS no real split sleeper. It is unrealistic to expect every driver to be able to operate for the same amount of time or that every driver needs the same amount of time for adequate sleep. The biggest factor is the mandate for ELD. Give experienced drivers back our paper logs. Change the HOS to something realistic. More than anything start letting experienced drivers make the rules instead of someone who has no clue how to drive (or Congress because once again they have no idea.)


Avtar Singh - Comments


Hi I am driving 23 years my study crash is because driver not sleeping right know eld log book some time u have more than hours log book left but u need to stop because after one hours not parking driver start log book early morning is book finish early than he sit down truck stop 5 or 6 pm then he starts watching tv or phone media until 10 pm he sleep only 5 hours then day he feels drowsy and driving so we need to change rule and regulations free of mind because I think Canada rule is better than USA please study Canada rule if driver stop late he sleep more


Anonymous Anonymous - Comments


I have been driving off and on since 1983. The biggest thing that has change in the industry is the cell phone. It can be good or bad. I see new guys going down the road watching movies on their cell phones. But we do need them. Common sense will go a long way. You can’t learn that in these trucking schools. I think schools should be regulated and last a little longer than a couple of weeks. They need to learn the whole business so they know how it all works. Just some thoughts.


Jason W - Comments


In this study it is stated "Since 2009, fatal crashes involving large trucks have steadily increased to 4,415 fatal crashes in 2018, a 52.6 percent increase when compared to 2009".

FMCSA started CSA2010 in 2009 which was developed in the name of "SAFETY". After 10 years of study, millions of dollars invested and many name changes (now SMS), we now actually have a 52% increase in fatalities. I personally find these results very appalling. This is not just about fatal crashes, there are many other areas which show just as poor "SAFETY" results.

FMCSA has this statement at the bottom of the Safety Measurement System page:

"Readers should not draw conclusions about a carrier's overall safety condition simply based on the data displayed in this system. Unless a motor carrier has received an UNSATISFACTORY safety rating under part 385 of title 49, Code of Federal Regulations, or has otherwise been ordered to discontinue operations by the Federal Motor Carrier Safety Administration, it is authorized to operate on the Nation's roadways."

If "readers should not draw conclusions" then FMCSA knows the data is flawed. Why then would we ever publish this data for public consumption? FMCSA has tried to wash their hands of this poor data in the disclaimer but yet they still post this information publicly. Although they allow this data to be downloaded daily by private companies like Central Analysis Bureau (CAB) for use in the private sector. CAB then regenerates this data into what is called an "underwriting" report and then sells this data (which remember FMCSA says readers should not draw conclusions about the data) to insurance companies. Today, 10 years later after making this data publicly available all insurance carriers who underwrite truck/transportation risks uses this poor data provided by FMCSA in their underwriting acceptability and pricing.

The cost of insurance in the transportation sector is different than any other business sector. In most businesses the cost of insurance is toward the bottom of a business’s expenses. Yet a motor carrier’s cost of insurance is in the top five expenses he/she every year. Over the past 10 years since publishing this data (SMS) the cost of transportation insurance has increased nearly 100% for established truck lines. For anyone new wanting to open a new DOT authority, the increase over the past 10 years is closer to a 400% increase in insurance rates.

You might ask, why would an insurance company raise rates like this? This too has a simple researchable answer, take a look at these primary insurance companies (Great West, Northland, Sentry, National Interstate, Progressive, Berkshire Hathaway just to name a few) who all specialize in writing transportation accounts. If you look at their combined ratios (profitability) most are worse off today than they were 10 years ago.

So again, I would ask the following question? If the data we are collecting and producing for public consumption is producing such poor results from a "safety" standpoint, why are we producing these results at all.

From an investigative background you have to ask, who could profit from this flawed data being produced and made available publicly? There are only two groups who come to mind.


First one being the insurance industry, this is visible by looking at the combined ratios of these specialized transportation insurance companies. The commercial auto segment for the ninth straight year will end with underwriting losses yet again. Although you will see Progressive and Berkshire Hathaway who write accounts that have been declined by the standard market for reasons based on CAB data were both very profitable. These two carriers earned large profits by overcharging and taking advantage of the turmoil in this industry. Both of these carriers have increased their rates by as much as 400% over this 10 year period that SMS data has been sold of given to CAB and reproduced as an underwriting report.

Second and largest culprit who could profit from this data being public are the attorneys. Many of these specialized law firms now seek out any minor auto accident involving a motor carrier. It has become so easy to lawyers to use this flawed data and put the motor carriers owner on the stand and make them answer to each and every one FMCSA violations. Even though most of this information never pertains to the actual case, they are fleecing this poor data to make the motor carrier look like a dangerous operation.

I would love to see how many transportation attorneys we have today vs 10 years ago (prior to this data being public). It would also be worth looking into the number and size of jury awards vs motor carriers during this same 10 year time frame. These lawyers are praying on this "flawed" data to win these nuclear very awards where the driver was not even at fault.

Please remember, FMCSA made this data public and created this entire mess back in 2009 with the start of CSA 2010.


Jason Basham - Comments

The is a Comment on the Federal Motor Carrier Safety Administration (FMCSA) Notice: Request for Information: Large Truck Crash Causal Factors Study


ELD and foreign, non-English speaking drivers obtaining CDL. I can't imagine how licenses are being handed out to people who can't read a sign telling them that there's something happening ahead. the next time you're coming up on stopped traffic just think there's a good chance the semi behind your family has no idea traffic is stopping due to construction. I see it every day, you may think there's standards but they're not being enforced. ELD is a clock you race against from the moment your truck rolls a wheel. Sounds ridiculous but it's not, you plan a day and something as simple as making a wrong turn, traffic or being held up at a shipper can ruin your parking plans, getting through town during off peak traffic or even your income. ELD is dangerous and study's prove it, problem is that lobbyist paid off politicians to make it happen and safety doesn't outweigh greed.


Erika Wilson - Comments


Honestly, we do not need another study... update the CSA system so law enforcement can enter the cause at the time they are reporting the recordable accident. this will give you the data you need, all the time.

Talk to the truckers, they will tell you, the reason for the rise in crashes is distracted driving, mostly of the public in the private passenger autos. Traffic continues to increase and people are just not paying attention.

There have been increases in trucking companies purchasing dash cams to protect their liability because as you know, the trucker is always guilty until proven innocent.


Nicholas Peterson - Comments


It blows my mind that you don’t know the answers to this issue. You demanded an ELD system to run an already flawed guidelines to HOS. You have mega carriers pushing trainees out the door before they know what they are doing. So, you have inexperienced drivers that have to beat the clock. There needs to be an entire overhaul of the system. While you're at it...limit brokers percentage they can keep. Carriers carry all the costs with little pay. I'm still amazed how an industry that is so vital to our economy can be so messed up.


Brandon McDaniel - Comments


As a 10 year commercial truck driver my problem is now that the eld mandate has come Into effect I feel exhausted all the time because I'm having to race a clock! Before the mandate I was able to stop and sleep or rest as needed! Now it's a race to get as many miles as I can as fast as I can before the clock runs out! Seeing the clock tick down to zero we feel pressed to driver harder and faster which leads to us making mistakes!


Simranpal Singh - Comments

The is a Comment on the Federal Motor Carrier Safety Administration (FMCSA) Notice: Request for Information: Large Truck Crash Causal Factors Study


ELD is most dangerous factor. We can't sleep according to our body and we force to sleep 10 hours according to clock. Nd we also need a nap in between driving hours which we can't due to 14 hours clock. I been on road for 8 years now that’s the real factor if u ask from any commercial drivers and if u don't listen us this thing going to keep increasing. People sitting in AC rooms can't understand our problems. Please have your CDL ND drive on road for at least one month sir then u can understand our problems.

Ron Craig - Comments


1st off it's not been 15 years there was a study done in 2013,2011,2010,none of which ever went anywhere from Ann pharos to Rodriuguise if a study is to be handled then why not look at the real issue and crack down on the non cdl drivers who share the roads with professional drivers who are required to perform more safety actions than any other entity on the US roads,2nd why not perform the study yourself by climbing into the truck and coming out to see ant hand what is actually going on and I sir will offer you this ride for a six week study that you personally can conduct...


Raymond Friend - Comments


I feel like this is just a waste of time, nobody listens to us anymore and its sad.... But here I go again trying and trying to get it through to you guys what needs to be done in our industry for safer roads. 1. Stricter training for mega carriers. Their training is absolutely horrific and put anybody behind the wheel. 2. This is America our language is English and everybody who wants to drive a commercial vehicle or any vehicle needs to be able to read, write, and speak fluent English no if and's or but's. 3. 14 hour rule. Come on guys you cannot but a time clock on our industry that is a 24/7 365 day job. We need our flexibility back. Do you even understand what that 14 hour clock has done to our parking situation? Do you know how many truck stop restaurants now close 3rd shift putting people out of jobs? Did you know truck stops have taken advantage of us charging 14 to 18 dollars to park in a reserved spot cause of how full truck stops get now? There never was such a thing as reserved parking before this 14 hour rule went into effect. 4. 34 hour restart is a joke. At least cut it back to 24 hours. I'm for rules and regulations even though I know what I'm capable of doing and when I need to sleep but this industry is something I loved doing and your over reach in our industry with rules and regulations make it really hard to want to stay in this industry. 5. Get rid of the ELD it has nothing to do with safety and clearly shows it has made it worse and the big reason is because it does enforce the 14 hour rule so now everybody speeds and races the clock. That is why wrecks are on the rise. And I'm sure next stupid rule that comes out is to govern our trucks, that would be the dumbest thing ever. You think wrecks are on the rise now just wait till you guys do that to us and see where that gets you.... finally, number 6. People who drive truck should be making rules and regulations in our industry not people who never ever even sat in a truck. I'm sorry for the long rant but everything I speak of is the truth about what is going on out here. I'm open to have a live discussion with anybody in D.C about these issues. As an owner/driver I'm tired of seeing the carnage that happens out here and trust me I even worry if one of my trips could be my last cause of someone else's irresponsibility behind the wheel. No matter what it still comes down to the human being behind the wheel. Thank you!


Billy Phipps - Comments


I am 45 years old and an owner operator. I grew up around trucks. I was a fulltime police officer in Texas as well. Still involved with law enforcement on an as need basis now. Total time 18 years LE.

We have an uncontrolled situation of drivers on our roads and highways now. I can only rate the way ALL drivers to that of a video game called grand theft auto. They drive the same way as in this video game. All age groups. People who don't know about semis can’t understand the dangers they face with the actions they take around semis. A lot of truck drivers as well. I run a dedicated account from Austin/San Antonio to Dallas every night 6 days a week on one of the deadliest/dangerous highways I think in the nation.

Drivers in cars continually cause wrecks with semis with their cut in front braking or whatever dangerous action they partake in at the time of sequence. They tailgate. Paying too much attention on their phones and don't see you and will change lanes right into you. The dangerous acts are surreal to say the least.

Truck drivers. A lot of drivers are pressed for time and will exhibit dangerous acts of driving as well to adhere to the ELD time stamp. They have to keep driving as fast as they can a lot of times due to there is nowhere to stop. It doesn't matter what speed their governed at. The slower they are. The more dangerous they become. This due to trying to pass another truck of same speed but weigh less a lot of times. This causes trucks that can do the speed limits to cut across two or maybe three lanes of traffic to go around them. Here we have a lot of truck drivers out of Mexico driving north and south on i35 from Laredo. They drive extremely dangerous all the time. They have no respect for the general public or laws. They are mostly illegal immigrants with false/fake driver’s license.

As to summarize this message. ELD time stamp with +/- room for error causes extremely dangerous driving conditions during all kinds of weather. Cars and their inability to focus and be alert of what is going on around them on the roads are extremely dangerous!


Matthew Sloan - Comments


ELDs, lack of proper training, and a grossly over regulated industry!! The ELD mandate has taken away the freedom of the drivers to operate off their biological clock instead you’ve forced a computer on us that forces drivers to be in a hurry and drive when their body says they need to be resting!! The ELD mandate was sold to the public on safety and had nothing to do with safety obviously! The FMCSA has let the mega carriers influence the industry standards to fit what they want not what the industry needs! Training is the first and foremost need to promote safety and knowledge of driving and training is the least regulated safety issue!! How is that when all you hear is safety first? Why is it that an industry is regulated by people that have never driven a truck around the block let alone driven one on the highway or have lived the life of an otr driver? The trucking and all of the transportation industries should be regulated from within and NOT by the government or unions! Thank you, FMCSA, for making our roads less unsafe than ever all in the name of money!

Matthew Sloan

Hoxie, Ks

Denis Provost - Comments


A part of the trouble is that drivers are still trying to find ways to make enough money and pushing the limits of the laws.

I believe that a straight 13 hour max day along with the ability to work without a rest is the best way to rectify the over tiredness and stress of drivers.

They will get more rest each day and be able to earn enough to take care of themselves which will both relieve stresses that they carry and help them to be healthier and more alert on the roads.

They could max out at 91 hours each week while still getting 11 or more hours off duty each day maximizing the ability to rest and work at the same time.

This would be especially good for "home based" drivers who leave and return to the same starting point each day.


Michael Millard - Comments



Chris Usilton - Comments


There are multiple reasons in my opinion. 1. Drivers racing a clock. 2. Mega carriers putting unskilled and untrained drivers behind the wheel. 3. The regular motoring public is out of control with speeding/tailgating/pulling out in front of trucks etc. 4. Not enough enforcement for said motoring public. 4. TEXTING/Facebook huge problem. 5. Fmcsa overreaching over regulating. I absolutely believe they need to have people that have experience in this industry in the mix of making these decisions. 6. Not enough parking. 7. Shippers and receivers holding truckers hostage 4-8-12-24-48 hours at a time. I could go on and on. I have been in this industry 26 years zero accidents put out service 1 time in 26 years because I wrote the wrong date on my log. I used to love and take extreme pride in doing our country a great service, but I would 100 percent quit this industry tomorrow if I could do anything else remotely close to the money I make now, that's what's become of this industry.


Anonymous Anonymous - Comments


First of all, we need to pay attention on cars. Most of the time cars make problems for trucker's...

Second big companies drivers, most of them are only wheel holders not drivers.

Next HOS rule its making me more tired. Because we are pushing every day for nothing...

You should give more freedom for owner operators and more strict rules for company drivers!

I never heard dispatch force owner operator to drive faster or so... but for company drivers swift Werner or England I hear all the time!


Daniel Dorris - Comments


Pause the eld mandate for starters. Fix the hos so drivers are not racing a clock. Talk to drivers instead of mega fleets who don't know how to dispatch trucks. Start going after companies like Walmart and other large warehouses who keep drivers for more than two hours. Those are just a few things


William Brady - Comments


First off, the required rules for cell phones is not a problem. Let's take a look at the eld situation. People are watching and racing a clock that people stress over. We are an industry that is under trained. You do not have to go immediately after you 10 hour break. If still tired don’t go. But we have big companies pushing the driver and the new recruits are scared to say anything because they are new. I myself have been driving 23 years of experience. If I'm tired, I pull over get some rest. But big companies control what the industry needs, not what's logical. When are you as government officials going to work for us and not against us! Listen to the ones who have knowledge and experience. Don’t listen to those who say they are professionals. I'm an American truck driver who loves this industry and want proper and common sense rules, not educated guesses.


Comment from John Wingo


There are several reasons that contribute to commercial vehicle crashes in today’s society. ELD'S are one problem but not the main reason. Speeding and Aggressive driving are the main reasons. Tailgating by commercial vehicles at high rates of speed even in inclement weather conditions is also a problem. The motoring public not giving large vehicles the room they need to maneuver, i.e. passing, turning, backing...everyone is in a big hurry and don't want to yield. Vehicles entering an interstate highway is a huge problem because they don't yield to the high speed traffic or they don’t accelerate to match the traffic speed and they have plenty of time and space in which to do it. This causes a lot of the accidents as well. Majority of the trucks on the road now are running against the clock with these ELD's. There is no flexibility for rest breaks once you start your day....so if you do stop and take maybe a 4hr nap...you just lost 4hrs off your 14hr clock.... along with whatever hours you've already driven. Distracted driving is huge...major contributor. Not just cell phones...but these tablets associated with the ELD. Its mounted where you can look at it so you can keep an eye on your time. All it takes is a split second for you to look at it and wind up in a crash. We didn’t have to do that with PAPER LOGS. You filled it out WHILE YOU WERE SAFELY STOPPED SOMEWHERE...truck stop, rest area, home. A lot of accidents happen too because of inexperienced drivers being put into situations where they just haven't been trained properly. Some of the larger companies are letting drivers who may have only 6mos experience train newer drivers and they wonder why their trucks are being wrecked.


Comment from James Lamb



@FMCSA Acting Administrator Jim Mullen announced at TRB that FMCSA is seeking public comment on how best to design and conduct an updated study to identify the causes and contributing factors of crashes involving large trucks. Comments due by March 16.


James Lamb


Replying to @FMCSA

This is why we need to #DefundFMCSA Up to an additional 150 occupants of large trucks will die statistically speaking between now and March 16th because you still have not suspended the ELD rule. Admit you were wrong and made the roads less safe. #StopTheBleeding #SuspendELDsNow


Comment from John Smith


Well number 1. Is the big thing is these new E.L.D. forces drivers to run tired no way to stop 14 HR clock to take a nap to be better rested it's just like a can of Pringles once you start you can't stop you’re in heavy traffic clock is running everything you do your under a running clock other than half hour break number 2.its people that has never driven a truck tell someone how to drive it when to drive it and how long to drive it and where to drive it I have been a driver for 21 years now and every time you folks step in and say we going to make it better so how is that working for you now ???? Higher crash rates lack of English speaking drivers lack of better training just let use drivers do our job we know when we are tired and hungry and need a shower I don't need someone to hold my hand when I started 98/99 we had 5on 5 hrs. off never got tiredness always rested now we got college kids coming in there trying to tell us how to do our job !!! And we got shippers and receivers out here they don't care how long it take to load. Or unload u but will say as soon as you are done you can't stay on our lot weather you have time to drive or no we will call cops have you removed from lot and truck towed so overall the driver is the one getting screwed from both sides put the control of the truck back to driver like it was 18 years ago we all adults here working we don't need a baby sitter trucking has become a bad joke anymore nowhere to park anymore truck stop charging us to park on their lot so look real hard hours of service and the damn E.L.D S PLEASE HELP US TO HELP YOU WORK WITH DRIVERS NOT AGAINST BRING BACL LOG BOOKS OR GIVE US MORE FLEX ON ELD CRAP LIKE I SAID BEEN HERE FOR 21 YEARS AND KNOCK ON WOOD ACCIDENT FREE THANK YOU FOR YOUR TIME JOHN P. SMITH SR. P.S I DONT TELL YOU WHEN TO EAT OR GOTO BED OR WHEN YOU CAN WORK OR GO HOME WORK TOGETHER QUIT REGULATING THE HELL OUT OF US


Comment from Curt Fenslau


I would like to express my views on why we are having a rise in accidents being a fleet owner and a driver myself for over 25 years this is hands down the worse I have ever seen things in my professional opinion I honestly believe the ELD mandate is the biggest cause of the major accidents you have drivers in an 80,000 pound + vehicle racing a clock it does not take a rocket scientist to figure out this is a bad thing If you will not change the ELD back to paper logs then you need to give us more flexibility with it do away with the 14 hour rule also we do not need 10 hours in the sleeper honestly how many people sleep 10 hours it needs to have more flexibility so people are not racing it I honestly believe this has been all part of the ATA which cares nothing about the drivers or the small companies they are directly funded by large carriers so they are trying to level the playing field with their subpar drivers and big money because they know they cannot compete with our service the FMCSA is a great group but please stop playing into the hand of the ATA you are choking out the little guy and that’s what this country was built on please help us please for once help the little guy the independent this isn’t about getting rich like the large carriers we love what we do we put our all on the line everyday please do something I am tired of seeing my brothers dying daily because of your unreasonable rules and regulations thank you


Comment from zack Wright


I am a 25 year old man with 8 months of otr driving experience. I also have 3 years of non cdl delivery driver experience, flatbeds, box trucks and forklifts.

The three biggest things that cause a rise in accidents in trucking from my observation has been training, other vehicles and their ability to drive, and fatigue.

  1. Training. It all starts at the bottom, which is training. I paid out of pocket to go to a private school, where I was put into a truck with three other students. One on one driving time was rare, and I left school perplexed why we learned outdated techniques such as double clutching. No trucker I’ve ever talked to uses this. But its required to know.

Biggest problem I found, we never drove with any weight in the trailers. That’s a wrong way to learn

I actually went and found a family friend to help me learn because I was underprepared.

And the state test is a joke. I was allowed to take it in a 28' foot pup trailer and passed. Next day I can drive 53' all over. How could I of proved to the state that I can drive a 53 if all I drove was a 28 with no weight?

  1. Other cars. Multiple times other smaller vehicles have caused me problems. They do stupid maneuvers all the time. They cannot merge onto the freeway, very common problem, and then they flip me off!

They cut me off all the time and take my stopping distance, tailgate me, etc.

They have no real training and it shows

Four wheelers need reevaluation tests regular intervals. Retesting drivers would generate more revenue too for the state.

  1. Fatigue. I like most people do not understand the 14 hour rule. It needs to be changed so drivers earn hourly wages only. That way we don't have to fight for our miles, which are always so inconsistent. We can work a normal 8-12 hour day without feeling super fatigued and exhausted all the time.

Please require 15 minute break every two hours like every other job does.

In conclusion,

this industry is horrible and unsafe. over scrutiny is why I will not continue to drive as a career, and its why so very few young people are driving. It saddens me that a job I liked will end soon because of such bullshit drivers face.

Thanks for reading. And good luck finding more drivers or the self-driving trucks.


Comment from Jon Edwards


Are you SERIOUSLY asking for public comments on a topic that's already been studied?

And by your agency already. STOP the madness and insanity.


Comment from mark nanninga


how about being able to stop the clock when we need a nap or don't feel good.


Comment from Derick West


There is no reason to conduct a study, just listen to real truck drivers. We are on the road we can tell you the problems.


  1. ELD - get rid of the ELD all together so many drivers are watching the clock on their ELD and trying to race against the clock its hurry hurry hurry. That in and of itself has caused a spike in truck related wrecks.
  2. HOS - hours of service needs to be reformed. Nobody wants to work a 20 hour day and nobody is asking for that. But not everybody needs 10 hours of sleep at the end of their 14 either. While on the HOS topic the biggest thing that I can think of if a reform is needed is the ability to legally pause your drive time. Why should my drive time be counting down when I'm sitting at a shipper or receiver waiting on them to load or unload the truck? I'm not driving but under current hos my time is running out and I cannot help the fact that all across the country shippers and receivers hold up drivers wasting their time.
  3. Rest areas - more and more truck stops and rest areas are shutting down. Leaving drivers without room to park. This goes back to the HOS and ELD topics. Not everybody starts their driving at the same time so not everybody reaches the end of their 14 at the same time. Yet all the truck stops and rest areas are filled up at 5pm and the drivers who haven't reached the end if their 14 yet find it difficult to park at 8pm or later when every place is full and there is not enough parking.
  4. Shippers and receivers - shippers and receivers all across the country are known to hold up drivers. A suggestion to the fmcsa would be to get involved in that end and hold them accountable. There is no reason why a driver should pull in somewhere to load or unload and have to sit and wait for hours on end. If they want something moved or delivered it should be ready when a driver comes to load or deliver it. This goes back to all other topics above. It wastes our time under current HOS which makes it difficult or in some instances impossible to find a place to park. And causes drivers to race against the clock on ELD to try and get somewhere on time. My personal opinion hold shippers and receivers accountable. If a driver pulls in to load or unload make it a federal mandate that if the driver is not loaded or unloaded within 2 hours of checking in the shipper or receiver MUST under federal law pay the driver detention pay for every hour they sit after the first 2. Also on the same note If a shipper or receiver exhausts a drivers available driving hours and they cannot or will not have enough time to find a safe parking area after loading or unloading then the shipper or receiver MUST under federal law provide or allow parking for drivers as well as facilities for restrooms, and food.
  5. Brokers / dispatchers - hold brokers / dispatchers accountable for trying to push drivers who are tired or otherwise need to take a break. Especially if that driver is later in an accident. Truck drivers are people too and when they spend hours at a time driving sooner or later their eyes will get tired. Sometimes all someone needs is a quick nap or a break. Many drivers find themselves in a position at some point where a dispatcher or broker starts trying to push them or in other words harass them, often by trying to bully them into pushing on by holding their job over their head, threatening to fire or deduct money off the load if it's not their by a certain time. Make that practice illegal and punishable by hefty fines and or jail time. Many other occupations have policies regarding harassment in the workplace truck drivers should too.


Comment from Armand Carver


Leave the public out and talk to drivers. The public doesn't want trucks. they have no respect for trucks they need more education on how to operate around large vehicles


Comment from Daniel Smith


I plane lack of give a crap about the person next to you, constant worry if bills will get paid, push strict regulations. And driver amenities such as cruise control auto adjust air ride, and a false since of security with crash mitigation technologies let THE DRIVERS MIND WANDER AWAY FROM WHAT HE/SHE IS DOING, and that is transporting this nation’s economy.


Comment from Adam Stringer


I can tell you people are racing that clock. Look at how many people been killed in truck stops do to people driving fast.

ELDs are killing people.


Comment from Gary Whitener


Racing the clock because of ELD'S

No real flexibility in HOS

Speed differences between small cars and big trucks. Speed limiters prevent us from keeping up with traffic.

Overly regulated (not enough common sense rules)

Not enough training for both drivers and inspectors

Foreign drivers are treated differently at scales. They claim not to speak English so the trooper just passes them through.

Constant tug of war between state and federal regulations

Regulators fail to realize there is not a one size fits all solution

Worst part is nothing is going to change. It all comes down to money.

Shippers need to be held to a standard of loading/unloading time (99% of the time they know we are coming before we do, they should be ready)

Infrastructure needs improvement. (Costs a lot of money to repair trucks and trailers)

All of the listed affect one thing and that is our time so once again we circle back to racing the clock


Comment from Clarence Parmer


  1. First and foremost you have to have a strict set of entry level standards for new drivers.
  2. Better training. These companies that offer training and schools are not comprehensive enough. Time spent with a trainer should be a minimum of at least 6 months and certain number of miles.
  3. Eliminate the ELD requirement. It has done more harm and increased accidents and fatalities than ANY other one thing in the last 25 years I have been doing this. It causes drivers to rush through their day. Sometimes that involves speeding and careless driving. ELD should only be for companies who have an unsafe safety rating or at the very least, companies with 50 or more employees.
  4. You must teach the public about driving with trucks on the highways. This needs to start with drivers ed and continue with random written tests when renewing driver’s license throughout a lifetime. Of course, advertising on billboards, sides of trailers and all types of social media.
  5. Eliminate split speed limits in states such as California. Countless university studies have proven this to be unsafe. If need be, hold back federal funds until states comply.
  6. HOS At some point you are going to have to understand that not all people are the same. People have different sleep requirements. Imagine working a job that was essentially a continuous swing shift. There needs to be more flexibility in the HOS with longer on duty and drive times so drivers can take breaks as needed. I am sure there are numerous medical professionals who could back this up. I have tons of ideas on this one.


Comment from C B


Accidents involving CMV’s on the rise? Start looking at the people being hired; the schools are letting people receive their license with them not even close to being able to drive. Then they get to a company go with a trainer that may not even have experienced themselves, with a trainer less than a month and get turned lose on their own. Getting trained in a manual then coming to a company with automated manual not knowing there is a difference. All these "safety" devices that are being installed are a joke collision mitigation, lane departure, blind spot, rollover prevention, etc.... These things go against everything I was taught in school myself and was also trained by a 40+ year veteran so I had the best of both worlds. I could go on and on


Comment from Lenora Williamson


Drivers need to have a clean driving record before allowed in truck school, or a company owned driver trading service. Drivers need to be able to read write and speak English properly. That helps everyone concerned from dispatchers, to drivers, to shipping and receiving personnel, police and the general public. They need to have a limit at the national level on how many times someone can fail a cdl exam. 2 should be the maximum am out of times. If you can't pass the exam, then No one has any business in a truck. There is too much at stake here. It is not only deaths, but injuries as well. Why did the fmcsa get so lax on the rules? Drivers should have more education and training before being let out on the road to hurt or kill people or even themselves.

Thank you


Comment from Jeffry Rodriguez


There are a couple issues with this industry too many registration examples the

ELD making driver rush more and racing with a clock ...

Putting pressure to the driver to dealing with traffic or trying to get home before the rush hour...

Plus, ad to the system there many carriers putting driver on the road without experience they don’t know how to be dealing whit the snow on bad weather....

And the list is going down just like

I traveled to Pennsylvania and I didn’t see a single snowplow always from Youngstown, OH to line of NJ


Comment from Charles Merry


When u have a stopwatch on the dash ELD. People's attitude changes and the get in a hurry. with freight rates so low and cost of operating is very high. U are pushed to make bad decisions or cut corners. And when u do that in this industry people die. The hours of service do not work for flatbed, oversized, or Refer. There is a lot of waiting [ time you are not paid] by no one and it puts company and driver in a bind to make appointments and money on the load. U can't regulate sleep .the 11 driving and 10 off with no 14 hr. rule and no half hour break will work across the board and will relax the pressure on drivers I know it is a pipe dream I have when through a lot of hos changes in 40 years flexibility is the key .we are inundated with so many must have programs that cost a lot and rolls taxes government costs .it is getting so bad 750 trucking companies went under and more to come I am sure the accidents are a direct link to being pushed to the limit to make money no one likes to failure.


Comment from Robin Stevenson


First of all the H.O.S. sucks your telling when to rest drivers are driving when they’re tired because you’re telling them when to sleep you have shippers and receivers that don't give a shit about the eld yes you probably have some drivers that text and drive but I see more people in cars texting and swerving all over the road cutting trucks off than I have ever seen sense 2003 when I started driving the driver training sucks they push drivers thru the training to get more in school it's about the money not the training there really needs to be better training we need better flexibility on the H.O.S. the 30 minute break is uncalled for I should be able to stop for my break when I want to we have so many regulations out here on the road it's hard for us to our job


Comment from Joe Lindsey


As A 15 yr. Veteran driver I truly find that the 14 hr. Clock is still being abused by most and the younger generation just can't handle working 14 hrs. straight and then not be able to park comfortably...being held up at shipper and receivers for plus 4 hrs. And then the company wanting you to finish a 10 on sight which is not true rest...no shower.no amenities...it becomes a juggling act...these companies will fine a driver for not complying.

Furthermore, there's so many trucks running the same speed and the same times of the day that you end up with road rage and extreme hazards with 12 to 20 trucks in the same 2,000 feet of roadway...it's ridiculously dangerous....and Swift....you the FMCSA should be ashamed for not shutting that outfit down years ago....period...

Now....give us a 16 hour day...mandate these warehouses pay us to wait more than 1 hr. And or give us safe haven at their facility...in a 16 hr. Day we can nap / rest

Meet our goals for the day 500/ + miles... And for love if God turn these truck speeds up to 75 for older drivers with no tickets...turn them down for younger drivers.

Another larger fatality increase factor in the equation is team driving to increase revenue and improper restraints.... another easy helpful solution would be drivers under 5 yrs. Don't really need to pull no more than 32k on their wagon...65 k max... b

There's a huge difference...

Myself I don't even work from December 20th to Feb 15th

To dangerous...

And yes...I would love to come off the road and play a role in helping the FMCSA solve these issues...if that's no to arrogant...I have a deep love for trucking but have really list some of my passion over the speed restrictions and e-logs....

I'm supposed to be living in a free country...my constitution says I am to not be impeded in my pursuit of happiness.... yet I'm told when I can drive, and how fast or slow....

I can't even decide when I'm tired and when I want to sleep...

At 50 years old if I sleep 6 hrs. I'm good...after that I find myself staring out the window for hrs. Before I can start my next shift then I'm tired before it's over...I end up late or driving fatigued and boss man...I know when to sleep...I don't need a nanny...no more I had one as a child...


Joe C. Lindsey Sr



Comment from Jason Cripps


Plain and simple, the ELD mandate is responsible. I have been a CDL holder and professional driver since 1992. I own and run a trucking company responsible for 42 trucks and drivers, and I drive one myself. Since the ELD mandate came into effect, drivers are racing the clock, unable to rest when they need to, only able to rest when the ELD tells them too. They speed down exit ramps, on surface streets, and inside the truck stops trying to save every second they can and have become dangerous. Look at your study, and then look at how many have been run over in a parking lot. Kind of like what I call the "me first" attitude of drivers, when they have to pass you only to slow down once they pass just so they can be first, it's a mental condition that is telling them that the clock is ticking, they can't stop it, and they have to go from A to B just as fast as they can. There is the problem, plain and simple.


Comment from Brad Kemp


I often see two factors.

  1. Drivers driving too fast in hazardous conditions because of tight schedules and perceived need to cover as many miles as possible during allotted driving time. Drivers are paid per mile, not for being safe. Drivers are restricted by legal driving time constraints. Drivers are required by customers to arrive by a deadline. That combination forces drivers to drive too fast for conditions, and to keep driving when conditions are unsafe at any speed.
  2. Too often drivers will ignore needed maintenance of safety related items. Stopping for repairs is not paid time and doesn't get the load to its destination on time. The incentive is to keep going, not to stop and be safe.


Comment from Ramon C Hall JR


In My opinion the continued crash rates are reflection of a few things.

  1. The eld and hos mandates have caused drivers to race the clock and be a as swift as they can be to be productive, get the job done and be able to make a good pay doing it, there are solutions but not simple.
  2. Freight rates are not increasing as they should have over the years. There seems to have been a decision made across this industry that retains the right to keep profits hi for the shippers and rates low for the transportation industry as a whole. My point here is, if the industry would pay better drivers would not be required to push so hard to make a good living.
  3. Shippers and receivers alike are not held to a standard of efficiency when it comes to loading or unloading these trucks. Meaning when transportation is held up due to loading or unloading and there isn't a monetary charge to the loading / unloading party that's given to the truck driver it causes the driver and his company to lose revenue. This behavior effects productivity thus forcing the driver to push harder to replace the time and revenue that was lost.

In my opinion I think that if we could get some kind of base line of pay or code of conduct on #'s 1&2 then it would make #1 easier to adjust and safer for everyone. We all are out here to make money and thus far the only way to do that is to run as hard and long as possible so we can reach our goal. Short of an all-out driver strike across the country I’m Not sure how we can get the shippers & receivers to properly plan and pay for their loads and wait time but something needs done or we will not see a reduction of lives lost due to transporting goods no matter how tight or lose the mandates are made.

Thank you for your consideration of my opinion.

Ramon c Hall Jr.


Comment from Billy Williams


I want to let you guys know that I drive an automatic transmission truck ,with these Bendix Systems on it, I am just waiting for someone to run in the back of one of our company trucks, these trucks dealers is pushing these companies to purchase this automatic transmission with these Bendix Systems, this system is not for a 80,000 pound vehicle, this system picks up shady areas and it will slam the brakes on, you could be on the Highway all along, now think what's going to happen when you have these drivers riding down the highway with his feet up on the dash, and gets behind one of these trucks with these systems on it, that driver is going to go right through the windshield of his truck, you guys need to be investigate this, and the company I drive for, these guys they’re are hiring, some of them shouldn't be in a truck, and this company's that's out here with this slow no pulling, doesn't need to be out here, and this is company I work for, this truck doesn't pull and they are too slow, they have received many calls from people traveling about this trucks.


Comment from Thomas Henson





Comment from Anonymous


The regulations are stringent. Cars cause accidents with big trucks and the truck drivers are blamed immediately. Elogs are jokes continuous clocks make drivers drive tired because the company doesn’t give enough time to get sleep. Cars give no respect for trucks and the state patrol local law don’t do anything if they literally watch a car cut off a truck. FMCSA have their hands in something they know nothing about. You guys probably have never driven a truck. Being tired and cars are your main reason why accidents happen. Y’all need to leave the trucking industry up to people who have done that line of work. Y’all are idiots


Comment from Anonymous


As I see it with over 25 years behind the wheel, there are two main issues that need to be addressed.

  1. Inexperienced drivers regardless of their age. Instead of the way the private schools are operated now, with promises of being road ready in four weeks or less. This promise alone makes me shutter!! I propose an apprentice program of three years minimum. Starting with a classroom teaching the basics and the laws, then a simulator, hands on pre-trips with more mechanical knowledge, then backing and maneuvering in TIGHT areas

1 Each trainer would have verifiable minimum 20 years on highway driving experience with a safe record.

2 A new trainer every 6 months

3Training in all weather conditions

4Training for all terrain .... A flat land

B mountains

C cities.... including east coast major cities

D rural driving

E course set up for controlling skids, jack knifes, blown steering tires

F gear and automatic transmissions

G training for all endorsements

H night and day driving

I basic geography and map reading.... stressing that a GPS is not and end all tool and it will lead a

driver into trouble

5 Each school would be CLOSELY regulated and responsible for each graduate for a set period of time after graduation. This is not to be construed as an attack on the schools as no one is born with this knowledge and has to be trained. This is to eliminate the release of commercial drivers on society that shouldn't be behind the wheel for financial gain. As far as the time required for completion, a carpenter, electrician or a plumber goes through a 5 year apprenticeship. These are important jobs but do not hold the lives in their hands a commercial driver does in one day.

  1. The rule that was on the inside cover of the original CDL manual.... Read, speak and understand English! This needs federal regulation as the states have dropped the ball. I have no issue with ANYONE driving, but if a person needs to learn English that would be an additional year to learn to communicate.

A final note: I understand this would add considerable expense but having capable drivers behind the wheel will quickly show up in less crashes that the truck driver is charged for. A point system for moving violations that is in use now should be used for current drivers. Any driver that points out would be required to complete a condensed or a complete apprenticeship. This would weed out the problem drivers over the first five years! I know the different trucking organizations will cry there is already a driver shortage and this will add to it. I am now disabled and as I drive my personal vehicle and see the stupid mistakes made by commercial drivers....my first thought is "there certainly is a safe driver shortage"


Kari Fisher – Comments


Since most of the truck accidents are caused by non-CMV drivers, it makes sense to me that the Share the Road information is broadcast on networks. More news stories about how to drive around a rig. Let’s get Drivers Education in the schools again. I know when I got in a truck, I learned fast that I had been driving wrong around trucks and now I educate others.

If more people knew how to drive around trucks, not cut us off and stay out of blind spots the accidents are going to decline.

We are professionals and trained. We undergo drug testing and have physical every two years to make sure we are healthy enough to drive.


Daniel McKay - Comments


I have been driving for over 30 years tractor trailer. I have come across all types of weather and road conditions that come along with them. Knock on wood that I have had no major or minor highway accidents while on our interstates. The government agencies that are issuing CDL's to new drivers should hold some of the blame. I have come in contact with drivers that can barely speak a word or only a few words in English. Our country thrives on diversity and by no means should keep someone from making a living, but when someone that cannot comprehend or translate the highway sign meanings or what is defined in the FMCSA motor carrier handbook how can one expect these drivers to make the correct decision(s)? Many 1 to 2 year drivers have zero experience driving in little to mild or full blown bad weather. The written test should not be given in any language but English but living in California you can take a test in your Native language. How is this helping the issue. I think it should go back to like it was through the 80's and early 90's and issue different licenses. 1 if you drive an automatic or have only driven and taken your test in an automatic that's all you can drive with the (A) next to your CDL endorsement. If you take your test in a manual you are clear to drive any drivetrain. New drivers like airline pilots need to have a certain number of hours before they are allowed to go solo. There should be a CDL license issued perpendicular for 2 years with new drivers giving potential companies the leverage on where to be sending their new drivers. DOT and FMCSA should set up a 2 year probationary time and intervene if recorded issues are frequent. Some things we cannot control period. I carry myself a dashcam to protect myself and my freight. There are numerous times automobiles pull right in front of you or change lanes with no safe distance or an "out" for the tractor trailer. They don't think twice they have no idea the stopping distance we need but over and over people put themselves and family members at risk of injury or death. The ELD is not the problem if used correctly and the driver knows how to take advantage of it the ELD actually works great. The hours of when the start of your 14 can be worked on a lot better. Shouldn't have to punished or loose hours while waiting for a load or unload. The state's police need to work harder on cars that impede into a truck's area too soon. Oregon had actual signs that they will ticket you if you cut into a tucked path too early. Tractor trailers should stay in the right lane always except to pass. They don't need access to every lane. there's no reason why a truck and trailer should be out in the number 1 or 2 lane. There should not be a slower speed for trucks on the open interstate then for automobiles. It’s not making any sense to have one faster than the other. It puts a black mark on the commercial driver trying to pass at set low speed limit with a line of cars behind it. My biggest input would be better trained drivers and licensed for the equipment they operate. Hopefully some of this input will make someone question it or use it.


Danny Piersall - Comments


Crashes and safety of the industry have been my concern since the day I started driving. After driving for over 10 years I have been taking notice of many things that have been my concern. From hours of service to equipment safety issues that have never been anyone’s concern.

Let’s start with equipment. With the concern for aerodynamics and fuel mileage. The design of the trucks has created several safety issues. From the windshields not being able to be completely cleaned from rain and snow. The side windows not being able to be seen out of and mirrors being covered during rainstorms. Every trailer or at least 99% of them have the issue that the rear side marker light is just a solid red light. As the trailer is being backed no one can see the flashing lights from the side. So, these items cause fixable issues that can be fixed. Let's put some drivers in on these types of issues.

Now about the vehicles driving around these trucks. Interaction is the concern a driver has to deal with more than any other driver on the highways. If there was a truck only lane to the left. The interactions would be eliminated by a significant percentage. By just doing this, accidents with the local motorist could be potentially nonexistent.

I have some other ideas that might be of concern if you are really interested in doing as your acronym suggest.


Roberto Torres - Comments


I’ve been a company owner and driver myself for 34 spotless years. Drivers are trying to beat the clock because a machine is telling their body when to work and not. Elds are comfortable to work with but the hours flexibility to nap and avoid loss of time due to traffic, accidents, weather, shipper and receiver delays...those are factors that require flexibility. companies won’t talk about this because it pushes drivers away...but that is a fact. Eld is not the problem. it’s the flexibility of been able to turn off and on when necessary. because your body, mind, and health letting you know when you’re ready. I myself have been caught in predicaments of. Tired but I have to go because I can’t shut off and take a nap or rest...1 suggestion that I’ve got from talking to hundreds of drivers...the 11hrs driving and 14 daily are fine. but let us work at body pace. When your 11 are us. Then we will take 10 sleep straight.... but again, let us have flexibility on the drive time...and the 34 reset is a waste of time. Nobody’s body needs 34 straight sleep hrs. All that does is delay you even more so you can hurry more. Like I said...34 years scratchless driving. I can answer any question you would like from 34 years of experience and 3 generations trucking family

thank...you... Goldengate Logistics

mc 657413

email [email protected]

11 hours at your own pace

16hrs daily to deal with all predicaments

terminate 34 reset

drivers can now have flexibility and work with patience and knowledge

no more ""hurry up because I’m going to be out of hours soon""

(PS: big companies won’t tell you this...their scared for lack of interest)


Anonymous Anonymous - Comments


The main reason for truck involved crashes increasing is due to ELOGS!!! Drivers are forced to be more aggressive, speed and take chances whilst chasing that elusive clock. Plus add to the fact a driver might be tired but has dispatch breathing down their necks..."you got hours on your clock...DRIVE!"


Donnie Cartwright - Comments


Hello, 1st of all I've been driving 30 years. Been around trucking all my life. I'm 50 years old. When I started driving there wasn't any training so to speak. I had ridden thousands as a kid. I knew what to do and not to do when I decided to drive. I was local at first, then branched out. I always keep in the back of my mind what can happen to myself and to the public if an accident occurred. To drive a tractor -trailer isn't for the faint of heart... Look into the backgrounds of the people who is the cause of crashes. I would bet that a lot of them are inexperienced, not of our country, (the big truck in companies has billboards in Europe to come to the United States and drive). Only US citizens and our neighbors Canada, Mexico, should be allowed to operate in the United States. It's so dangerous out here these days. REFUGEES SHOULD NOT BE ALLOWED TO OPERATE SEMIS IN THE UNITED STATES... I help them guys all the time. They don't know what they’re doing!!! I still learning. The Russian truckers are the most dangerous. They are so reckless. JUST STUDY THE PEOPLE IN SEMIS THAT CAUSE WRECKS. YOU WILL BE SURPRISED!!!

And electronic logs put people in a hurry. I've been on one for five years now. I like it. But for the first year I was in a hurry. I'm was never in a hurry. But I got used to it. I own my own truck so I have total control over my truck. I've been an Owner - Operator since 1994. Company Drivers should have the same freedom... " We are the Captains of our Ship" Some drivers are so controlled, it's not even human like.

Split speed limits are dangerous.... Change logbook regulations...I own my truck and trailer. All owner. operators should have more flexibility. (Not the large carriers with lease truck drivers) I go to the bank and get loans for equipment... These large carriers are a big problem. Since deregulation of trucking in1980, the circus has grown to epic proportions... No English, no CDL or driver’s license. That's a law that's needs to be enforced. My statements have nothing to do with race. All colors should be able to speak and read English when operating on public roadways in the United States. Everyone should be aware of their surroundings. No rookie should operate in the Rocky Mountains in the winter for sure!! And wear sunscreen. That's all I know. So long, Donnie Cartwright. of Madisonville, KY.


Winston Herzfeld - Comments


It shouldn't be hard to figure out it's because now when a driver starts his day all he’s thinking about How quick and how far he can get M11 hours we didn't worry about that before we had flexibility there's no flexibility on the electronics log


Lloyd Lazarus - Comments


HOS is a big issue. The 30 minute break needs to be abolished, it is babysitting and needs to stop. It is pervasive in almost all government thought cradle to grave mentality. The HOS need revisiting, a 12 on 12 off no unstoppable 14 hour clock. The unstoppable 14 hour causes drivers to drive when they may not be mentally alert also drive during rush hours when they know that it would be more efficient and less costly to drive ,but because that 14 is ticking they often are forced to continue when it would be better to park and sit for an hour or so . Another good idea here the ability to split time say something like no more than 12 hours driving in any 36 hour period, this would give us the ability to drive at night when there far less traffic. I think the 70 hour rule needs to be amended to 90 in an 8 day period. The other item that desperately needs fixing is the standards and practices of how training is conducted. Incentives for schools to be paid by the FEDS for students graduated is insane. The school is now interested in the money and not whether this student should be a commercial driver. Companies are "using " students as team operators, when this is unfair to the student, they are routinely paid half as much as the trainer and do the same amount of driving and the company makes much more revenue for moving freight twice as much. The ONLY thing we need more of is DOT and police enforcement of unsafe behavior by cars around trucks. The general motorist is frustrated by the slow moving truck and often makes a hostile move in front of and next to large trucks and there is NO enforcement of safe following distance.


Randall North - Comments


I'm not sure I understand this. Has there really been no "large truck crash studies" in 15 years? Please tell me this is simply poor editing as in the above header. Do we really not have anyone collecting and comparing data from fatal wrecks, regardless of the vehicle sizes? With all due respect, isn't this what we pay ALL of you to do for 40 hours a week? ...for 15 years? Doesn't Excel do all of this for you, just type in the numbers from forensics and excel gives you leading causes. I can't comment on how to help you improve how you study crash's because I don't know how you currently study them.


Bennie Duncan - Comments


Look at the interaction between. The HoS and ELDs. Before many people were gaming the system, but those tricks gave drivers flexibility and breathing room incase anything should arise. With the ELD those were effectively removed. I know you guys have changes pending that may alleviate this. I would say enact the changes and see if there is any increase or decrease of accidents.


Adam Thomas - Comments


I feel that there are 2 contributing factors:

1) The ELDs with the current HOS regs are unquestionably making people race the clock. People are not robots. They need flexibility! They need to be able to stop when they get sleepy. The inability to stop the 14 hour clock is a huge issue. Truck drivers are not allowed to drive for more than 11 hours in a day but there are too many un-controllable things that lead to things that happen when driving (traffic, weather, shippers taking long time to load, etc.). The fact that driving a minute past your allowable time can literally have a negative impact on your career for years is crazy. Why is it perfectly fine for a critical care nurse directly overseeing lives of multiple people and having to make critical, split second decisions able to work double shifts with not a word said by anyone. Nobody even blinks an eye yet if you are a professional truck driver, you have a million laws telling you when and how you can work??? It just doesn’t make sense!

2) The automatic transmission is leading to more deaths. The mega carriers will put anyone in a truck with a week or two of training and let them go. This is possible with an automatic transmission because they are simple to drive. A manual transmission takes time to learn to operate it and very few will ever master it with a couple weeks of training. This causes people to spend more time with an instructor teaching them and leads to drivers being better trained.

I would want to see the stats. I would want to know the average length of time the CDL holder had their license (I.e. experience). I would also like to see whether it was a company driver or owner/operator. And I would like to see the stats on whether the accidents are happening at a higher rate with the drivers having an automatic transmission only endorsement as well if the trucks themselves were automatic or manual shift. I think this data will lead in the right direction. There are simply too many HOS regulations and not enough oversight on the Mega-carriers ability to throw anyone in a seat. It needs to go back to more O/O and less of the mega carriers with their lobbying money buying laws to cripple O/O because they want a bigger share of the pie. In the internet age, the mega-carriers are far less needed. Get rid of the HOS regulations and allow capitalism to work rather than continue crippling the O/O so the mega-carriers can squeeze the little guys out of it entirely!


Daren Keats - Comments


I have 35 years in the trucking industry, as a driver and an owner/operator. FMCSA fails time and again in protecting the general public with its failed policies and unsound regulations. ELD's is just one example that there are so many people working at FMCSA that have no clue as to what they are doing or talking about. They no longer have credibility. FMCSA's own statistics on crash studies show that FMCSA is a contributor to the increase in crashes and fatalities in the country by their own reckless regulations and policies. Until FMCSA listens to and implements' policies and regulations by the drivers and DOT safety officers that are on the front lines will our highways again become a safer environment for all of us.


Patricia Steeves - Comments


As the wife of a truck driver; I have seen and heard a lot over the past 10 yrs. I feel there is several reasons for these fatal accidents. 1: ELD. Since the government put these into effect you have drivers racing the clock. There's no way to stop the clock when you're stuck somewhere loading or unloading, in traffic, need to eat, shower, nap or even fuel up. 2: 4 wheelers. They have no respect for the space they need to give a semi. They’re on their phones, always in a hurry or just not paying attention. My husband has been driving for 42 years, his CSA score is perfect and really doesn't deserve to have it ruined by someone who is not paying attention. I've heard of several truck drivers who have to jump thru hoops to prove that they were not at fault for an accident. Final reason: foreigners who have little to no experience in a semi. They have their trucks on cruise control and a laptop mounted on the dash watching DVDs, REALLY!! The trucking industry isn't what it used to be.


James Edwards - Comments


This is easy and I'll save you a lot of time these are the consequences of bad training making it "easier" to drive a truck with the introduction of automatic transmissions and the whole push for drivers in an industry that's saturated. Add the eld and no flexibility in the hours of service and this is what you get. This better include time in country age, time behind the wheel. You guys put a timer on people and now when they are killing themselves and each other you go why? So much for your college education.


Hasan Chami - Comments


Hours of service is a main contribution to high accident rate.

Inflexible hours of service causes drivers to run maximum miles possible within the 14 hours on-duty window. For example. If a driver felt sleepy while he has only 2 hours on his 14 hours and he needs 2 hours to arrive at his destination pick up or delivery. The driver will not be able to take a break. Not even a 15 minuet break. Because this break will cause him to either violate hos or delay him 10 hours. Keeping in mind that drivers consider rush hour times and when to drive through major cities. Drivers do not need to drive more than 11 hours a day but limiting When can they drive the 11 hours is the problem. Considering that many drivers cannot drive 11 hours a day when they have to load and unload during the same day for loads that are about 500 miles (very common as a same day delivery). 2 hours to unload 2 hours to load as minimum. Drivers only have 9:30 hours to drive. Without even the possibility of a short 15 minute break. Also, in many cases if a driver had to take his 10 hours during daytime and he is not used to it. Then he will have to be up all night and forced to drive throughout the night Regardless If he had a good sleeping time during day light of, he or she is not used to it. Allowing drivers to take a break without it reducing the miles he can run in 24 hour period is a key. Drivers are paid by miles and not very well. Any reduction in the miles they have to drive effects their paychecks. Drivers are driving legal but not safe. Fmcsa need to figure out a way for the drivers to drive safe first. Before ELDs drivers cheated their logbooks to drive safe. Illegal but safe. Now they drive legal but unsafe.


Anonymous Anonymous - Comments


How about some real statistics on the nationality of the drivers involved? Over 80% of the drivers in these accidents are foreigners. Where they come from, they don’t even drive not to mention they don't even have an interstate system. The only place even close is Germany and they aren't storming the boarders to come over here to drive a truck. That’s because they got it together over there. The foreigners that come over here can’t even speak our language but somehow, they get a license yea right. That’s because they buy a license and the trucks they are driving are one of their realities or friends or somebody they know somehow and they aren't even close to being road worthy but somehow they are never cited or even inspected but when one of us (Americans) has a head light out or some other minor infraction mostly because the roads are so rough that it literally beats the parts off the trucks dot runs out of ink writing us citations, trying to impound the equipment, arrest us, etc. Maybe it’s because you the government knows the business is a minority owned business you know owned by a foreigner and does not inspect them at weigh stations or audit the company for compliance. Why can you not ensuring proper driver training through regulation, you already regulate the industry to the point of ridiculousness and hire uneducated people who have full discretion to enforce something they don’t understand. Furthermore, asking the industry and the general public for guidance in this matter is unacceptable.

It just further shows the complete and total incompetence on your part to regulate the industry. How about you resign your position and refund my tax dollars spent and stop waste my tax dollars and stop taxing us to point we are forced out of business.


Stephen Rudometkin - Comments


After 24 years of driving with the CDL in the last 10 years of driving the quality of the driver has gone down. There is no more mentorship it to turn and burn mentality with the trucking companies. I don't like the logbook rules and the control the cameras. But the problem is that corporations are pushing you guys to make things tighter to control the driver. You add more rules that you're pushed by the corporations to do to make more money for the corporations. But you're not looking at mandatory training for the drivers, was electronic logbook I have to remind myself to slow down mentally to be stay safe. I see the truck drivers drive like four wheelers and they have the same mentality it's sad it's scary. I have a brand-new 2020 Freightliner Cascadia and there's too much technology. I can set my cruise control, use my Jake brake to set myself up for the turn safely, that the Jake brake off at the apex of the turn in the optical sensor will control the speed of my truck that scary. Too much technology not enough hands-on training. When you have an automatic transmission optical sensor you can't shifter truck it's easy to put someone into a truck with that technology, But your safety standards will drop and more people get killed because of too much technology and not enough training hands-on one-on-one. Thank you


Rhonda Tubbs - Comments


I am a woman truck driver/operator going on 37 years now, in the upper mid-west, subjected to every kind of weather there is. I have observed and helped a lot of other drivers. My observations are as follows;

  1. The NEW automatic braking system, I drove a Volvo with it for 2 years, never again! It is a suicide system, especially on snow and ice, on ice the last thing you want is the brakes coming on, you have to gain control with the throttle if the trailer starts to slide, you CAN NOT, because everything is froze w/autobrakes! #1 cause of accidents
  2. E.L.D.'s Major distraction. Couple them w/the DEF system and every other gauge and sensors in a truck and you lose track of the road. Drivers are always PRESSED for time, always trying to beat time, and putting safety second. I have talked to a lot of drivers that have ELD's with cameras in them, and there on edge all the time, due to the fact, somebody is always watching them. What happened to our Constitutional Right To Privacy??? Go back to the good old days when you could have 8 hours off within a 24 hour period? Accidents were a lot less then, and everybody did not have hyper-ventilation sitting at a dock, sitting in a grain line, or sitting in a traffic jam. Drivers are so stressed out now, they do stupid things!
  3. Refugees getting CDL's that cannot read, speak or understand the English language! States are furnishing interpreters (like my home state of MN) to take the tests with. How is this happening? I have had to talk to their dispatchers for them, because they do not know where they are at. I have had to follow them coming up to a round-about (drivers call them circle jerks, due to the hazard they cause) and the driver comes to a complete stop, because he doesn't know what to do, with 2 miles of traffic behind him. I could go on and on, but they do NOT belong in trucks to they can be properly trained and can read English.
  4. Proper training for the rest of the population that has a driver’s license. I have suggested, to our State Reps., a mandatory video (and I would be willing to help make it) that every time a person’s driver’s license is up for renewal, they would have to watch an educational video about why trucks do the things they do, I.e. Enlighten their awareness of spacing, braking, and what weights they are next too.......
  5. Lane restrictions around metro areas. With trucks having to be in the right lane, it causes chaos, nobody can get to their lane to take an off ramp and nobody trying to get on can find a space to get to during rush hour. Absolutely backwards. Through traffic, including semi's, take the far left lane, the rest take the two right lanes, the flow of traffic goes at a steady pace!


Roger Lathem - Comments

The is a Comment on the Federal Motor Carrier Safety Administration (FMCSA) Notice: Request for Information: Large Truck Crash Causal Factors Study


For related information, Open Docket Folder



I am a driver and been driving for 19 years. I'm also a fleet manager for the company I work for. I see everyday people on their phones texting and driving not paying any attention of the other drivers around them. Yes, I also see truck drivers doing this also. I also see drivers with bare feet up on dash boards watching something on their phones driving down the road. Even though technology helps use for the future it is also one of our biggest problems. People are so custom for everything being done for them now, now they have time to watch YouTube, movies or what have you going down the road. I also think that in major cities instead of their being a no left lane law should be looked at a little different. My personal thought on that is that for straight thru traffic they should allow trucks to be in left 2 lanes for traffic entering and exiting the highway. Look at Columbus Oh straight thru traffic can use left lane and for semis is a good idea as I go thru their everyday without any troubles. I don’t have to keep stopping and going which slows traffic down and it also causes accidents when someone isn’t paying attention what is going on around them. Another thing that causes accidents that I have seen is you have trucks running 62-65mph and other traffic is running 70-75 also can cause accidents. I also think that new people trying to come into the trucking industry should have more than 3 weeks of training before been allowed to be on their own in a truck. I also think that someone that has only been driving for 3 months should be allowed to train a new truck driver. Their do not have enough experience behind them to be teaching someone new to drive a truck. All of these are factors for crashes. Yes, everyday a driver can learn something new even me as many years as I have behind the wheel there is always something to learn.

Thank You

Roger Lathem


Anonymous Anonymous - Comments


Electric logbooks are dangerous and no way to stop the 14 hour clock


Clayton Frey - Comments


I would like to start off by saying I have been in the trucking industry for 19yrs. These studies for the ELD have not proved any good outcomes. All the ELD does is restricts a driver on getting plenty of sleep, driving during daylight hours where there are more people on the road so naturally adding more trucks to the congestion of traffic is going to cause more accident mainly because the average small vehicle driver does not pay attention. Most truck drivers are responsible drivers. Has anyone ever looked at how many small vehicle accidents there are compared to how many commercial vehicle accidents there are? The commercial vehicle accidents that involve a driver being tired is most likely caused by the ELD being in effect that the driver has to race the clock. Look if someone is tired, they should be allowed to pull over and sleep and not have to worry about running out of time for the day.

What's safer? .... a driver getting sleep so there is no accident or a driver driving tired? Us old school drivers like to drive at night because there is less traffic on the road and we can make up time because of the less traffic. Having to drive during the day is too much stress on drivers on dealing with the traffic. For Instance, I drive at night from Harrisburg PA to Chesapeake VA in about 5hrs down and about 5hrs back just so I avoid the traffic. During daytime hours it can take as much as 8hrs one way because of traffic accidents and guess what I notice when I see these accidents. majority involve small vehicle accidents that they weren't paying attention. I have seen people in small vehicles shaving their face, reading books, playing on their phone or iPad, reading newspapers, headphones. As for truck accidents let's think about this one companies need drivers who have no knowledge of anything in the trucking industry so most people today can't drive a manual shift in which leaves drivers being bored since they don't have to shift so of course they are going to be playing on their phone or doing any of the above I listed about small vehicle drivers not paying attention. Driving an Automatic transmission, you will not have the control of the truck as well as a manual transmission. I had several months of practice / training before I went to get my license. Driving an 80,000 pound truck down the road just can't be taught in 2 weeks! So, with that being said trainees need to have at least one month driving course and mandated to be with a manual transmission.

Look back on the older generation who has been around trucks and trailers for many of years and question them. It's safe to say they are able to fix the truck or trailer if it needs something to get them down the road safely to a truck stop to get fixed or get home. These people today companies are throwing in trucks with 2 weeks training or none at all know absolutely nothing about the truck or trailer. Maybe I'm old school but I am 36yrs old and went to school to be a mechanic to learn everything possible so I knew how to drive a commercial vehicle properly. I have many of certifications from being a mechanic before driving.

Now as for the ELD mandate let's think about this one how about we make the small vehicle every day drivers be put on Ignition Interlock and or ELD and do a study on them and let's see the results. I would be willing to bet my business and salary on the fact that the results will be shocking and give results most people wouldn't expect. You want to mandate commercial drivers. majority of us are safe because we know this is our lively hood and without our truck (s) we would be out of work which means no money. How is this a level playing field for the Owner Operators vs Big Companies? Big Companies have hundreds or thousands of power units. Whereas my company I have 2 trucks and don't want anymore. Why is this you may ask? I don't want the extra headaches and hassle of having hundreds or thousands of power units to be a multi-millionaire. More people working for a big company just means a higher turnover rate and less people care about their job because they know they are replaceable. I do this because I love what I do it's not just about the money. I live a comfortable lifestyle not a rich and fancy one. Being a small company of working for myself I am not replaceable so everything I do my family relies on me so this makes me more cautious and aware of everything. I can't undercut big companies because I have to provide for my family so I need to go where the money is and unfortunately it's getting harder to do that when my fuel bill is getting more, my truck insurance goes up every year even having a clean record, my shop insurance goes up just for me to be able to work on my equipment to save the money so I don't have the down time and repair expense to take it to an outside shop .

Common sense goes a long way and unfortunately most people don't have it and just don't care. Try being self-employed and make a living!


Robert Champion - Comments


I have been driving since 1980.

What I see is a lot of trucking companies just putting anybody in the seat. And in doing so they have inexperienced drives. They have made trucks that anybody can drive. So, they hold the wheel with one hand and the phone with the other. It's sad.


Matt Conway - Comments


Newer cars have a blind spot sensor on left and right mirrors. Semi-trucks should have this blind spot sensor on all new trucks. Overlooking a vehicle on either side while driving can cause an accident, but with sensor lighting up you will know that a vehicle Is there. A law requiring this will be good.


Anthony Wills - Comments


You need to change the hours of service and give truckers back the right to control their hours. You need to up the age of drivers and you need to make companies spend more time training the new drivers. You need to take these GPS and crash medigation off of trucks. And get rid of us required to run 65 miles an hour. And make it where companies are not making us run technology in our trucks.


William Crawford - Comments


YOU contributed to the problem of large vehicles (trucks & buses) when YOU insisted that ELD's would be the fix-all.

ELD's are causing drivers to SPEED to complete their trip which leads to accidents.


Robert Spoon - Comments


Items to consider

1) distractions in the cab but also distractions in the motoring public as a whole

2) inflexibility in Hours Of Service which force drivers to operate when they should be resting

3) lack of parking no more surveys actually provide a pathway to more parking spaces

4) CDL holders lacking the ability to read and understand highway signs and directions. If the overhead sign says slow traffic ahead but you can’t read the sign then it may as well be advertising Pepsi drinks.

5) crumbling infrastructure which takes a toll on the human body physically and mentally and has an effect on reaction times

6) lack of standards in CDL training both before and after receiving a CDL


Phil Killerlain - Comments


To get the right answers you need look no farther Than the Training of new drivers for the last 25 years What little bit has only been concentrated on just passing the CDL test and not much more

Then you have the PAY SYSTEM based on miles ran And regulations based on Hours worked Which lead to the drivers being in a RUSH from the time they start the 14 Hour clock until it runs out! Being in a Rush leads to mistakes no matter the occupation But in trucking it shows up in accidents and deaths Then you have distractions today's drivers have to many screens on the dash that lead to them staring at instead of the road! As helpful as GPS has been for getting drivers to certain points it also is a distraction when not familiar with an area and they are looking at it instead of the road same with the screen Dispatch and ELDs when running close on hours towards the end of the day Drivers are watching the ELD screen counting off the time causing them to rush and pay too much attention to it ! Because of the THREAT of Fines and or loss of employment from running over the time limits!

So, if you really want to decrease wrecks and deaths?? Start with more training especially Winter Skills and a Skid Pad course make it part of the CDL requirements! This alone would cut out half or more of the truck wrecks each winter! Then Start pushing companies to Pay drivers by the Hour! Unless you are going to get rid of the 14 hour death count down each day!


Joe Butler - Comments


Look why don't Y’all just eliminate the 14hr rule and the 30 min break. There's 24hrs in a day. Mandatory 11hrs driving time and a Mandatory 10hrs break. If you eliminate these two, the driver's will be less stressed on trying to complete their day without having to worry about finding a place to park and have that constant pressure of feeling rushed. Let's face it, those videos Y’all show of how ELD works is not being based on actual events. For instance, accidents, construction or whatever else that we drivers face unexpectedly. 11+10=21 which leaves 3hrs for unloading or loading. Drivers can choose their driving time to avoid rush hour traffic day or evening.


Dennis Dematteo - Comments


If you would like to do a study, I say you do a country wide program where HIGHWAY patrol officers drive 18wheelers like professional truck drivers do for at least 6mo unmarked truckers equipped with video cameras and radar guns to document video and speed of other vehicles. I feel this will be more useful not only for crash data but speed limits and road repair and further safety for big trucks on our roads!


Anonymous Anonymous - Comments


I want to sleep when I want to sleep not when your ELD let me sleep...we are humans not robots....I wake up 3am to start my day, my biologic clock tell me I am not ok but to be home for the weekend I need to start at 3 am...I think the FMCSA became a domestic terrorist organization. Americans are dying because of your ELD mandate...with your stupid enforcement good drivers are leaving the industry and you don't have new drivers coming in because you are killing the owner operators and it is no joy and no pride in driving a truck....you have a lot of frustration in the industry and a lot of drivers complain about the ELD mandate...every day I meet a driver angry with cops...eld....FMCSA...and this guys are in traffic carrying 80000 lbs....trying to beat the clock....14 hours rules....the traffic...snow.....FMCSA created a problem and people are dying....don't blame the drivers....a fast solution: flexibility at the driver discretion .8:2/7:3/6:4...nobody want to work more...but we need flexibility...and for good drivers you need small businesses and owners operators with joy and happiness in what they are doing.... FMCSA copying socialists driving systems from Europe it's not the way to go ....time will prove how wrong FMCSA is but the sad part is that the Americans are dying on the road....I hope that the families of the people hurts in the accidents they go after the FMCSA officials in court and prove their wrong doing and make them accountable.


William Springfield - Comments


you need to check into these truck drivers school to see just how well they're training these drivers and these young drivers they won't take advice from the older drivers the younger drivers don't want to take the advice they know it all

Oleg Vishnevskiy - Comments


I am working in Truck industry since 2000. I had to see a lot of negotiable changes in Trucking Industry by FMCSA. The reason for the Trucking Majority Accidents is ELD. When we used Paper Logs, we rested when the body wanted it, and slept as much as we wanted, and when we wanted to sleep. Today, ELD tells us when to sleep, which is contrary to the nature of the body. When using Paper Logs, then some idiots exceeded the speed on the tracks, but mostly the trucks drove quietly. The Track drivers was more respected than now. And the reason for speeding is definitely the ELD because a lot construction on Freeways create congestion traffic drivers need to drive because ELD don't count the congestion traffic.


Anonymous Anonymous - Comments


I believe that the ELD's have a lot to do with the rise in accidents due to the driver feels pressured when his day is nearing the end of his hours. I'm a driver and have found myself in this position more than once due to several different reasons, such as delays at the shipper or receiver, a flat tire, or an accident that shuts the freeway down, just to name a few. Also, one of the biggest problems in this business is that the people making all these rules and regulations up have never even been in a truck.


Markcus Davis – Comments


Why ask why? When drivers speak, you guys don't listen. These accidents/ deaths are a culmination of many problems that the government cause. First, transportation is overregulated in the wrong areas and under regulated in other areas. Elogs, they have encouraged high stress level and stress encourage chronic illnesses. This will lead to more driver dying of heart related illnesses behind the wheel. It's going to get worst. Driver are trying to make up time being in the dock all day. The government is not making the shipper and receivers accountable. Brokers are taking too much of the money. This makes drivers beak the law to make ends meet. I can go on and on, but in a nutshell, Washington is the problem. Stop being about making and taking money and get down to business of the people. There are going to be more accidents/ death until you flunkies start listening to the drivers. It will get worse. What you guys are doing are not working. Please feel free to contact me. Let's work together and not against each other.


Brian Bridges - Comments


The Hours of Service rules promote an unsafe environment for all motorists and unhealthy to commercial drivers. The evidence proving this statement is plainly seen every morning and evening during peak traffic hours.


The driving behavior among motorists during morning and evening rush hour commutes is aggressive due solely to the urgency to get to their destination on time or not be late. Under the FMCSR hours of service, every commercial driver on the road is subjected to the same aggressive driving behavior exhibited by rush hour motorists, difference being the commercial driver is under this stressful sense of urgency from the time their shift begins.


Terry Jordan - Comments


I was a Pennsylvania State Trooper for approximately 18.5 years. During that time, I had investigated well over 1,000 crashes. I was either the primary investigator or assisted other Trooper's with their investigation.

The biggest issue to overcome is how the crashes are reported for FMCSA to get accurate and consistent information on crashes reported. The other issue is most commercial vehicle crashes are just given basic investigation and aren't dug into in great depth. Unless there is a fatality most police agencies don't investigate the driver or the company past the roadside investigation. Most agencies don't have the manpower to do more than a roadside investigation.

Some investigators maybe biased against trucking companies and place fault with them versus a passenger car.

Some investigators don't have the skill to look at a crash and make a true determination as to casual factors of the crash.

FMCSA has been looking at fatigue as casual factor in commercial vehicle crashes. That was one of the reasons for ELD's. In all of the crashes I have investigated I could probably count on one hand the number of times I felt that fatigue was the cause of the crash. Private passenger vehicles on the other hand I investigated several where the operator fell asleep.

Speed, following distance, distraction, improper lane change and probably less than one percent of commercial vehicle crashes were mechanical related were factors in crashes I investigated.

I have been working in the private sector for the past few months and have viewed in cab video of the company I worked for. There have been several close call incidents that I have reviewed. In a majority of these incidents the driver was either not looking far enough ahead to forecast what was occurring in the distance or the operator wasn't giving themselves enough space to manage the traffic around them.

There are studies out there that approximately 87 percent of CMV vs PV crashes are the fault of the PV (passenger vehicle) how is that accounted for? Are they still preventable on behalf of the CMV even though the PV was found at fault?

To gather useful information on crash data FMCSA would have to develop a Federal Crash form to gather consistent and accurate information regarding commercial vehicle crashes. No two agencies utilize the same crash report form, so not all agencies are reporting information in the same manner. As I state earlier there isn't consistent reporting of crashes. Age, experience, and nationality needs to be taken into account as well.

In this day and age companies still don't utilize the technology at hand to monitor and train their drivers. It is much easier these days to monitor drives by GPS and video. Many companies don't utilize it and companies that do have it don't utilize it to the fullest extent to train and monitor drivers.

It still boils down to companies making money. Companies do what they can to squeeze the most out of their drivers.

Insurance companies that take the biggest chunk of money from trucking companies don't incentives safety measures by trucking companies. In fact, they go out in search of claims to buy and purse for money. That is a whole other subject for later.

For FMCSA to truly see where the problems are there needs to be consistent reporting of crashes and crash data to see where the true problem is. Until this is done all other efforts won't matter.

For trucking companies, it is a matter of utilizing all of the technology that they invest in.

The other motoring public needs to have a certain amount of awareness and respect for commercial vehicles

In addition to creating an unsafe environment, the Hours of Services rules is unhealthy for commercial drivers. Because of the sense of urgency to drive as far as possible within the 11/14 hour rule and 30 minute break, commercial drivers are exposed to heightened stress levels which medical studies have shown harmful to the body. Also, the same urgency pressures commercial drivers that they may not eat properly.

What are possible solutions?

For the long haul commercial driver, a miles of service rule would make for a safer and healthier environment because it would eliminate aggressive driving behavior and lower stress levels that the commercial driver is currently under. By putting a limit on the number of miles a commercial driver can drive in a daily period without a time restraint, the commercial driver will be in control of optimal drive time based on location, time of day, weather and road conditions. The commercial driver will also have liberty to stop without worry of losing precious drive or on-duty time to rest or eat.

Mandatory rest periods would be necessary after the maximum miles driven limit was reached. Required breaks during the course of the day would be feasible but the breaks would be set according to miles driven, not by time limit. A suggested mandatory rest period and maximum miles per shift might be a 12 hour rest period after reaching 750 miles. Mandatory breaks during the shift might be a minimum 1 hour break between 275 to 350 miles of driving and minimum 15 minute breaks at or before 200 mile intervals.


Erich Finch – Comments


I don’t think cell phones, GPS, or anything else has to do with it. I think it’s the lack of training in companies pushing drivers threw, I believe we need to tighten the ropes up on trainers, and schools that teach them! I’ve been out here over 20 yrs. An seen a real problem with drivers not trained right, racing the clock on elds running faster threw construction just to get every min of their 11 hours. We need the 14 hour rule removed. But hey who are we? Just a bunch of drivers that now nothing of what we need. I guess we should be asking our desk pushers (ata) (patt) an all the other non-driving ppl that think trucking is a 9 to 5 job! Thank you for reading.


Timothy Horak - Comments


Smith Defensive Driving Course is the greatest way to instill Safety in all Commercial Motor Vehicles. I have taken the Course and I apply the teaching to my driving, and it keeps me safe. While I was a CDL instructor I used the principles from the course and applied it to the students while learning how to drive CMV.


Cristi Lazar - Comments


ELD mandate was forced in to the industry by the lobbying groups from the mega carriers because of the FMCSA fines for the logs....but if you don't know how to do your log you are not supposed to drive anyway....now you destroy the small carriers because they can't compete with the mega carriers ..but the studies show that more Americans are dying on the roads....A few years ago FMCSA put a show about the woman in charge of FMCSA stayed in a truck one day and she slept overnight....what a joke...now you realize that good drivers are leaving the industry because of FMCSA and you are left with the millennials....and accidents and people are dying in crashes....but like in the wars we (drivers)are just soldiers.....FMCSA is the leading party responsible for what is happening on the roads....people are dying because of FMCSA and the incoherent policies produced to and in favor of mega carriers.....if you keep protecting mega carriers you will not see any improvements....because small carriers are the foundation for next generation of drivers ....long story short....FMCSA destroy the industry with wrong policies....no good drivers because of FMCSA....no happiness on this profession anymore...angry drivers with the rules and FMCSA and you are stuck with the new drivers inexperienced....results: people are dying...I have a lot of experience in driving but what I sow in the last 2 years...unbelievable....what was taking you so long to realize that you have a problem....

You need solutions....destroy the 14 hours rule...8/2,7/3,6/4..(sleeper split) at driver discretion not at the ELD recommendation and give some small advantage to small carriers (3-5 trucks )you need some good publicity and to sell a dream that you can succeed in this business...you will attract good peoples....if you protect big companies and you create advantages for them like you did in the last few years....it is like Amazon...zero taxes in federal ...and you think that the peoples are stupid and don't see what are you doing....we supposed to be number one ....FMCSA is copying a socialists driver system from Europe....when you copy you are not the number one....that's the first mistake....

Good luck to you....


Bryan Huntsman - Comments


Start holding four wheelers to the same standards they hold us too. Same consequences same amount of points. Once you do that shell see things start to clear up.


Michael Sater - Comments


The biggest safety factors are simply put. WE HAVE OUTGROWN ARE FREEWAY SYSTEMS. WE NEED TO EXPAND OUR ROADWAYS TO THREE AND FOUR LANES TO SAFELY MOVE TRAFFIC. The hos rules need to be changed. Do away with the 14 hour and the 70 rules. As long as we are getting our nightly or in some cases our daily sleep let us run when we are rested and sleep when we are tired. It's total nonsense to be close to home and not have enough hours to make it there just because you maxed out your 70 hour rule. PUT SOMEONE IN THE FMCSA THAT HAS AT LEAST 20 YEARS OF DRIVING A TRUCK UNDER HIS BELT.


Forrest Franks - Comments


You did this......

Why are crashes rising????

ELD's are not the problem as a whole.

Lack of flexibility is. Forcing drivers to drive long hours instead of being able to manage their hours as they feel.... Not every driver is wired the same. For instance, 8 hours of sleep for the last 10 hours of driving. Able to split driving and sleeper berth into 4 segments. Into no less than one hour. Meaning sleeper berth could be broken up into any combination they wish. Sleeper 1-1-5-1 or 2-2-4 or 4-4 or 2-1-3-2. The same with the hours of driving for ten hours. The fact that you don't allow teams to split their driving is asinine. And your idea of splitting is a joke and not only impractical but pointless to try to use...... Obviously the idea of a team to split up the workload is to shorten work time by splitting....

Ask yourself her' Einstein why employees in the workplace work in segments. Not forced to work straight through. And forcing people to work in segments isn't the answer. Everyone is different. The race against the clock plus governed trucks is your problem, it causes speeding in low speed zones. Here is the problem, you ask for input. Then do what you want regardless of input or do what those with the money want. Big companies want. Hourly mandated pay to the carrier or owner operator of a hundred bucks an hour regardless of appointment or sitting off site. Would change things immensely. Everything you do is counterproductive, and in detriment to or at the expense of the driver or carrier. You give dealerships a monopoly on emissions and creates that cause unnecessary tow Bill's. YOU ARE THE PROBLEM.

I know you won't listen and do what you and the corporations want anyway. But just for fun I thought I would inform you of your intentional ignorance. And blatant disrespect and disregard for people trying to make a living. My take on this is what I say to you will go in one ear and out the other. Have a nice day...


Mateo Anonymous - Comments


Your supposed to be #1 on safety, your own company asses to follow rules. And you want to put driverless semi-trucks on the road? You’re on our asses about the dam clock but you want to employment a policy were driverless trucks keep on turning them wheels without a clock? You’re asking for advice on a device that is going to kill people? We know humans will do it, but a robotic machine. Shame on you for letting these people automate our jobs. Guess it's all about the money and not us drivers. I won't help you at all.


Anonymous Anonymous - Comments


This just another attempt in putting be out of work, there are just too many vehicles on the roadways. The U S population is much too big people need to stop having children and letting others come in from other countries


Fred Bowers - Comments


I've seen on the roadways, two reasons for an increase in crashes. One, due to a multitude of reasons, ELDs, fuel prices, low wages, just in time freight and added pressures put on companies and drivers to deliver in a shorter window of time, and overzealous law enforcement officers out to ruin a drivers day, there has been an ongoing exodus of drivers between the ages of 45-75, leaving the profession, and taking their years of experience with them. What we are left with is an industry full of young drivers who don't respect their equipment, other drivers or the rules (laws) of the road. Trucking has become one of those jobs that Americans don't want to do. Those drivers and their experience aren't coming back, so let's focus on the 2nd problem.

There is an epidemic of drivers who are pulling off onto the shoulder of interstates and other busy highways, to take their 30 minute break on the shoulder, or often times to urinate. This forces motorists to move over a lane or sometimes two lanes, and when you have traffic continually changing lanes, you increase your accident risk. Moving over and changing lanes is one factor in road construction accidents. The worse part of drivers taking their breaks on the shoulder of a highway, is when their 30 minute break or urine break is over, they now must merge into traffic moving at 65-80 miles per hour, from a dead stop. The practice of drivers pulling onto the shoulder of an interstate or other busy highway except to render aid in an accident or they are breaking down. This practice MUST stop!


Request for Information Concerning Large Truck Crash Causal Factors


Request for Information Large Truck Crash Causal Factors Study

View Attachment:


Anonymous Anonymous - Comments


I have been driving for many years. An every so often regulatory comes to develop more regulations. The biggest problem I have seen is you won't regulate how drivers are put into the industry. You can't school someone for 6 weeks and then call them a professional driver. If you can't speak English how do you understand road signs and traffic warnings. Yes, I am talking about too many foreigners being turned lose with an 80,000 pound rocket. Then the eld put everyone under the gun. Trying to get a day’s work done when only the driver has to abide by the time limit. Shippers and receivers could care less because there’s no repercussion for holding a truck for hours on end. The trucking industry is the most taxed and over regulated industry in the country. So, I guess if you would really like to do some real help to the industry go back to the beginning, then go down the line. As for the automated trucks they will only fuel inflation the cost is way out there. But at the end of the day I think it's just another way for the bureaucrats to get more control over supplies and resources.


James Pittman - Comments


Truthfully, it all started with the introduction of "personal technology ", driving in the years, of primitive Citizen Band Radio, almost every driver used CB radios, for communicating traffic awareness, as the implementation of personalized communication equipment, became more prevalent, and laws changed to better suit the voters, loss of individual communication was lost, example, major accident, 4 tractor trailers 8 cars, blocking the entire highway was handled as follows... south bound you got a major crash up ahead 98 mile marker, ALL lanes blocked... that's a big 10-4, thank you very much, anybody copy this radio? I need 5 drivers, I copy, this is a red corvette...pull up beside this big blue rig and stay beside me, Big green ford pickup truck has a copy. Yellow Volkswagen has a copy... Big black Mack has a copy... let's all slow down to 45 miles an hour, and let emergency personnel, and police, and wreckers "CLEAR THE AREA", but by the time the traffic reaches, the "Crash Site", nothing is there... for years this went on as a solution, weeding out highway communicating.... WHAT'S THAT big rig blocking the left lane for, I’m going to VOTE, that ALL trucks are restricted from using the left lane so they don't do anything like this again, creating a continuous, river flowing into the already over flowing ocean of asphalt... enters the non-communicating, slow casual weekend boat hauling, camper hauling, children hauling, eating while driving, putting on makeup, first time driving 18 years old new drivers, beer drinkers, (I see that from my view)and last but not least, disturbing electronic distracted race car drivers, who don't have a race car, restricting freight hauling workers, by breaking laws that aren't listed, the laws of inertia, the laws of centrifugal force, laws of gravity... Enters the mathematician actuators, who claimed, I can save the company ( Hidden fallacy fictitious )money but by slowing down the truck at a certain speed... miss in formed noncommunicating drivers... why are the big trucks so slow !?!!?! Before speed limit my truck at 80,000 pounds fully loaded gave a smooth ride, at a fair 125 mile an hour, reaching 135 miles an hour, NO problem, and now I don't brag about this, because now it's against the law, also it was during ALL, cars and trucks ALLWAYS, communicating, but with the technology TODAY, I say, it's time to change the entire aspect of the highway communicating completely!!! Let everyone do whatever they want, talk on the phone, eat and drive, do whatever you want, but only in the right hand lane, entering and exit lanes are more to the right of some highway roads, change needs ALL ASPECTS, of communication, road signs and signals, instead of making comment about holiday drinking and driving, and time to get from one place to another, needs allowed words and phrases, short and quick, beginning with, left lane 90 miles an hour middle lane 75 miles an hour right two lanes 60 miles an hour, all vehicles should already have installed, "traffic communication cellular radio", instead of red lightning amber lightning, have ALL colors, 100 miles an hour displays red, staying in the spectrum, the slower the cooler the color, police can see what color is displayed and KNOW how fast the vehicle is going. Stop blaming one another, I see this traffic every day, to this day, I love driving, I have over 4 million SAFE VERIFIABLE miles, with restrictions of today's laws, I don't believe anyone is going to reach this level, I wasn't one of the tired, not sleeping enough drivers, if I was tired I pulled over and got some rest, today this type of driving with electronic monitoring systems , don't allow for the freedom to stop and refresh the drivers with a shower or nap, because it gives hours the NEW drivers of today aren't used to. I can still drive 34 hours straight, without sleeping because I'm used to it, but I'm restricted from my abilities, because someone else has health issues, I don't have the same issues, but have the same restrictions, I feel like a professional boxer that's been put in with inexperienced, low level part timers, who's only meaning of doing this is for the money, so I'll keep doing this "job", keeping it fun because that's why I started doing this in the beginning of my career as a truck driver, and now I just watch how these governed speed limit trucks can't do anything about the car that passes and gets in front of them and slows down, and when the governed down truck tries to pass, the car speeds up, and the driver governed gets a ticket for "impeding the left lane", STOP restrictions for trucks that have the ability to see over ALL traffic, and giving unrestricted abilities to the traffic that can't see past the bumper they're tailgating, and change the entire engendered process, traffic lights changing in the middle of nowhere and no traffic around, emergency traffic , should be allowed to trigger signage, left lane closed . Hopefully.


Comment from Derek Friedrichsen


I know as a human it is difficult to admit when we make mistakes however it still happens. You FMCSA are the reason truck crashes are on the rise. You are responsible for Electronic Logging Devices. All the studies in the world won’t change the fact that you were wrong if you won’t admit it. Racing the clock is why crashes are on the rise. The lack of proper training is another problem. People in your administration making rules and regulations about a job you've obviously never done is a problem. First requirement to lead FMCSA should be holding a CDL and having a million miles under your belt. Over 90 percent of trucking companies are small Mom and Pop companies but yet the 10 percent Mega fleets buy the regulations to try and stomp us into the ground. They are the ones pushing autonomous trucks because its profits over safety. Technology is not always a good thing. Automatic headlights just as an example, yesterday while driving in a snowstorm across Wyoming, I met car after car without headlights on in the daytime. The night before I saw a car driving without lights way past dusk. Most people don't know how to find the light switch because of automatic lights. The dumbing down of America at its best. Lane departure systems are another example. I see car commercials where a family simply avoids side swiping a school bus because of sensors beeping to them where the bus was. Thank you, Baby Jesus for that Nissan. Keep taking the driver out of the equation, that seems like the thing to do. In a world of distracted driving let's give people more of a reason to drive with their heads up their hinnies. You're like a dog chasing its tail. I will let you in a little secret. The second biggest lie told to the American people, Adam Schiff told the biggest, is that there is a driver shortage. That is a LIE! Driver turnover is 100% at a lot of your Donors fleets, whoops did Say that, I mean the Mega fleets. There is NO DRIVER SHORTAGE, there is a shortage of Mega Carriers that take care of their drivers.


Comment from Anonymous Anonymous


(FMCSA-2019-0277) There needs to be flexibility in the hours of service. The ELD is not the problem. Drivers are pushing themselves harder and harder to beat the clock. If you're sitting at a receiver or shipper for multiple hours, more than likely you are going to be resting. This should not count against a clock. If you decide to stop and take a nap because you are tired or you don't want to fight rush hour traffic, or you don't want to drive in inclement weather, you should not be penalized. You should be able to break up your driving and resting periods any way you need to so you can safely and efficiently do your job. As long as you tell us when our body needs rest and for how long, you take the safety out of it. There is not a one size fits all when it comes to the human body.


Brian Stewart - Comments


As an OTR Truck Driver of 14 years, large truck crashes should be investigated from other angles other than blaming electronic device usage by the driver. As an once North Carolina licensed CDL driving instructor I personally feel that the CDL school industry standards are not on par with the skills necessary for today's trucking industry. Furthermore, a common conversation amongst Driver's on today's roads involves the ELD mandate which consequently effects the Driver with almost a form of intimidation placed upon to perform their daily required task which results in a level of driver fatigue that is hard to explain with words. I personally have felt the impact of ELD with the feeling of being extremely over worked and rushed due to the ELD having the "stopwatch" effect placed on myself. Speaking for myself and other's within the trucking industry paper logs allowed the Driver to set their own pace which results in a more alert driver. It is hard for a driver to work long days with barely having enough time for breakfast, bathroom, or simply a nap due to the mental effects that the ELD places upon Driver's. It has been argued against for some time now that ELD here to stay. But the question that most all drivers have is to what cost? Possibly another 911 lives or maybe 885 lives. Technology has limitations in every industry and it should be limited within the trucking industry since it is primarily a hands-on, face to face job throughout every second of the day.


Safety for the Long Haul Inc. - Comments


Safety for the Long Haul Inc. appreciates the opportunity to suggest methodologies to help FMCSA and the greater large truck safety community better understand the causation of large truck crashes in the planned Large Truck Crash Causal Factors Study (LTCCFS). The attachment to this submission first reviews our qualifications to advise FMCSA on causation concepts and on effective methods for understanding. The submission attachment then presents 13 suggested guiding principles and specific practices for the study.



Safety for the Long Haul Inc. - Comments

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Safety for the Long Haul Inc. – Comments


Safety for the Long Haul Inc. appreciates the opportunity to suggest methodologies to help FMCSA and the greater large truck safety community better understand the causation of large truck crashes in the planned Large Truck Crash Causal Factors Study (LTCCFS). The attachment to this submission first reviews our qualifications to advise FMCSA on causation concepts and on effective methods for understanding. The submission attachment then presents 13 suggested guiding principles and specific practices for the study.



Safety for the Long Haul Inc. - Comments

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MJ Thorne - Comments


the study must be careful to clarify sources of information. there should be divisions between crashes for drivers on paper logs vs electronic logs, technology enhanced trucks equipped with things like automatic braking systems, crash avoidance systems, etc. vs older trucks that do not have such devices, and experience of the drivers. There should also be company driver statistics vs owner-operator statistics. Experience of the driver along with what driver personally has at stake (such as their own truck) are major factors.

In particular, notice needs to be paid to systems that are designed to deploy without the assistance of the driver. Automatic braking is an example of a system that may deploy because of a false reading of an obstruction. in an event where the system does hard breaking, will the condition of road surface be taken into consideration? Will the source of the hard breaking (person vs machine) be taken into consideration? on a snowy/icy surface could automatic breaking be the cause of a chain reaction multi vehicle accident? If you only look at the fact that there was hard breaking (without determining if it was the driver or the automated system) you will have skewed results. Also, there is concern regarding attempts to determine if the driver was fatigued. Will guesses be made, or will only instances of the driver being cited for fatigue be used?


Shawn Baker – Comments


(1) the ELD mandated logs people are having to drive faster to be able to get to places where it would safely be so they could stop because of the new ELD mandates

(2) When I started driving truck it was a rule and part of the regulations that anybody driving a commercial motor vehicle in the United States was required to be able to speak and read English a lot of people that are in this country cannot read or speak English so when they going to the scale House with the scale master can’t talk to them because they don’t know a different language other than what the scale master speaks they also The Colorado incident comes to mind.

Note; we are losing companies and drivers because of the ELD mandates and the tight rules and regulations regarding the hours of service me myself I still hold my CDL but I don’t drive truck anymore because of your rules and regulations because of your scrutiny. if only you guys have the guts to ask some OTR drivers what is going on instead of sitting back and trying to figure out things from your damn seat and desk.

Try to regulate the companies more and not the drivers there are companies out there like the one that I work for once upon a time and they still do it they still instruct drivers to illegally drive but yet you don’t go after them.

We as drivers cannot make a buck with you guys holding us down. your new ELD mandate was just a way for you to get rid of the small guys and keep the big companies I don’t call that a free country. I myself was going to buy my own truck until you came out with the ELD mandates.

And last but not least you guys really don’t want to hear what we have to say. Like the guy in Texas when you guys were down there looking for comments a driver had spoken up about people that don’t speak English driving truck In the USA and he was told to sit down yes, we all heard about it.


Phil Killerlain - Comments


The reason for most truck wrecks falls back to training You have so many new drivers on the roads today that where inadequately trained to begin with Since 2004 when the FMCSA and the court due to lawsuits from safety groups who had no concept of the dangers they were trying to force on trucking with the 14 hours of service rule ! You now have drivers on the roads that from day one of their trucking employment Started racing the 14 hour clock and honestly believe it's the way to do the job! Read some of their comments on social media Especially now with the ELDs! They start bragging about running 680 to 800 plus miles in a 24 hour period one even showed a picture of his ELD screen that showed 890 miles! So, if you really want to slow truck wrecks change the hours of service and make AOBRD legal to use drop the ELDs As the strict no changing the drive line is one of the biggest contributing factors to wrecks! Or make all company drivers pay be by the hour? But even by that you will still have drivers racing the clock to get as many of the drive hours possible during the 14 hour deal unless all 14 hours are paid! Then it will still take years to get rid of the drivers habits of clock racing you have created with INEPT rules and HOURS



Phil Killerlain - Comments

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Keith Miller – Comments


I responded to a bad truck company agitating me about my next possible trucking job being away from home. This was an email sent to me with a job offer for a Class A over the road truck driver that would be me if I accept. I did not accept this company for employment and felt responsible. Over the road truck drivers normally spend two weeks away from home and then take a break at home afterwards go back out and do it again. This is a full work schedule; truck drivers have home responsibilities the same as all other workers. Truck drivers need to be safe and fully engaged in the duties of the truck and shipping terminals while at work. A work schedule with less home time is not the right direction for the trucking industry. I'll give another lucrative example of trucker off time. The truck driver would be out for three weeks and then take three days home time then does it again. Even though the driver is not home as much there still a representation of the drivers home time responsibilities. This should be a limit to the amount of work a truck driver is allowed to do. Uniformity with all other workers is present with this style. We are all trying to be safe. Why this statement is important, I became alarmed when emailed this job opportunity over the expectations. I replied after considering contacting authority, "do not ever mail me again". This way my acceptance is put forth and I can plan how to list these communications. I was mailed again one day later asking me "why did you not ask me to remove you". This emailing is not right and I expect it to stop. I'm deleting the emails and leaving the only copies attached. The wrong expectation, no driver should be emailed or have to do is, stay away from home for twelve weeks and then do one week home time. This would be one thousand, one hundred seventy six work hours before an hour scheduled off. Calculated with fourteen work hours a day and ten hours rest. When actually the truck is under the drivers responsibility twenty four hours a day. To help visualize, shower and meals take two of the on duty hours or non-sleep hours.



Keith Miller - Exhibits

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Keith Miller - Exhibits

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Keith Miller - Exhibits 3

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Keith Miller - Exhibits 4

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David Rutledge - Comments


the problem with all of the big truck accidents and fatalities is not what everyone think it is, in every state around every major city there are many signs with attorneys saying if you are hit by a semi-truck call US and we are going to get you paid, some signs say that truck drivers are distracted drivers what I am saying is that there is so much attention directed at the big trucks that it says to the people in the cars that you are not the problem, the only problem is the distracted drivers are only the semi drivers and not the people driving their cars so the cars catch up to the semi-trucks and try to control them block them behind a vehicle then slow down to the exact same speed as the car in front of the semi then the vehicle in front of the semi applied their brakes causing the semi to either tailgate or rear end the car or every day I see people in cars get in front of semi-trucks then mash on their brakes and the truck tries to get away from the car then the car will accelerate to stop the semi from getting away from them and there are too many things to explain put cameras in the windshield and the hoods or the side mirrors of the truck you will see the people holding their phones up to their faces even police and state troopers and deputies holding their cell phone up to their faces with their knees holding their stirring wheel while both hands are holding their phones and texting I see this every single day put 3 cameras on the truck and you can see how people disrespect taunt and harass the semi-truck then the attorneys tell you that the semi drivers are distracted and negligent with their signs about how to get paid big money for people working two jobs this sounds like the deal of a lifetime


California Highway Patrol - Comments


Comments provided by the California Highway Patrol in response to the Request for Information: Large Truck Crash Causal Factors Study.


Daniel Blower - Comments



Andrew Baltrop - Comments



Mitta Anonymous - Comments


ELDs have caused truck accidents to increase. When road conditions are dangerous in the winter, a driver will push his limits in order to not lose his available driving hours. If there was more flexibility with available driver time and with the 14-hour limit, it would greatly increase how cautious a driver will behave.


ZF North America, Inc - Comments



Mike Chilton - Comments


The eld mandate has been a total failure in my opinion. T he mandatory mandate has caused the highways of America to be less safe by a exponential measure by putting undo pressure and anxiety on the truck drivers. We are always fighting the clock no matter the situation. It does not take into account for weather, traffic and other things out of our control. All you have to do is spend some time out on the road to see the way people drive threw construction zones and cities. Mostly the big carrier company drivers that go as fast as they can no matter the situation. This moronic law has made the roads much less safe than ever. There is no way you can stop the clock and if you want to get the load to its destination on time you are forced to drive when a little nap would be best. The driver is forced to go threw a city at peak traffic times when it would be better just to let the traffic clear out and then go on.
There are several factors that have led us to where we find ourselves today. Unfortunately most caused by the regulating authority.
First and foremost, electronic logging devices. By enacting this rule, you have given drivers permanent hand cuffs to wear. Instead of racing for miles as in the days before eld, now we find ourselves racing the clock, because shippers and receivers only care about appointments met. What they dont care about is what happens after you arrive. You can sit, usually without pay for several hours while waiting to load or unload. That eld clock is ticking the whole time. Which puts you behind for your next load....and so on. End result is speeding, driver fatigue, recklessness etc. And dont mistake it, the trucking companies do not care about drivers. We are nothing but an ass in a seat to them. Drivers get to the point that they just dont care either.
Next point; foreign drivers. Every American driver out there knows where these folks get their cdl from. If the govt doesn't, shame on you. These are the most reckless, inconsiderate group on our roads. The eastern European especially. They dont care about safety, or following laws. They call us stupid for entering state scales or weigh stations, They certainly dont. We've all seen the tailgating and putting cars on the side of the road. Unfortunately american drivers also realize that our fmcsa will do nothing about this, and thank you for destroying our safety reputation thru our illegal cdl holders.
Finally; training. That's the biggie! I went to work as a trainer for a mega carrier a while back, and was told that we "push" new trainees out in 3-5 weeks, and nobody failed. Sure, you can train a monkey to drive, everybody knows that. Can you teach him to make snap decisions that affect other's lives? Simple question, right? Can you teach him to say no to a dispatcher who pushes too much? Can you encourage him to stop and get rest when he gets tired no matter who says what? Training is every day. Safety is everyday. Common sense is everyday. Regulations dont make for better safety, the people behind the wheels do. And ask real truck drivers how to best regulate. Dont pertain to know this industry just because you have a college degree and your own parking space. ASK A PROFESSIONAL.
Illegal drivers
Common sense eld.
Educate the people
I am not sure that their is a way to study the time pressure that all drivers are under with the ELD's, but I do think that should be included in the new study. Also I think the Training for new drivers should also be part of the study or the amount of driving experience the driver of the commercial vehicle had in each case. I also think that you should take a hard look at any non commercial drivers involved. I think the public is under educated on how to drive around commercial vehicles and that needs to be looked at as part of all accidents involved in the study.

The Insurance Institute for Highway Safety (IIHS) welcomes the opportunity to comment on the Federal Motor Carrier Safety Administration's (FMCSA's) development of its Large Truck Crash Causal Factors Study (LTCCFS). IIHS supports FMCSA's decision to conduct this study and encourages FMCSA to develop specific research questions and hypotheses that will inform its decisions on study design.

IIHS encourages FMCSA to specify and prioritize its research questions and use those to guide study design, pursue a representative sample, consider oversampling certain crash situations worthy of further study, collect a control sample, and include extensive photographs for every crash. This study is an opportunity for FMCSA to increase knowledge and improve safety.

Please see the attached document for the full text of my comments.


Eric Teoh
Director of Statistical Services
Insurance Institute for Highway Safety


Marianne Karth - Comments


FMCSA Large Truck Crash Causal Factors Study (LTCCFS)
Recommendations from
a Mom on a Mission To Make Truck Crashes More SurvivablePlease conduct the following studies of truck underride in order to increase the ability to take informed and decisive actions to end this preventable cause of truck crash fatalities and injuries:There has been a dearth of information on the true number of underride deaths and injuries. This has led to flawed cost benefit analysis with the result that underride rulemaking has too often been deemed as not cost-effective. In order to strengthen support for making use of the underride protective devices which have been proven to prevent underride, please review truck crashes in which the involved passenger vehicle had multiple occupants. Analyze the severity of injuries for those who experienced underride/passenger compartment intrusion (PCI) vs those who did not. (Note: This is a high priority recommendation. I have not seen any studies of this nature, and it was a factor in my survival of a truck crash which killed my daughters.)

Ensure that underride is adequately included in the next edition of the MMUCC, this would include the VIN of the trailer or large truck involved in the crash. Identify with as much detail as possible the make/model/type/design/etc. of the truck and the underride equipment (if any). Differentiate between underride guards which meet the federal standard and those that are primarily for ease of loading or non-structural.

Please include in your upcoming Large Truck Crash Causal Factors Study (LTCCFS) an analysis of how many people have died due to side underride (and Passenger Compartment Intrusion on the sides of large trucks) in the fifty-one years since March 19, 1969. On that day, the Department of Transportation said that they "anticipated that the proposed [rear underride] Standard will be amended, after technical studies have been completed, to extend the requirement for underride protection to the sides of large vehicles."

Other countries, besides the United States, have a Front Underride/Override Protection standard. Please do a review of what FUP can do to mitigate truck crashes. Analyze how many fatalities might have been prevented in crashes where a large truck rear-ended a passenger vehicle and also in crashes where a large truck and a passenger vehicle collided head-on if FUP had been installed on the truck. Please determine how many lives might have been saved in the U.S. since Volvo Truck Corporation "introduced Front Underrun Protection Systems (FUPS) in 1996 IN OTHER COUNTRIES - which helps a truck recoil backwards in case of a head-on collision with a car." Volvo also applied for a FUP patent in September 2003. The Volvo FH has been a forerunner in safety. Not the least within passive safety, where Volvo Trucks was the first truck brand to offer airbag (1995) and also introduced Front Underrun Protection System (FUPS) in 1996, ten years before it became a legal requirement. The Volvo FH - the drivers' choice since a quarter of a century. - And this truck promises to keep changing the world of trucking .

Please review the formula which has been used to conduct a cost benefit analysis as a part of preliminary regulatory analysis for underride rulemaking. Provide this information to an Underride Protection Committee (composed of a variety of stakeholders, including underride victim families) so that they can assess and discuss the thoroughness of the formula. Obtain recommendations from this Committee about what additional components should be included in the underride CBA.

See attached file for links which provide additional supportive information.

RoadAware Safety Systems - Comments
There is nothing in the cab of a semi-truck to give the driver an early warning and an actual, calculated safe speed based their load, present road geometry and vehicle dynamics. Present, in-cab navigation and fleet management systems, as well as equipment designed to enhance safety, such as automatic emergency braking (AEB) and roll stability control (RSC) and video systems are reactive to situations, not proactive. If nothing tells them what speed to take a curve or to go down a slope they will go as fast as they 'feel' safe. Often, their 'feel' is wrong, resulting in a runaway or rollover crash. Presently, they have no information available to guide a change in behavior.
When a driver is given an advanced warning and a calculated safe speed to navigate hazardous road segments such as curves and slopes, they are shown to modify their driving behavior to reduce risk. We believe that with calculated tip over and stopping speeds, the risk of rollovers and runaways will be significantly reduced. Our work has shown that driver behavior can be modified when they are provided with a safe speed based on calculation of their specific situation.
Additional work is needed to collect more driver baseline behavior as it relates to high-use interchange curves in cities and steep slopes associated with mountain driving. Work to date shows that even experienced driver are driving seat-of-the-pants through these hazardous road segments because nothing in the cab provides a recommended safe speed based on the geometry of the feature and the vehicle dynamics (power unit, trailer configuration, load type and weight), the calculated tip over speed and the braking potential on a slope.

March 15, 2020

Jim Mullen, Acting Administrator
Federal Motor Carrier Safety Administration
1200 New Jersey Avenue SE
Washington, DC 20590-0001

RE: Docket Number FMCSA-2019-0277 - Request for Information Concerning Large Truck Crash Causal Factors Study

Dear Mr. Mullen:

On behalf of the American Academy of Sleep Medicine (AASM), I am contacting your office to submit comments on the Request for Information Concerning Large Truck Crash Causal Factors Study (LTCCFS) [Docket ID FMCSA-2019-0277]. The AASM is a professional society that represents a membership of 11,000 physicians, scientists, allied health professionals, and accredited sleep centers. The AASM is the leader in advancing sleep care and enhancing sleep health to improve lives.

Our responses to your questions are provided in the attached letter.

We are pleased that the FMCSA is choosing to study factors that contribute to FMCSA-reportable large truck crashes. As sleep physicians, we believe that sleep disorders, including insufficient sleep, circadian rhythm sleep-wake disorders, and OSA are major contributors to crashes in this group. Given that these disorders are identifiable, and effective treatments are available, we believe that estimating the degree of risk related to these factors is highly relevant for public safety. We have seen a tremendous growth in the prevalence of obesity since the first Large Truck Crash Causation Study (LTCCS), and we believe that your efforts are critical for reducing truck crashes related to fatigue and improving highway safety for all drivers.

We thank you for considering our comments and look forward to your response.

Indira Gurubhagavatula, MD, Chair, AASM Public Safety Committee


Secretary Chao, Deputy Administrator Mullen, Acting Administrator Owens,

There has been a dearth of information on the true number of underride deaths and injuries. This has led to flawed cost benefit analysis with the result that underride rulemaking has too often been deemed as not cost-effective. Opponents of this rulemaking suggest that crash avoidance technology to prevent crashes from happening would be a better use of funds.

In order to strengthen support for making use of the underride protective devices, which have been proven to prevent underride, we propose a study to review truck crashes in which the involved passenger vehicle had multiple occupants. The severity of injuries for those passengers who experienced underride and Passenger Compartment Intrusion (PCI) should be compared to those passengers who did not experience underride and PCI.

It is past time to appropriately address the deadly truck underride problem. Act decisively to get the attached underride research study underway as swiftly as possible. Make it a priority. Establish an Underride Protection Committee, with a diverse group of stakeholders, to be an essential part of developing and discussing the details of this research -- including use of digital technology to speed up the research process.

Make truck crashes more survivable.

In memory of AnnaLeah (Forever 17) and her sister Mary (Forever 13),

Marianne Karth
AnnaLeah & Mary for Truck Safety


Truck Research Services - Comments



Owner-Operator Independent Drivers Association - Comments


Owner-Operator Independent Drivers Association (OOIDA) re: Large Truck Crash Causal Factors Study.


American Trucking Associations, Inc. - Comments


The American Trucking Associations, Inc. submits these attached comments in response to DOT's Request for Information Concerning a Large Truck Crash Causal Factors Study.


Mecanica Scientific Services Corp. - Comments


Kindly refer to the attached correspondence.


Mecanica Scientific Services Corp. - Comments


Kindly refer to the attached correspondence.


Pamela Biddle - Comments


Thank you for the opportunity to submit public comments regarding this potential updated study.

Pamela Biddle


Truck Research Services - Comments


Farrel Krall is submitting attached file as a replacement for the file submitted on March 16, 2020. Reason being, the links in the original doc would not open. Please determine that all links on replacement file are opening correctly. Thank you. Sorry for the confusion on my part.