Below are select quotes from recent Hours of Service (HOS) comments filed with FMCSA by organizations that typically oppose industry-supported HOS changes. These are some of the organizations that might decide to challenge FMCSA’s changes in court if the agency finalizes some or all of its proposed HOS changes. These quotes communicate the positions of these organizations and appear to put FMCSA on notice.

• Road Safe America
  “Road Safe America implores the FMCSA to be led by the facts and figures. The first step requires the agency to…look at their own research as well as studies conducted by others on fatigue, sleep, and their effects on driving. The second step is to withdraw these proposed changes that will diminish truck safety.”
• The International Brotherhood of Teamsters
  “The proposed revision to the Hours of Service regulations…is an attempt to effectively “rollback” many of the regulatory improvements thus far and in our opinion will have a deleterious effect on the safety and health of our driver members and to the motoring public who share the road with other CMV truck drivers.”
• Advocates for Highway & Auto Safety
  “Fatal truck crashes continue to occur at an alarmingly high rate.”
  “Driver fatigue is a well-known safety problem within trucking…”
  “Given these realities, Advocates is staunchly opposed to the dangerous proposals…and the framing of them under the guise of ‘flexibility.’”
• The Truck Safety Coalition
  “We…remind the FMCSA that their statutory mission is to have ‘Safety as [its] Highest Priority.’ None of the proposed changes demonstrate a commitment to that mission because the Agency has failed to provide proof that any of the charges will actually improve safety.”
• Insurance Institute for Highway Safety - Highway Loss Data Institute
  “IIHS strongly cautions FMCSA against making such large changes, which relax already long workday limits, without sufficient regard for proven safety risks
  “…FMCSA should rely on the strongest form of evidence—rigorously conducted scientific studies—and not simply on experiential anecdotes, to make these decisions."

Two things are clear in these statements:

1. These organizations are adamantly opposed to loosening HOS rules.
2. Each believes their path to victory lies in FMCSA’s use of data to justify their proposed changes.

STC’s bet? Any final HOS changes will end up in court. If so, a key question will be whether FMCSA will have the research and data to win the day.