Because the current hours-of-service regulations are flawed in the first place, OOIDA is telling the Federal Motor Carrier Safety Administration (FMCSA) that spending time and money to record, collect, check and store the driver's daily record of duty information is a waste of money and resources.

"It is a given that fatigue can, and in some cases does, cause crashes," says the association. "Collecting data derived from the fundamentally flawed hours-of-service regulations, however, is a high-priced exercise in futility."

"Not only that, if you attempt to maximize your allowable on-duty time under the current hours-of-service regulations, you will experience fatigue," says OOIDA Director of Regulatory Affairs, Rick Craig, "Because the rules impose an 18 hour work/rest cycle."

Ditto for enforcement of the present HOS regulations, says OOIDA, which can cause severe delays in drivers' schedules and place them at great risk of being fined, placed out-of-service and/or losing their jobs.

"In addition to being useless information, it's a huge burden on the industry," says Craig, "And the hourly burden is grossly underestimated by FMCSA. If you put a pencil to FMCSA's number, it comes out to less than two minutes per log sheet for drivers and motor carriers to comply with the logkeeping requirements. Our estimates, as reported by experienced OOIDA members, far exceed that. We figure the dollar cost to the industry easily exceeds $10 billion annually."

The FMCSA requested comments regarding the renewed approval of an information collection contained in a driver's paper record of duty status and in an automatic on-board recording device. OOIDA submitted written comments on July 20, examining the time and cost burden of the paperwork and voicing constitutional concerns with electronic on-board recorders.

To read OOIDA's comments in .PDF format, click here.