How Will the Hours of Service Changes Impact You?

Hours of Service (HOS) changes announced in December 2011 are scheduled to go into effect on July 1, 2013. As this date gets closer, here is a summary of the impending changes:

- Within the 34 hour restart, a driver will only be able to use the restart once a week.

- Similarly, the 34 hour restart will need to include two 1 a.m. to 5 a.m. time periods.

There are two court cases that have a small chance of delaying the implementation of the HOS changes, but FMCSA has indicated they would like to see these changes occur on schedule.

It is important to note that there will be no change to the number of daily or weekly hours of available driving time. The daily limit will remain at 11 hours of consecutive driving time per day.

Attached is a link to the summary of changes directly from the FMCSA website.

Some changes to the HOS rules took place already in February 2012. This includes a change to allow some time spent resting in a parked CMV to count as off duty time.

We have found that most customers are looking for a simple answer to how this will impact their transportation network. How will this effect rates? Will single day transit time be reduced? The reality is that there is not a one-size-fits-all-supply-chains answer. Since on the road drive time remains the same, individual load by load transit times could be unchanged.

It is clear that the potential impacts could be relatively narrow. For example, repetitive deliveries and pickups that occur daily between 1 a.m. and 5 a.m. are more likely to be disrupted than shipments that occur during daylight business hours.

Beyond that, calculating HOS impacts on irregular lanes will remain extremely difficult to predict, since each load, driver, and their current HOS status is unique and ultimately the responsibility of the driver to monitor and communicate to the shipper or third party provider.

The change in HOS is an opportunity for customers to review how their own facilities are performing as it relates to being flexible with appointment schedules and actively trying to reduce or eliminate unexpected and unscheduled delays and detention. It is always industry best practice to efficiently load and unload carriers.

Any potential change in overall capacity from HOS changes could get drowned out by what happens in the overall economy and seasonality. Looking back a year from now, it may be hard to separate which changes to the market were a result of HOS changes and which could be attributed to the overall economy and market forces of the marketplace.

If you are unfamiliar with the current HOS rules, attached is a link to the current HOS guide from FMCSA.

We encourage you to read this in order to better understand the process and complexity that drivers currently face and will continue to face as it relates to HOS.

About the Author - Mark Walker, Senior Vice President, C.H. Robinson