The US Poultry & Egg Association, National Chicken Council, and National Turkey Federation have submitted comments to the Department of Transportation opposing the Federal Motor Carrier Safety Administration's proposed changes to driver hours of service rules published in the Federal Register on December 29, 2010.
The comments were prepared by the Joint Poultry Industry Safety & Health Council, which is made up of members from US Poultry & Egg Association, National Chicken Council and National Turkey Federation. Collectively, the three organisations represent companies that produce 95% of the nation's poultry products and employ hundreds of thousands of workers.
The regulations proposed by FMCSA would further restrict the time truck drivers may drive and be on duty. If implemented, the regulations would have a substantial, negative impact on productivity and the economy. Our members operate as private carriers and would need to put additional trucks and drivers on the road to deliver the same amount of product. This would add to final product costs and increase congestion on the nation's already clogged highways; potentially doing so with less experienced drivers, and thereby increasing the risks to highway safety.
FMCSA's proposal seems to ignore the simple fact that the American Trucking Association reports trucking's safety performance has improved at an unprecedented rate while operating under the current hours of service regulations that became effective in 2004. Both the number and rate of fatal and injury accidents involving large trucks have declined by more than one-third and are now at their lowest levels in recorded history. The remarkable reduction in the number of truck-involved fatal and injury crashes occurred even as truck mileage increased by almost 10 billion miles. Clearly the current hours of service regulations are effective.
The poultry and egg industry operates 24 hours per day. The proposed revision to the “restart” provision, requiring two consecutive midnight to 6 a.m. off duty periods to begin a new work week for hours of service calculation, is particularly troubling as a result. Many of our drivers normally work evening or night shifts and are accustomed to resting during the day. Requiring two consecutive nights of sleep would disrupt drivers' circadian cycles and may actually lead to increased driver fatigue. Depending upon the individual driver's schedule, the restart period may actually be as much as 53 hours. This extended restart requirement could significantly reduce driver pay, as there will be reduced wage earning time each week.
In-depth details regarding the comments can be viewed on US Poultry & Egg Association's website, www.poultryegg.org/positionpapers.