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Good morning. My name is Tilden Curl. I am from Olympia, Washington, and I have been a professional truck driver for over 20 years. I currently operate throughout seven western states, and I appreciate the opportunity to testify on behalf of the Owner-Operator Independent Drivers Association. OOIDA represents the small business truckers that are the majority of the US trucking industry. More than 90 percent of carriers own 20 trucks or less. Half of all trucking companies are one-truck operations. Small business truckers are committed to highway safety. For us, accidents have an adverse impact on our businesses and our livelihoods. OOIDA’s average member has a quarter century of experience and more than two million miles of accident free driving. I want to thank Administrator Ferro, who recently saw our commitment to safety and some of the challenges truckers face every day as she joined an OOIDA Board Member on a two-day ride-along from DC to St. Louis. As professional drivers, we need flexibility to balance countless demands. Loss of flexibility has an economic impact for small business

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truckers and over time, changes to HOS regulations have reduced that flexibility. Less flexibility makes it more difficult to stop for rest, avoid traffic, or keep a schedule after being delayed by a shipper or receiver. The recent HOS rulemaking, which was a result of a court settlement, was an opportunity to help truckers balance these countless demands. Unfortunately, the changes went in the opposite direction, adding new restrictions to the 34-hour restart, requiring an arbitrary 30-minute break, and retaining the unstoppable 14-hour duty clock. The impacts of these changes are borne out in a recent survey of OOIDA’s membership:

While only 3 percent said they felt less fatigued, 46 percent of respondents felt more fatigued after the changes;

79 percent have seen impacts in their ability to use the restart; 65 percent have seen lost income; and More than half have experienced reduced loads and mileage. My own experience has mirrored these responses, especially with the

two 1 AM to 5 AM periods during the restart. This often puts me in the

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middle of Seattle’s rush hour, and much like DC’s Beltway traffic, this means more time on the road and a greater risk of accidents. For these reasons, OOIDA supports H.R. 3413, Mr. Hanna and Mr. Rice’s legislation that will ensure a full examination of the 34-hour restart restrictions. As it is now, the restart restrictions could reduce my potential work week by as much as one day, possibly costing me as much as to four to five thousand dollars a month. While some would argue technology is the safety solution, OOIDA’s members see this as a false promise and a way to ignore larger issues. This rings true when accident data shows that carriers who depend on technology such as on-board recorders and speed limiters crash twice as frequently as carriers who use experienced and safe owner-operators. With this in mind, what should be done? FMCSA itself can act by returning flexibility to HOS, including allowing truckers to pause the duty clock with rest breaks. Trucking, government, and most importantly shippers and receivers, must address the detention issue. Professional truckers, while still

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considered unskilled labor, deserve to have their time fairly compensated. We must stop placing more rigid requirements on the driver, while allowing carriers and customers to make demands beyond the allowance of regulations and safety. FMCSA must act on entry-level driver training and driver trainer requirements as the foundation of a healthy safety program. Advancing this policy, first called for by Congress in 1991, is OOIDA’s top safety priority. Our comprehensive driver-training proposal forms the keystone of our Truckers for Safety agenda. You can learn more at truckersforsafety.com. In closing, bringing our complete supply chain in as partners to address the regulatory responsibilities of truckers is the right direction to take. Further, FMCSA should prioritize providing additional flexibility while addressing core needs like entry-level driver training. The wrong direction is to rely on further restrictions and unproven technology. Thank you for the opportunity to testify and for holding today’s hearing.