Trucking Advocate and Activist Allen Smith of TruthAboutTrucking.com : Articles Current News and Information for CDL Truck Drivers and Truck Driving Students…"Raising the Standards of the Trucking Industry"
Like the movie with the same name, is the perfect storm brewing for the U. S. trucking industry? With the possibility of more than a quarter of a million truck drivers facing termination from their driving careers from the CSA 2010 initiative, coupled with the talk of changing the current HOS rules, is there a a catastrophic event heading straight toward professional drivers and trucking companies alike?
The hours of service rule for truck drivers could be looking at losing two hours of driving time, along with doing away with the 34 hour restart rule. The ATA and company CEO’s fear that these two aspects combined will reduce productivity among drivers. ATA Chairman, Tommy Hodges stated that the CSA 2010 will be a “free agency for drivers.” He went on to say, “a driver that knows he’s got a good record, he knows how to abide by the rules, and he knows and understands his value to your company, (is) going to come in and say, ‘look at my score, you’re going to pay me 50 cents a mile or I’m going to go to XYZ,’ and he will.” He went on to comment that productivity loss could be as high as 18 percent if the changes are indeed made.
No doubt that losing two hours of driving time and the 34 hour restart will change the way trucking companies operate, but could not adding additional time for rest also increase productivity by eliminating much of the “pushing of drivers” to run further and harder? The industry sees the loss of revenue coming by not being able to push their drivers beyond their physical and mental limits in order to get the freight delivered and move on to the next load. Are the industry leaders more concerned with the loss of dollars than the safety of their drivers?
Truck drivers operated under the former set of HOS rules for years and did just fine.The new HOS rules, if they occur, will basically return nearly as they were before.Is the industry fearful of losing their ability to push their drivers’ work loads, or more afraid of the good, safe and professional drivers gaining more control over their own careers?
Hope Rivenburg, the widow of slain trucker Jason Rivenburg, along with Congressman Paul Tonko, AskTheTrucker, and everyone who has worked so diligently to get HR 2156 passed into law, has designated June 28th 2010, the official day for Jason’s Law – Bill HR 2156.
Jason’s Law, otherwise known as Bill H.R. 2156, was introduced on April 28th, 2009 and has been referred to the House Committee on Transportation and Infrastructure. The Bill, named after truck driver, Jason Rivenburg of Fultonham, NY, who was found shot to death in his truck, would implement a pilot program to establish safe truck parking facilities.
What this day of recognition means is that on, June 28th, 2010, we are calling for EVERYONE to call their Representatives and Senators, telling them that it is imperative for them to support HR 2156 in order that truck drivers can have the promise of safe and adequate parking. We need to flood the phone lines and “Get Er Done”
This is a Bill that has the Support of everyone. With all the many differences that exist among one another within the trucking industry, we are all in unanimous agreement that H.R. 2156 must be passed and become law.
Organizations in Support of H.R. 2156- “Jason’s Law”
OOIDA Owner-Operator Independent Drivers Association
Teamsters The International Brotherhood of Teamsters
It’s time to for us all to be determined and not depend on the next guy. Here is an article written by Todd Dills of OverDrive Magazine which explains why we must not be passive, but instead, the absolute vital importance of why we must all be proactive in this cause. We must all create a frame of mind within ourselves that says,
” If I make this call today, Jasons Law Will be passed”
Hope Rivenburg has made numerous trips to Washington in support of HR 2156, attempting to gather support and co-sponsors for the bill.
She does this for 2 reasons:
So that her husbands death will not be in vain
So that no other truck driver or their family will have to endure similar pain and loss
Truck driver fatigue is always being taunted as a major problem. The NTSB, the FMCSA and the American Trucking Association are all behind the implementation of a new bill that will require truck drivers to undergo testing for a medical condition known as sleep apnea.
Media reports are stating that about 30% of all truck drivers have sleep apnea. Furthermore, it has been reported that the condition affects between 6% to 12% of the adult male population.
Truth About Trucking “LIVE” talk radio discussed the real truth behind truck driver fatigue and the sleep apnea deception on Wednesday, May 19th, 2010.
We had the reports . . . we had the data . . . we had the numbers.
When one study did not provide the data that they were looking for, then they conducted more studies until the data met their agenda.
Sleep apnea is a serious medical condition that needs to be treated and the truck driver population needs to be made aware, but the real problem of truck driver fatigue lies with the lifestyle of the professional trucker and how the motor carriers contribute to this problem. (See our previous post: Motor Carriers Responsible for Truck Driver Fatigue).
Continually pushing the issue of sleep apnea as the major cause of driver fatigue is taking the focus off of the real problem : pushing drivers to their limit, disturbing drivers while they are trying to sleep, forced dispatch and so-forth. Sleep apnea needs to be taken seriously and those who have it should take steps in its treatment. But saying that 30% of truck drivers have this condition is just not the case, when independent studies have shown a regular percentile of around four percent.
Furthermore, if the studies conducted do not present the figures that you were hoping for, performing more studies until you reach the wanted figures only minimize the findings.
Driver Fatigue is no stranger to the trucking industry. The FMCSA has performed studies in the past in order to better understand what causes driver fatigue and how to reduce it by correcting the major contributing sources.
Back in 1996, a 7 year study, The Commercial Motor Vehicle Driver Fatigue and Alertness Study (DFAS), was published by the FMCSA evaluating driver fatigue. At the time, Hours of Service was under review and many contributors to driver fatigue were considered. The cost of this study was 4.45 million dollars. This is the Introductions written by the FMSCA concerning this study.
“The Driver Fatigue and Alertness Study (DFAS) was the largest and most comprehensive over-the-road study ever conducted on driver fatigue and alertness in North America. It provides extensive information on the alertness, driving performance, and physiological and subjective states of commercial motor vehicle (CMV) drivers as they perform real-life, revenue-generating trips. This Executive Summary overviews the objectives, methods, principal findings, and safety implications of this landmark 7-year study.”
During this comprehensive study this is what was concluded in regards to the concerns of Sleep Apnea:
“Although this study was not designed to determine a population prevalence, analysis of subject sleep revealed that two of the 80 drivers (2.5%) had clinically-diagnosable apnea, a sleep disorder characterized by breathing cessations. The driving performance of these two individuals was not statistically different from that of other comparable drivers in the study.”
The Study concludes with:
ASSESSMENT OF RESULTS FOR FATIGUE MANAGEMENT:
“There is no quick fix and no single solution to the fatigue problem. Sleep is the principal countermeasure to fatigue…. Partnerships among government, industry, drivers, safety groups, the scientific community, and shippers are needed for effective solutions to the commercial motor vehicle driver fatigue problem.”
In an article by Misty Bell of eTrucker , Mary Gunnels, director of the Federal Motor Carrier Safety Administration Medical Programs made the statement “We know that fatigue is a problem,” she said, “and we know that sleep apnea is a major contributor to fatigue.”
Do we really know that sleep apnea is the major contributor? Where is the data?
In that same article, Martin R. Walker, chief, FMCSA Research Division, pointed to the prevalence of sleep apnea in commercial truck drivers, noting that a study published in 2002 found that almost a third of CMV drivers have mild to severe obstructive sleep apnea. This study, along with a later study, found that older age and higher body mass index are two factors commonly linked with sleep apnea.
30% of drivers have mild to severe sleep apnea? How could that be? The 7 year study performed by the FMCSA didn’t come close to those figures?
I decided to look at the research, and this is what I came up with:
It appears that these figures and statements made during the Sleep Apnea & Trucking Conference of May 12, 2010 were possibly based on this study. At least this is the only study I could find actual data on.
The study was conducted by the University of Pennsylvania Sleep Apnea Study. The research was conducted during 1996 to1998. Sleep apnea is a condition in which a narrowing or closure of the upper airway during sleep causes repeated sleep disturbances, and possible complete awakenings, leading to poor sleep quality and excessive daytime sleepiness. This study was completed to assess the risks of commercial motor vehicle (CMV) crashes due to the presence of sleep apnea among truck drivers.
Basically, this study involved 1391 drivers. The drivers were asked a series of questions, including their height and weight, sleep patterns, medical history, snoring, etc. This was used as a screening process to determine which drivers were most likely to have sleep apnea. Out of the 1391 drivers, 406 were selected as a result of their questionnaire, to proceed with the overnight laboratory study in order to determine how many of them were accurately predicted to have sleep apnea.
The results were as follows:
64% or 260 of the 406 flagged for most likely to have sleep apnea had no sleep apnea.
21.2% or 86 of the 406 flagged for most likely to have sleep apnea had mild sleep apnea. 7.9% or32of the 406 flagged for most likely to have sleep apnea had moderated sleep apnea.
6.9% or 28 of the 406 flagged for most likely to have sleep apnea had severe sleep apnea.
Now, the above percentages and figures are for the 406 flagged drivers. When you perform the calculations based on the group study of ALL 1391 Drivers, here are the results ( the calculation required to accurately represent and determine % of ALL drivers):
2.0% or 28 of total 1391 drivers had severe sleep apnea ( matches the 1st study by FMCSA- DFAS) 2.3% or 32 of total 1391 drivers had moderate sleep apnea 6.2% or 86 of total 1391 drivers had mild sleep apnea.
This would mean that only 4.3% of drivers have moderate to severe sleep apnea. If you include mild sleep apnea, the % jumps to 10.5%
The following statement in the report however is the most revealing of all:
“The results of the study showed that the prevalence rates of sleep apnea among commercial truckdrivers are similar to sleep apnea rates found in other general populations.” The study also revealed that the prevalence of sleep apnea depends on the relationship between two major factors – age and degree of obesity as measured by body mass index (BMI) – with the prevalence of sleep apnea increasing with increasing age and BMI. Another meaningful study finding showed that the prevalence of sleep apnea depends on the average duration of sleep over consecutive nights at home. Short sleep duration, six hours or less per night, results in an increase in the prevalence of sleep apnea.”
Here’s that last statement again which has not been mentioned by the authorities and experts as a major source of sleep apnea,” Short sleep duration, six hours or less per night, results in an increase in the prevalence of sleep apnea.”
When you consider that the average OTR truck driver gets 5.2 hours sleep/night, then you have to wonder if it is the trucking industry lifestyle, behavior, and rules which are major causes for driver fatigue and also for creating/inducing “driver sleep apnea.”
The original hypothesis tested was the following: “A driver diagnosed with sleep apnea is more likely to be involved in a motor vehicle crash than a driver with no history or symptoms of sleep apnea, after controlling for differences in the other predictor variables included in the model.“
Finally, the study concluded to say, “No association was found between sleep apnea presence or severity and multiple crashes. This suggests that the commercial drivers in this study who were diagnosed with sleep apnea were not at increased risk for having more than one crash over the 14 year period prior to and following diagnosis…. Furthermore, there was no evidence from the data used in this study to suggest that crash risk is impacted before and after drivers are diagnosed with sleep apnea.”
There are many reasons for Driver Fatigue, and despite what many would like you to believe, lack of available sleep is the major cause. Sleep Apnea appears to represent a much smaller percentage than what is being stated. The data strongly suggests this.
Although sleep apnea is a real condition, it represents a much smaller percent of the driver population than the FMCSA and the ATA are suggesting. To screen a driver by height and weight (BMI), and neck size ( 17 or greater) is not only discriminatory, but is ludicrous. To force drivers to pay for the testing based on such information is simply wrong and unjust. A serious look at other reasons for driver fatigue should be investigated.
On the other side of that coin, if you do believe you may have sleep apnea, then you should by all means be tested and start the treatment.
The FMCSA needs to create laws, ensuring that drivers are not sleep deprived rather that associate driver fatigue on the hype of sleep apnea. It appears this is just a way to take the attention off of the real and valid reasons that drivers are fatigued, thus relieving the responsibility from carriers, shippers, and receivers who are all a part of depriving drivers from the rest they need. It’s also a way to deviate attention from the present HOS rules which need to be modified in order to aid in better and more rest for drivers.
Creating a sleep apnea testing program will be a BIG money maker for many as well as one more excuse to eliminate “undesirable” drivers from the industry.
When it comes to truck drivers not operating while tired, the responsibility is a two-way street. The driver must have the full authority to be able to call the shots when it is time for him or her to shut down due to fatigue. The motor carrier must adhere to the professional drivers’ request, without any repercussion from retaliation measures, such as dispatch forcing them to sit for three days or giving them low mileage and poor paying loads. When a truck driver is involved in an accident, particularly one that results in fatalities, it is major headline news bringing the spotlight on the driver and the cause often being fatigue. The spotlight needs to be more on the trucking company and questions asked as to why the driver was operating under such conditions.
It’s time we stop dancing around the facts of why these terrible incidents occur. Nearly every trucker I know will explain to dispatch that they are too tired to pull a load that they have just been given. We all know that many dispatchers will whine and plead with the driver that the “load has to get there” and they are the only driver available at that time and place. If the driver continues his or her stance on being too tired, dispatch will very often turn to the retaliation mode and shut the driver down by making them sit for days incurring no income, provide them with poor paying loads or at worse, find a way to dismiss the driver from their employment.
Professional truck drivers will often find themselves in a position where they must determine whether or not to make the forced run or risk losing the job and their means of support for their families. This scenario has been going on within the long-haul trucking industry since I can remember, and yet, with all the talk about driver and public safety from the FMCSA, the ATA and every other authoritative figure, no enforcement regulation has ever been designed or even addressed in regards to the responsibility of the motor carrier for bringing an end to this forced dispatching and retaliation against drivers who are only doing what they should do legally . . . if truck drivers feel they are too tired to run a load, they should have the right to say “No” and be allowed to rest without the fear of retaliation. I have known many drivers who went ahead and took the load, ended up in an accident due to fatigue, and when they made contact with dispatch again, the dispatcher responded with, “Well, you shouldn’t have taken the load if you were too tired.”
Motor carriers can get away with this, simply because nothing is ever recorded or written down as to what conversation between driver and dispatcher went down. Even with discussion between driver and dispatcher on such equipment as Qualcomm, etc., seldom does the driver have full access to the records. The fault, in OTR truck driving, will always come back on the driver. The dispatcher, load coordinator, dispatch supervisor or any company authority figure will never have the character or moral ethics to admit that the wrong-doing came from them . . . it is always the fault of the driver. Many times, they would rather risk endangering the life of the truck driver and the general public, all for the sake of getting the load picked up and delivered on time.
The FMCSA and the ATA need to step up and address this problem that many trucking companies have in regards to forcing a driver to continue running, even when the driver has expressed, within his or her legal rights, that they are too tired to drive and they need to get sleep and rest. It’s all about safety, right? Yesterday, the FMCSA extended the hours of service rule for truck drivers working on the Deepwater Horizon Oil Spill in the Gulf of Mexico. Although situations such as this is a good way for drivers to make some much needed extra income, who would be held responsible if one of the drivers’ fell asleep at the wheel? The FMCSA? The ATA? The trucking company? No, I can guarantee you that it would be the truck driver.
The above image is from Houston, Texas where a driver fell asleep at the wheel, careening off the overpass. Why was the driver so tired that he or she fell asleep? Are there not regulations for truck drivers requiring them to be given the opportunity for rest? Of course there are, but these Federal Regulations mean nothing when the driver is faced with forced, retaliation measures from the motor carriers.
It appears to me that safety is the key, only when it mostly benefits the trucking companies and those trucking Associations and Organizations who have the power and political contacts to bring an end to this pushing of drivers who are at the collapsing edge of fatigue.
Union or non-union? That is the question many truck drivers across America have debated for years. Truck drivers face long hours, low pay, disrespect and continual abuse by trucking companies which come in the form of taking advantage of CDL students and new drivers as a means of cheap labor. Couple this with the on-going abuse of the truck driver DAC Report and the illegal lease agreements between driver and the trucking company lease-purchase programs, professional truckers seem to take it from all sides. Recently, I received an email from a recruiter of a major trucking company. Here is a small part of the message:
“I am a recruiter for a major carrier and have been for some time. Though it is never discussed, I’ve been there long enough to understand how it all works . It’s frustrating watching drivers be treated as an expendable resource as well as purposefully being paid an unlivable wage in order to createturnover. I’d like to be part of the solution to the problem rather than the instrument of the companies who cause the problem.”
For five years now, I have been publicly speaking and writing about the abuse of truck drivers, purposefully being done by the trucking companies and the “leaders” of this industry.I have always maintained that the trucking companies, the dispatchers, the recruiters and the trucking organizations all know too well that everything I have disclosed through the years is accurate. The above email from a veteran trucking company recruiter is verification. Furthermore, this is not the first message I’ve received from recruiters and dispatchers within the industry . . . only the first that I have shared publicly.
I never expected to be well received by trucking organizations and the so-called organizations standing up for drivers . . . but drivers can expect that Truth About Trucking, LLC will continue to fight to “raise the standards of the trucking industry.” As more dispatchers and recruiters who possess a greater deal of character than their peers, continue to come forward to confirm the truth that we first exposed on a public forum . . . drivers will see a change for the better. They must first understand that any change for the professional drivers will only come about through the works of the drivers themselves.
If trucking or driver organizations sincerely cared about their drivers, there would be no DAC abuse . . . there would be no lease purchase program designed for the driver to fail . . . there would be no CDL graduate paying $5000 for a license and sitting at home a year later without a driving job . . . there would be no cheap labor pool of new truck drivers earning .19 cents per mile . . . and there would be no constant, self-made turning over of drivers by the trucking companies. It is no wonder why so many thousands of drivers are in favor of unionizing the trucking industry. If trucking companies only continue to abuse the professional truck driver, CDL student and newcomer to the industry, who is left to fight for themselves? It will have to be the driver. Once again, all eyes are on the Employee Free Choice Act.
The Employee Free Choice Act would allow the truck drivers, not the trucking company, to choose whether and how they want to form a union. Many drivers have their eye on this legislation and so does the ATA and trucking companies across America. In March of 2009, I had John Wojcik, the editor of People’s Weekly World Labor as a guest on the Truth About Trucking “LIVE” talk radio program. I could see this issue coming and it is now breaking the horizon. The ATA and trucking companies are preparing for the battle.
Personally, I can see the pros and cons of a union. Having been an owner of a trucking company, I can understand the concerns from a business viewpoint. However, we are not talking about any business . . . we are talking about the trucking industry. More specifically, we are discussing the long-haul trucking industry. In an industry that has been described by professional, veteran drivers as the “most corrupt” industry they have ever seen . . . is a union the only answer to fixing the problem?
Truck drivers who are for organizing a union within their trucking companies, believe it is the only way to receive the respect and pay they deserve. Apparently, the American Trucking Association believes other wise. The ATA has added a new “business solutions” publication to help trucking companies prepare for the potential passage of the Employee Free Choice Act. In other words, it is a publication to assist trucking fleets in understanding how they can fight back against those truck drivers demanding equal rights, pay and benefits.
Organizations and trucking companies fighting against drivers, keeping them right where they want them to be. Whether you are for a union or against is not the issue. It appears the giant trucking organizations are against truck drivers even having the right to choose. This employee right could very well make the trucking companies abandon the abuse and actually give truckers the respect and lifestyle they deserve.
Will Hope Rivenburg and Family be at GATS? With a little help from…….. OOIDA or the ATA
The families of Murdered Truck Driver Jason Rivenburg are continuing their campaign for “Jason’s Law”, H.R.2156, which will implement a pilot program to address shortages in safe parking for commercial motor vehicles on our National Highway System. It is necessary that we continue to collect as many signatures on the petition as possible in order to ensure the passing of the bill. Jason’s Law will create the 6 year Pilot Program in the amount of 120 million dollars in grants over a 5 year period.The legislation allows the Secretary of Transportation, in cooperation with appropriate State, regional, and local governments, to allocate funds to improve rest areas that serve the National Highway System.
Whenever I speak to Hope Rivenburg ( Jason’s Widow), gratitude just pours out of her. It’s quite humbling to speak to someone who has gone through so much, and yet so much of her words are in appreciation of others. She appreciates all the websites and blogs who have helped in the support of “Jason’s Law”, no matter how small or large they are, all the individuals who have expressed their most sincere condolences, and everyone who has signed the petition.
Along with the many individuals, trucking blogs and websites such as this one, there are 2 major organizations who are supporting Jason’s Law… OOIDA and The ATA.
During my conversations with Hope, she has expressed that she is also very grateful for the support of both The ATA and OOIDA . She said that OOIDA wished her the very best in all her endeavors when she had first contacted them about the proposed bill . Hope said that it wasn’t too long after though, when Congressman Paul Tonko (D-NY) released the draft of the bill “Jason’s Law” or H.R. 2156, they came to bat and supported the family and the bill through magazine postings and calls to action.
Hope and her family initially met with Congressman Tonko on March 14th, 2 days after Jason’s funeral, in a coffee shop in New York State, to discuss the need of the bill. Since that first meeting, Hope and her family members have worked tirelessly in order to make sure that this Law passes and that another family does not have to endure the same kind of tragedy or loss. You can read the family Journal which gives an account of the struggles and progress which they share on their Blog
On April 28th Congressman Paul Tonko introduced legislation H.R. 2156 in the House titled “Jason’s Law,” which would implement the pilot program to address shortages in safe parking. I think Paul Tonko’s name is engraved on the hearts of Jason Rivenburgs family, as well as many others who are grateful for his initiative in introducing “Jason’s Law.”
OOIDA Executive Vice President Todd Spencer said Tonko’s bill is a “good one” and urges members to call their representatives and educate them about how this bill will help provide safe parking for truckers. “We need to pursue whatever is possible to expand the amount of parking in areas where it’s so desperately needed,” he said. Read the entire post here.
Shortly after, the ATA quickly jumped on board and strongly supported HR 2156 and S971. In an article posted May of this year in FleetOwner Magazine, “Jason’s Law: ATA pushes for quick passage of truck-parking measure” President and CEO Bill Graves stated, “The parking shortage for commercial motor vehicles comprises the safety of drivers out on the road and requires a comprehensive solution involving all interested parties.”
This is a time when it is necessary that we all stand together ( as we are). Drivers, Trucking Blogs and Websites, OOIDA, the ATA and everyone else who is concerned about the safety of drivers’ lives out on the road and the desire to see” Jason’s Law” a reality( not a dream) are in unison together.
This August The Rivenburg and Hardendorf family members are hoping to attend The Great American Trucking Show ( GATS) in Dallas, TX. It is their desire so set up a booth and run their campaign, to reach so many thousands more about “Jason’s Law”, providing their many pamphlets, T-shirts, bracelets, etc….educating people about the crucial need and vital importance of this legislation.
As you can imagine, cost of the trip for the family members and the added cost of a booth at GATS, can be quite expensive.
I asked Hope Rivenburg if she would accept sponsorship from either The ATA or OOIDA for their campaign at GATS. She was thrilled and deeply moved at the thought of a sponsorship.
It is at this time we would like to make our plea for Sponsorship to both the ATA and OOIDA for the Rivenburg and Hardendorf family members. Please reach out and help them, as they have endured so much, and yet remain dedicated and loyal to the cause of their passing loved one and his fellow brother and sister truck drivers. We know how important this bill is to you, imagine how much more important it is to Jason’s family. Their presence at GATS will surely impress and imprint the hearts of thousands more.
ATA and OOIDA: Please contact Hope Rivenburg for your sponsorship. God Bless You email at : h_rivenburg@jhlrivenburg.com
We thank you all for all that you have done, continue to do, and will do, in order to ensure that “Jason’s Law” becomes a reality and that Jason Rivenburg’s death was not in vain.
Special thanks for my friends who inspire me to be a better person and to fight for the rights and betterment of others:
Desiree, Damian, Fred, JB, Daniel, and all my twitter friends!
Timothy Hardendorf, Jason Rivenburg’s uncle, appeared on trucking talk radio: Truth About Trucking “LIVE” sharing his family’s quest in helping to provide safe truck parking for all truckers, through Jason’s Law, H.R. 2156. The bill, now sits in Committee and the show largely dealt with the aspect that now is the time to act.
Mr. Hardendorf shared the family’s sincere thanks for all of the support that truckers and citizens alike, have expressed for the passage of Jason’s Law. Greatly supported by truck drivers and organizations such as the ATA and OOIDA, Mr. Hardendorf stressed that the bill is still just in the first phase and we all must continue to let our voices be heard and to advise our representatives and senators that we fully support H.R. 2156.
Please take a few minutes out of your day and make a phone call to your state representative and senator and let them know that you want their support for bill S.971 – Mr. Hardendorf also pointed out that just by dropping a post card in the mail with the words, “I support Jason’s Law” written on the front, will help bring about this much needed victory.
Don’t know who your State Representatives are? Find out Here:
Special thanks to Timothy Hardendorf for coming on the show at such short notice. At the end of the show I was calling him Mr. Hardenburg! focusing so much on the Rivenburg name, but I’m sure he’ll excuse me for that. Important bill . . . let’s do what we can to help bring about safe truck parking . . . lets contact our state representatives and senators and let them know that we support Jason’s Law.
: ata, change, CSA 2010, hos, hours of service, trucking
