Emergency Relief

Hurricane Laura has been upgraded to a category 4 storm and expects an unsurvivable storm surge for parts of Louisiana and Texas. In response to this, our industry as always lines up hundreds of buses to take people to safety. The FMCSA has relaxed nearly all regulations to assist in this effort.

According to REGIONAL EMERGENCY DECLARATION UNDER 49 CFR § 390.23 No. 2020-004 you are allowed when directly involved with relief efforts in Alabama, Mississippi, Louisiana, and Texas are allowed to operate without restraint to HOS, most driver qualification items such as medical cards, and should even get a break on most mechanical issues during roadside inspections.

This relaxation of FMCSA regulations is only applicable to the time directly going from your terminal to the evacuation area while staging and working in relief efforts, and the empty trip back to your terminal at witch time all relaxation of regulations is over. Please be safe out there and remind your drivers that they should never drive tired.

Read the entire declaration here: https://www.fmcsa.dot.gov/emergency/ssc-wsc-regional-emergency-declaration-2020-004-hurricanes-tropical-storms-laura-and

DOT consulting

Short-Haul Exception Expanded by FMCSA

View this article on ChauffeurDriven.com


Summary

FMCSA posted a new rule yesterday (5/14/2020) that will take affect in about four months. The new rule contains 4 substantial changes to hours of service.

  • Short-haul exception is now 150 air-miles or 14 hours start to finish
    (previously 100 air-miles and 12 hours, except Alaska)
  • Adverse driving window (on duty time) is extended by 2 hours
  • 30 minute break (property carriers) is now only required after 8 driving hours (instead of on-duty) and can be taken as on-duty time
  • Sleeper berth exception now allows 2 breaks totaling at least 10 hours, given at least 7 hours is spent in the berth (previous 8).
RuleExisting RuleNew Rule
Short-Haul12 hours, 100 Air-Miles14 Hours, 150 Air-Miles
Adverse DrivingAdds 2 Hours to Driving Time OnlyAdds 2 Hours to Driving or On Duty Time
30-Minute breakMust be Sleeper Berth or Off-DutyCan also be On-Duty
Sleeper Berth8 Hours Consecutive Required7 Hours Consecutive Required

Short-Haul Exception

Under 395.1(e)(1) If a driver operates within a 100 air-mile radius of base and also starts and ends at the same within 12 hours, they do not require a traditional log.

Hours of service are still required, but only need the start time, end time, and total hours worked each day.

If you meet the requirements, consider using a form like this one instead of driver logs.

Please note, this form has been updated for the new regulation that is not yet effective.

Driver’s Time Record V2.3

Why this is important:

  • With the expansion to 14 hours and 150 air-miles, even more local limo drivers qualify for the short-haul exception
  • If a driver qualifies for the short-haul exception 22 out of every 30 days, they do not need ELDs.

Again, very few local operators will need ELDs. This not only saves money, but also lowers the administrative burden of properly managing ELD systems and/or paper logs.

Adverse Driving Conditions

Adverse driving conditions are defined under 395.2 as snow, sleet, fog, other adverse weather conditions, a highway covered with snow or ice, or unusual road and traffic conditions, none of which were apparent on the basis of information known to the person dispatching the run at the time it was begun.

The previous rule allowed drivers to exceed the maximum driving hours by 2 full hours in order to complete a run, or reach a place of safety or security if adverse driving conditions caused the delay.

The previous regulation did not extend the on-duty hours so a driver near the end of their shift was unable to use the adverse driving condition exception. The new rule corrects this and allows both on-duty and driving time to extend by two total hours. It also expands to include the driver’s knowledge of road conditions.

30 Minute Break

Under 395.3, property carrying drivers who do not qualify for the short-haul exception must take a 30 minute break at least once before exceeding 8 driving hours.

Under the previous rule this break must be off-duty or sleeper-berth time. The new rule expands to allow on-duty time to count as the required break. It should also be noted that more drivers will now qualify for the short-haul exception listed above.

Sleeper Berth Exception

A sleeper berth is defined under 395.2 and is generally found on over-the-road trucks. Sleeper Berths may be used in lieu of traditional off-duty time if the requirements of the exception are met. There can be found in 395.1(g).

One of these exceptions previously allowed a combination of at least 8 consecutive hours in the sleeper berth and up to 2 hours as a passenger (10 hours total) to start a new work shift.

The new rule modifies this to only require at least 7 consecutive hours in the sleeper berth, as long as the total hours in sleeper-berth and passenger time is still at least 10 hours.

Full Text

Review the full text of the new rule here.

Association Support

On a related note, the National Limousine Association (NLA) and the American Bus Association are cited in the final rule in support of the short haul exception extension.

Consider joining one or both as they fight to help our industry!

Camera Integration

Limo & Bus Compliance ELDs Now Integrated with Translogic Tech Camera Systems
Month to Month ELD and Camera Solutions

We are proud to announce that the full integration between LimoLogs and Translogic Tech has been completed and units are available for order.  Both of our companies specialize in safety and technology solutions for passenger carriers with a focus on top-level customer service.

“This was a natural fit for us,” says Joe Guinn of Limo & Bus Compliance.  “We believe that long-term contracts allow for poor customer service and inferior products.  Ray has been the go-to solution for top tier cameras with reasonable rates and month-to-month contracts.”

“We were excited to integrate with Limo & Bus Compliance because they share our vision of a safer, more integrated industry,” says Ray Gavino of Translogic Tech.  “We’ve been providing cameras for about 15 years, so it was only natural that we try to find a partner that would give our customers access to fully integrated ELDs.”

The new fully integrated units are capable of operating multiple cameras, integrated WiFi routers, door sensors and more.  All agreements are month-to-month and are incorporated into LimoLogs, an industry designed compliance and fleet management system.

Limo & Bus Compliance is an approved ELD vendor with the Federal Motor Carrier Safety Administration.

About Translogic Tech:  Translogic Tech is owned and operated by Ray Gavino and Devo Bavishi, two veterans of the transportation industry.  Translogic has been providing their propriety camera solution to passenger carriers for over fifteen years, with thousands of units deployed nationwide.

About Limo & Bus Compliance:  Limo and Bus Compliance is owned and operated by Joe Guinn and Chris Przybylski.  Joe and Chris combined their experience as operators and their experience as DOT Consultants with over 160 successful audits to offer the only fleet and compliance software specifically created for the limousine and bus industry.

Joe Guinn
Limo & Bus Compliance
(971) 236-8287
[email protected]
lbcfleet.com


Ray Gavino
Translogic Tech
(866) 959-3226
[email protected]
translogictech.com

Camera Announcement

FMCSA Time clock change proposed 2 additional hours

FMCSA Proposes Changes to Time Clock Exemption and More!

Not just for truck drivers

The FMCSA has released its long-awaited proposed changes to Hours of Service rules for operators of commercial vehicles.  While these rule changes have been thought to mainly affect freight carriers and not passenger carriers, today we found a nice surprise. One change will have a major impact on the limousine industry, specifically for operators that are utilizing the short-haul or “time clock” exemption.  

Changes to the time clock exemption

The exemption currently states that if a driver stays within 100 air miles, and does not have more than 12 hours from the time they report on duty until the time that they are relieved that the driver does not need to fill out a Record of Duty Sheet (log sheet).  Under the proposed rule change drivers under this exemption will be able to travel 150 air miles and have 14 hours in which to complete their work. Passenger carriers would still be limited to only driving 10 hours during their shift, but given the nature of dropping off passengers for events and dinners, this limit has rarely been an issue for the limo industry.

NOTE: The exemption still requires records of duty status but many companies find using the time clock exemption less burdensome on drivers.
  

This extension can have a huge impact on operators that are currently close to exceeding this limit 8 times in a 30 day period. This will prevent more operators from needing to implementing expensive and burdensome ELDs into their operation.  

Still, have to abide by state rules

Carriers will need to be aware of state regulations that may not adopt current rules immediately before they adjust their operating procedures.

There is a 45 day public comment period regarding these changes, after which it would likely be several months for these changes to go into effect. 

NOTE: Carriers who complete intrastate and interstate trips will need to abide by the stricter of state or federal regulations.

Additional Change – Adverse Weather

Another potential change would allow a driver facing adverse weather conditions to extend his current 15-hour workday by 2 hours.  This change is meant to allow drivers the opportunity to park and wait out a storm, rather than just the ability to extend their driving time.   

Click here to read these proposed changes, or to learn more about how to give your feedback to the FMCSA.  

Drivers Record of Duty Status
Under the proposed rules drivers will have an additional 2 hours a day and 50 miles before needing to fill out a log sheet


AZLimo – Excels at Federal Audit

Congratulations to AZLimo for passing their federal compliance review with the top rating available – Satisfactory!

Joe and Jacob have worked hard to ensure that their drivers, vehicles and overall operations meet the most stringent DOT requirements.

AZLimo uses our quarterly audits to help ensure they are always audit ready. Let Limo & Bus Compliance help you as well!

AJL - DOT Audit

AJL International Scores Top Audit Score

We’re excited to announce that our friends at AJL International, with offices in Dallas and Austin, recently passed their most recent DOT Audit with flying colors. We’ve had the pleasure of working with Matt and Jay for a long time and their commitment to safety and compliance is truly industry leading. Great job guys!

Limo & Bus Compliance specializes in compliance for passenger carriers. When experience matters, trust the company with the most successful audits in the limo industry.