TurboTrucker
2004-11-23 01:01:51 UTC
The FMCSA is taking comments until November 30,2004 by the public on the
proposed rules that would require on-board recording devices, or black
boxes, and it is essential that our side has a chance to respond. I'm not
sure that anything can be done to prevent them from being required, but if
anyone cares, it might not hurt to get your comments on the subject heard.
http://www.regulations.gov/AGCY_FEDERALMOTORCARRIERSAFETYADMINISTRATION.cfm
The above will take you to the comment page where you can offer your
comments. Instructions are there for acceptable methods for submitting your
comments.
I am posting my comments that have been mailed to them.
"Aside from the costs that would be associated with this proposal, there is
a fundamental issue at stake here. Truck drivers would be subjected to a
vast violation of privacy by anyone granted electronic access to the
proposed recording devices.
The proposal to use these devices as a means of enforcing HOS rules is also
new ground, for I cannot think of any industry or group that would be held
to this strict a standard, as a means to monitor their day to day
activities for enforcement purposes.
I think that most people understand that standards must be set, and that
they need to be enforced, but there must be lines that are not crossed, to
insure that people do not feel that their lives are constantly under the
microscope of governmental control.
In this case, the end is not justified by the proposed means. The trucking
industry has steadily improved their safety numbers over the past decade,
and this continues to be the case. Enforcement of the HOS regulations at
roadside inspections, audits of carriers, and fines associated with
violations are effective tools of enforcement, and reason to have made me
stay compliant for many years now.
The proposal of my being subjected to a random check at any time of an
electronic device that would be required to be installed on my vehicle, by
enforcement authorities is something I am not prepared to condone or
tolerate. This is not because I expect to be found guilty of wrongdoing. It
is because it violates fundamental freedom(s) that this country was founded
on. I find it an unreasonable violation of an expected right to be able to
do my job without being subjected to an uncomfortable level of scrutiny and
mistrust.
Some will state that as drivers of commercial vehicles, we are expected to
be held to a higher standard, and I agree with that premise and in fact
have stated it myself. I operate my truck with that in mind each and every
day. We all have a responsibility to share the roads, and do our jobs in a
responsible manner, and with regard to the general public at all times.
To those that endorse or who are calling for these devices, I must ask that
each of you consider something very carefully. If this is allowed for one
group or industry, where does it lead? As with all other methods of
stemming misbehavior in our society, it routinely has spread into other
areas as a general rule.
If a truck driver is allowed to be randomly stopped and have all of the
vehicle's previous activities scrutinized over a period of time, and then
is cited for violations based on that criteria, the next logical step will
be to apply this to other groups of people with the same goal in mind.
To illustrate what I am eluding to, imagine being stopped by an officer and
having an electronic device hooked up to your automobile, and then written
citations for every instance that your vehicle was noted for being operated
over the maximum speed limit for the state you reside in, or for that
matter, just a few moments before you were stopped.
I have been a driver for 22 years, and have attained a safety record that I
am proud of. I do not operate in an unsafe manner, nor do I align myself
with people that do.
The ticket to keeping enforcement fair and equal is to use tools that are
designed to reduce misconduct, but at the same time, assure fairness and a
sense of trust extended to those that are playing by the rules. As a person
who does his level best to abide by the rules, I am not willing to continue
working in this industry if subjected to this device requirement.
Stepping up enforcement at the state level, at inspection stations will
weed out those drivers that willingly violate the rules. Stepped up
enforcement and audits of carriers and imposing strict and hefty fines in
either case, that are not negotiable when they are found guilty, will
either force these drivers and/or carriers into compliance, or put them out
of business, as they should be.
I beg of the FMCSA to take time to consider this issue carefully, and to
not be influenced by outside groups or by those that have ulterior and
misplaced goals in mind.
Inside most of those trucks that are on the roads each day, is an average
person just trying to make a living."
~Tony~
proposed rules that would require on-board recording devices, or black
boxes, and it is essential that our side has a chance to respond. I'm not
sure that anything can be done to prevent them from being required, but if
anyone cares, it might not hurt to get your comments on the subject heard.
http://www.regulations.gov/AGCY_FEDERALMOTORCARRIERSAFETYADMINISTRATION.cfm
The above will take you to the comment page where you can offer your
comments. Instructions are there for acceptable methods for submitting your
comments.
I am posting my comments that have been mailed to them.
"Aside from the costs that would be associated with this proposal, there is
a fundamental issue at stake here. Truck drivers would be subjected to a
vast violation of privacy by anyone granted electronic access to the
proposed recording devices.
The proposal to use these devices as a means of enforcing HOS rules is also
new ground, for I cannot think of any industry or group that would be held
to this strict a standard, as a means to monitor their day to day
activities for enforcement purposes.
I think that most people understand that standards must be set, and that
they need to be enforced, but there must be lines that are not crossed, to
insure that people do not feel that their lives are constantly under the
microscope of governmental control.
In this case, the end is not justified by the proposed means. The trucking
industry has steadily improved their safety numbers over the past decade,
and this continues to be the case. Enforcement of the HOS regulations at
roadside inspections, audits of carriers, and fines associated with
violations are effective tools of enforcement, and reason to have made me
stay compliant for many years now.
The proposal of my being subjected to a random check at any time of an
electronic device that would be required to be installed on my vehicle, by
enforcement authorities is something I am not prepared to condone or
tolerate. This is not because I expect to be found guilty of wrongdoing. It
is because it violates fundamental freedom(s) that this country was founded
on. I find it an unreasonable violation of an expected right to be able to
do my job without being subjected to an uncomfortable level of scrutiny and
mistrust.
Some will state that as drivers of commercial vehicles, we are expected to
be held to a higher standard, and I agree with that premise and in fact
have stated it myself. I operate my truck with that in mind each and every
day. We all have a responsibility to share the roads, and do our jobs in a
responsible manner, and with regard to the general public at all times.
To those that endorse or who are calling for these devices, I must ask that
each of you consider something very carefully. If this is allowed for one
group or industry, where does it lead? As with all other methods of
stemming misbehavior in our society, it routinely has spread into other
areas as a general rule.
If a truck driver is allowed to be randomly stopped and have all of the
vehicle's previous activities scrutinized over a period of time, and then
is cited for violations based on that criteria, the next logical step will
be to apply this to other groups of people with the same goal in mind.
To illustrate what I am eluding to, imagine being stopped by an officer and
having an electronic device hooked up to your automobile, and then written
citations for every instance that your vehicle was noted for being operated
over the maximum speed limit for the state you reside in, or for that
matter, just a few moments before you were stopped.
I have been a driver for 22 years, and have attained a safety record that I
am proud of. I do not operate in an unsafe manner, nor do I align myself
with people that do.
The ticket to keeping enforcement fair and equal is to use tools that are
designed to reduce misconduct, but at the same time, assure fairness and a
sense of trust extended to those that are playing by the rules. As a person
who does his level best to abide by the rules, I am not willing to continue
working in this industry if subjected to this device requirement.
Stepping up enforcement at the state level, at inspection stations will
weed out those drivers that willingly violate the rules. Stepped up
enforcement and audits of carriers and imposing strict and hefty fines in
either case, that are not negotiable when they are found guilty, will
either force these drivers and/or carriers into compliance, or put them out
of business, as they should be.
I beg of the FMCSA to take time to consider this issue carefully, and to
not be influenced by outside groups or by those that have ulterior and
misplaced goals in mind.
Inside most of those trucks that are on the roads each day, is an average
person just trying to make a living."
~Tony~