There used to be a time when the topic of personal conveyance revolved around motor truck cargo limits, sub-limits and insurance. That changed with CSA years ago, with the early onset of the hours of service basic, a log book, and most notably, with the introduction of electronic logs. For those in the industry for some time, the adage was: the log book may be right but it doesn’t mean it is correct. Funny how the more things change, the more they stay the same.
With the implementation of the ELD mandate in December 2017, the first ‘next’ hurdle for FMSCA was to examine the personal conveyance guidance. If the ELD mandate is to place most CDL drivers under one electronic platform to deliver a safer roadway, how long would business wait to adjust? The quick answer is: not long. After review and input from the industry ending in February, FMCSA has agreed that a truck’s movement from a shipper or receiver to the nearest safe resting area may be considered as personal conveyance. I think most would agree, very practical. Have you considered the use of ‘may be’ in this equation though?
What if this new guidance ‘may be,’ in large part, the easy way out on this hot potato? If the issue revolves around huge delays loading and unloading at terminals, and the pressure of coercion, it may be possible that the new guidance does not address the real problems. What if for one moment, and maybe, just one time, we consider that shippers need to be brought into the solution process? If we are all serious about solutions, then another old adage pertains: if your only tool is a hammer then every problem looks like a nail. We would like to think that creating new industry best practices is not a one-tool show.
If you or your company have questions or concerns regarding the future of regulations, you should speak with a professional who understands their impact. AssuredPartners Transportation has professionals who assist clients in the area. To learn more, visit AssuredPartners Transportation.