Private Fleets Examine Impact of Proposed HoS Regs

by Bruce Richards

Truck News is introducing a new column this month – by Bruce Richards of the Private Motor Truck Council of Canada. The column examines issues of interest to the trucking community from the perspective of private carriers.

Reaction from private carriers to Canada’s proposed new hours of service regulations range from “no impact” to “we’ll need to completely redesign our fleet operations.” There doesn’t seem to be much middle ground. In discussions with PMTC members, we gauged their reactions to the challenges that fleets will face in dealing with the changes planned for implementation next summer.

The biggest challenge for fleets may be the reduction in allowable on-duty time. Drivers will be limited to 14 hours on duty (of which 13 hours can be spent driving) in any 24-hour period. The reduction in on-duty time of one hour from the current standard may not seem overly important, unless you operate a fleet that depends on a 15-hour day to make scheduled runs. And, there are fleets with both long haul and local operations that now utilize all of the currently available 15 hours.

Carriers whose operations are local in nature, with drivers returning home most nights, may appear to be the least affected – but if they are not careful some of these fleets could overextend the available hours. Consider fleets that currently plan for a 15-hour workday with regular routes that include many stops for store deliveries. In some cases the driver may also be the person who not only delivers the product, but also stocks the shelves in the store.

A fleet with this type of operation may find under the new regime, that the reduction in on-duty time precludes making all the required deliveries. Existing routes will require careful analysis and perhaps alteration. New arrangements with customers may be required to reduce the time the driver spends on each delivery, particularly where time is spent in the store. Current delivery times will need to be examined on a customer-by-customer basis to determine how to fit their needs into the new hours of service regime. The proposed one-hour reduction in on-duty time could have a significant impact on customer service.

Long haul and cross border carriers will also be impacted. For example, one perishable goods long hauler who utilizes currently available hours may not be able to meet its present delivery schedules under the new regulations. This fleet schedules its departures from Ontario to meet pre-established delivery windows in other provinces two or three days later.

A reduction in available working time could result in the need to renegotiate terms of sale with certain clients – not easy under any conditions. Customers could simply decide to look for a supplier who is geographically closer, and can meet the established delivery schedules without necessitating any change on their part.

If customers are unwilling or unable to make changes to their existing receiving schedules, the fleet needs to consider other options. These could include allowing for longer transit times with additional layovers for drivers, or utilizing teams to make the delivery on time – any of which will add hard costs to operations, and possibly additional downtime for trucks.

Another fleet delivers critical hospital supplies out of its Toronto area DC, to locations in the Ottawa area. They have developed a schedule that allows them to make those deliveries, include some pick-ups of supplies for backhaul, and return home within the allowable 15 hours, but without any time to spare. The proposed move to a 14-hour day will likely require a complete re-design of their delivery system and they are now considering how best to accomplish all of their needs within the proposed allowable time frames.

To accomplish those requirements they will need to consider options that range from a layover for drivers, to utilizing their fleet in a line-haul operation to a small DC in the destination city and then using local transportation to make the deliveries. Variations on these ideas could see the fleet line-haul to the company’s Montreal facility for early morning arrival and use Quebec based trucks from that facility to make the Ottawa area deliveries on time. This type of scheduling would demand very tight time frames and turnarounds, but is one of the options that need to be considered. Each of those options however would add costs in the form of additional trucks, rented DC space, additional drivers, or additional personnel at the Montreal facility.

Yet another private fleet delivers to a limited number of DCs and a large number of stores across the country on a daily basis.

Over the years they have developed a schedule that sees their drivers either back home or shutdown on the road after a 15-hour day. The delivery schedule is fairly intricate in that the stores, while open 24 hours a day for the public, have a limited receiving window that precludes deliveries after 11 p.m. for security purposes.

The proposed reduction in available hours for drivers will necessitate a major overhaul of the company’s existing delivery schedules. At the moment they are considering whether additional trucks and drivers will be required. Add the shortage of qualified drivers to the mix and one can readily see that there are no easy answers. Another option could be extending the delivery windows at individual stores, but that would bring about a number of complications beyond the control of the transportation department.

One common theme that surfaced during my discussions with fleet managers was the need to consult with their drivers. The message is clear that you shouldn’t overlook drivers as a valuable source of ideas and information as you seek ways to balance delivery needs with the new regulations.

Many private fleet managers plan to conduct in-house forums with their drivers and dispatchers to ensure that everyone is aware of the new regulations.

It cannot be assumed that everyone will understand written material in exactly the same way, or even that the material will be understood correctly. Responsible fleet managers and drivers are very conscious of maintaining clean operating records, so investing the time to meet with everyone involved to ensure a clear understanding of the new rules will be time well spent.

Despite the challenges of a new hours of service regime, most fleet managers agree that the result will be safer operating conditions for all drivers, and if we experience uniform implementation and enforcement all carriers will operate on a level playing field.

-The Private Motor Truck Council of Canada is the only national association dedicated to the private trucking community. This column presents opinions on trucking issues from the perspective of private carriers. Your comments are invited and can be addressed to trucks@pmtc.ca


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