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1. Are data currently available that can accurately record loading, unloading, and delay times?

There are no devices that function to exclusive or accurately record delays in loading, unloading, or dock times. With ELD’s companies are able to manually extrapolate how long a truck has been at a shippers location.  This is an estimation and not a definitive or practical way of determining detentions. 

2. Is there technology available that could record and delineate prompt loading and unloading times versus the extended delays sometimes experienced by drivers?

Carriers and truckers are operating on very tight margins. Increasing the compliance and recording responsibilities for trucking companies and drivers would be adding an unfair burden on to them. Warehouses, produce sheds, and shippers are important stakeholders in the transportation process. The responsibility and ultimately the benefits realized from increased efficiency will benefit them as much as their transportation partners. Technologies to record and capture the individual components of the loading/unloading process are best performed parties ultimately responsible for understanding the bottlenecks and making changes to expedite the process. 

3. How can delay times be captured and recorded in a systematic, comparable manner?

A potential solution might involve a driver checking in and out at a third party administer portal at a shippers location with their CDL. 

4. Could systematic collection and publication of loading, unloading and delay times be useful in driver or carrier business decisions and help to reduce loading, unloading and delay times?

The ability of a transportation company to understand how long a shipper takes to load and unload is an important part of the pricing and resource utilization decision. Currently carriers rely on institutional knowledge and experience to make estimates how long shippers will take to load and unload.  

5. What should FMCSA use as an estimate of reasonable loading/ unloading time? Please provide a basis for your response.

Reasonable waiting times for carriers need to take into consideration the commodity that is being transported.  Highly automated warehouses, shipping boxed dry freight can not be compared to a produce shed shipping refrigerated fresh fruit from the field on a 100 degree day.  FMCSA would benefit from a study period sampling various shippers to establish a baseline of reasonable times. From this FMCSA and the industry can work towards reducing times.

6. How do contract arrangements between carriers and shippers address acceptable wait times? Do these arrangements include penalties for delays attributable to a carrier or shipper?

Carriers who have direct shipper contacts have some clauses related to shipper delays.  Because the balance of power is in favor of shippers these are generally non negotiable and often times onerous. Carriers have very little ability to negotiate these terms, and no general industry standards to compare them to. 

7. What actions by FMCSA, within its current statutory authority, would help to reduce loading, unloading and delay times?

When drivers are delayed at shippers they typically are not performing any active work.  They’re relaxing or sleeping. FMCSA should reconsider assigning waiting time to not count towards a 14 hour daily shift. Another consideration might be a new category of time or exemption.  In instances where drivers are delayed more than 3 hours at a shipper, the time is not counted towards their daily 14.