With a laudable goal of improving safety, the DOT theorists have proposed a complex system that defines five categories of drivers with specific hours when each category of driver can and cannot work. It does not reflect the reality of the work environment. Clearly, the present requirement of 8 hours off-duty is not enough. But, there is little reason to believe that more than 10 hours is needed to provide that opportunity for sleep. The research does not support the placement of limits on time spent on other work-related activities by our drivers.
Nobody expects drivers to work without meal or rest breaks.
But, that is a matter best left to the drivers and their companies to manage. We also suggest DOT abandon the requirement for onboard recording devices. Such devices are costly to install and maintain. Even DOT acknowledges that there is no evidence suggesting they will do anything to improve a driver's safety performance. Real improvements in highway safety will come when all drivers, including in particular automobile drivers, learn to share the road safely with others.