AMSA Calls for Additional Hours-of-Service Reform

Moving Industry Submits Public Comments to Federal Motor Carrier Safety Administration


October 10, 2018

ALEXANDRIA, VA — The American Moving & Storage Association today submitted a public comment in response to the Federal Motor Carrier Safety Administration’s (FMCSA) request for input in four specific areas of current hours-of-service (HOS) rules, which limit how and when commercial drivers can operate. Under the agency’s Advanced Notice of Proposed Rulemaking (ANPRM), administration officials sought public insight into:

  • Expanding the current 100 air-mile “short haul” exemption to 14 hours of on duty-time
  • Extending the current 14-hour on-duty limitation for drivers encountering adverse driving conditions (ADCs)
  • Revising the current mandatory 30-minute rest break
  • Reinstating the split sleeper berth option

The association’s public comment, which drew on robust feedback from the diverse membership, covered a broad range of potential reform initiatives all designed to improve carrier operations while maintaining a strong commitment to driver safety. The American Moving & Storage Association is calling for:

  • Increasing the 12-hour short haul on duty-time driving window to 14 hours
  • Eliminating the 30-minute rest break rule
  • Adding “mechanical breakdowns in unsafe locations” to the ADC allowable definition list
  • Changing the ADC foresight standard to conditions unbeknownst to the driver at the start of their current work day
  • Allowing drivers to split their sleeper berth segments in combinations beyond the current two and eight-hour restrictions
  • Giving drivers discretion to split their required 10-hour rest period entirely

“Many of the federal regulations governing commercial truck driving are well-intentioned, yet limit economic growth while failing to achieve their goal of improved safety,” said Vice President of Government Affairs Paul Milotte. “For many of the areas we commented on, the rules actually pressure drivers to operate when they are tired and rest when they are alert. Granting our requests will empower drivers to exit roads during traffic congestion, remove operational incentives to meet a delivery time despite hazardous road conditions, and optimize the use of needed rest periods. Our drivers are no more inclined to risk their safety and the property they carry than any other motorist. It is our hope that the comments submitted to the FMCSA will lead to a best-case scenario: growing our economy while making our roads safer.”

“The American Moving & Storage Association shares the FMCSA’s mission to promote high safety standards while fostering economic growth. Our economy relies on commercial truck driving to deliver goods across the globe,” said President and CEO Scott Michael. “Giving drivers the flexibility they need to perform their jobs and operate their vehicles safely will allow the Department of Transportation and the FMCSA to meet their admittingly tall task of enacting regulatory flexibility while fostering additional job creation. We applaud Secretary Elaine Chao and Administrator Raymond Martinez for partnering with industry to accomplish these goals.”

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The American Moving & Storage Association, home of the ProMover certification program, is the national trade association representing the nation’s moving and storage companies, which provide household goods moving services, specialized transportation for sensitive freight such as computers and trade show exhibits, and warehouse storage services. The association has approximately 3,500 members, including domestic and international companies and industry suppliers, and supports programs and activities that promote consumer protection, professional development, safety, and operational efficiency. Find out more at and