HOS new rules

@TallJoe I too have now played around quite a bit with ETHOS (not as much as you, but quite a bit) and discovered exactly what you describe: "showing different outcomes based on the same inputs which were fed at different sequences."

It's at this point where the only choice left is to throw up one's hands and accept the final verdict that the FMCSA is severely incompetent. Silly me...I was starting to doubt it for a little while there.

 

Personal experience here. With keep trucking.
I was in the sleeper for 7.25 hours. When I checked my time. There was a button I had to press to see my drive time. The button was titled "see split birth hours" so I pressed it.
Before I pressed it I had no time. Onxe pressed I had my split time back. So I'm thinking cool.
But once I got rolling it showed as a violation. Mad as I can be I call k/t and ask what's up.
They said it will show as a violation. Untill I pull over and take my 3 hour break.
But the man on the phone was very adamant not to go over my 5hr 49 min drive time.
I drove for 4 hours took my break and the violation disappeared like it was never there. It was a bit nerve racking at first, but played out well. I hope this helps

 

@TallJoe I'm trying to find a relatively short sequence I can send the FMCSA to back up my claim that ETHOS yields different answers for the same input scenario. I contacted them yesterday to find out if my six-week-vacation scenario counts as a valid split sleeper berth break (my contact is currently checking into it) and mentioned the ETHOS issue in passing.

The sequence I stumbled on the other day was pretty long. I haven't been able to replicate it yet. I got the tool to indicate that 0900-1600 was the latest possible sleeper berth break to erase the 14-hour violation at midnight, then, after playing around a bunch with the inputs, got it to contradict itself by showing no violations with the break moved to 0901-1601.

If you find and post a sequence that works I'll pass it along to them. If/when I find one I'll post it here.

 

It is not only them who are unable to error proof their HOS validations. For instance, I do show one violation (which there is none) from the last week on my Keep Truckin ELD:
day 1:

day 2:



Day two shows in red color driving beyond 14 hour shift violation because the rest period from 5 am is not recognized by the program as the 2nd rest period which normally should pair the 1st period which started on day 1 at 8 pm and ended at 2:05 am on the 2nd day.

Side note: I moved from a parking lot onto the shipper lot which was very close - across the street. I could have been tempted and perhaps should have classified it as yard move but knowing that I had a little time left on driving line I decided not to, assuming that the Personal Conveyance from the shipper lot to the nearest available parking area was just as good.

 

The fortunate thing is that KT in DOT inspection mode does not explicitly show violations (red color graph, exclamation marks or notes) leaving it up to the person examining the logs to determine if there are any. That's good because otherwise I'd be afraid that LEOs would be more or less inclined to presume infallibility of some overseas programmers over my own claim of being correct.
Sometimes, I do call the KT customer support. They sound professional and are helpful most of the time but on a few occasions I had some arguments with them over the phone in which they were trying to tell me how I should interpret the HOS rules such as PC, Yard Move, or what actually 14 hour shift implies.

 

Peoplenet still doesn't allow a break of 10+ hours to be part of a split break. I just ignore it when it says I'm in violation when I'm not.

The FMCSA confirmed today that my hypothetical scenario in which a driver takes a 2+ hour break then violates the 14-hour rule (since there is no preceding 8+ sleeper break to pair it with), then takes six weeks off, then spends 8+ hours in the sleeper the night before returning to work has completed a valid split sleeper berth break, thereby removing the 14-hour violation from six weeks before.

Your example shows that ETHOS incorrectly reports a violation at midnight when the 7-hour sleeper berth break gets completed later. I will point that out to the FMCSA, but I also want to find a sequence that leads to two different answers for the same input. Shouldn't take very long.

 

My latest example was actually taken directly from Keep Truckin app, not FMCSA site tool. The funny thing is that when I plotted it on the FMCSA site (edited with some simplifications) it came out with no violations.
I no longer worry what the ELDs show for violations. It is up to me to know if I am in compliance or not. As I mentioned earlier, the actual logs are not marked with any violations indicators/flags when you present them to an inspecting person - he/she is the one who has to determine or rather discover violations if there are any.
I guess it is to our own benefit to grasp the meaning of the current HOS so we can utilize it to its fullest despite the obvious fact the the ELDs evidently could not keep up the pace with the latest changes.

 

Amen!

 

One more example that shows increased time efficiency despite long detention that used to burn 14 hours and often rendered the prebooked loads or loads that would follow impossible to realize.

Day 1. The appointment at the receiver is scheduled for 7:30 pm. I decided to go home for 7 off duty hours.
7 hours off duty - not a qualifying sleeper berth break, so it is not to be confused with a sleeper berth hours but it does qualify as the 2nd break that pairs with the first 8 hours break in the sleeper and does not count towards 14 hour shift. Since it happens to be 7 hours and a few minutes, it may be tempting to reclassify it as a sleeper berth - making it more usable but I did go home... so let's not promote falsifying logs. In this example, the detention spent in the sleeper at the receiver will serve the purpose of the 1st qualifying break for the next day timeline layout.

The receiver is known as Jewel DC or Albertson in Melrose Park, IL notorious for detentions. However, due to new HOS rules my 7 off duty hours extended the shift clock by 7 hours and instead of having to shut down at 10:05 pm, it was possible for me to drive until 5:05 am the next day. So I was not at all hesitant to book a load for the next day: 125 miles away at 11 AM EST/10 AM CST.



Day 2:


Here I am picking up a load at 9 40 am. Assuming the appointment set for 10 am, it would have been impossible to do under the previous rules.

Thank you FMCSA for making the HOS rules better suited for a modest owner operator such as me..finally.

 

They're also great changes for company drivers like myself who like to run. My eyebrows raised up really high the moment I read the news about the shorter rest break pausing the 14-hour clock because I knew it was a game-changer. It took contacting the FMCSA twice and posting zillions of comments here to learn the full extent of it but it's all been worth it because I now understand it completely. If only ELD makers could say the same. Peoplenet probably thinks it understands the rule revisions but it clearly doesn't.