Federation of Professional Truckers - Petition for Rulemaking

COMMENT FOR RULEMAKING Submitted by: Micheal Cobb, CEO Federation of Professional Truckers (FOPT) wethefopt@gmail.com https://wethefopt.org Date: December 1, 2025 Re: Request for Rulemaking — Modernization of Hours-of-Service Regulations I am submitting this comment in support of a rulemaking to modernize the Hours-of-Service (HOS) regulations to better align with current fatigue science and real-world operational needs. The existing HOS framework relies on assumptions developed more than twenty years ago, prior to the adoption of ELDs, advancements in sleep science, and modern fatigue-modeling tools. Two changes are urgently needed: 1. Remove the 11-Hour Driving Limit While Keeping All Other HOS Protections The 11-hour driving cap is not supported by modern fatigue research. Current scientific consensus shows: • Fatigue risk is driven by circadian timing, not cumulative driving hours. • Human alertness peaks 2–10 hours after waking, assuming adequate sleep. • Crash risk spikes during the 2 a.m.–6 a.m. circadian low, regardless of total hours driven. • Sleep debt and schedule misalignment predict fatigue far more accurately than hour counts. Meanwhile, the 11-hour cap pressures drivers to “race the clock,” pushing them to drive during circadian low periods or hazardous conditions to avoid losing time. This increases fatigue risk, not reduces it. Removing the 11-hour limit does not diminish safety, because the following protections remain in full force: • The 14-hour duty window • The 10-hour mandatory off-duty period • The 30-minute break requirement • The 7/3 and 8/2 split sleeper berth rules • The 60/70-hour weekly cycle limits • ELD enforcement and auditing The 14-hour window already prevents extended duty periods. Eliminating the 11-hour cap simply allows drivers to rest when biologically needed, not when the clock dictates. Other countries, including Canada and Australia, safely allow 12–13 hours of driving with similar or stronger safety outcomes. The United States’ rigid 11-hour cap is outdated and unsupported by modern data. 2. Replace the 34-Hour Restart With a 24-Hour Circadian Reset The current 34-hour restart is not based on circadian science. Human physiology resets on a 24-hour cycle, not 34 hours. Fatigue-modeling tools and sleep research confirm: • One full circadian cycle with adequate sleep is sufficient to restore alertness. • Extending rest beyond 24 hours does not meaningfully improve fatigue recovery. • The 34-hour restart frequently disrupts sleep timing, producing chronic schedule drift and increased fatigue. A 24-hour circadian restart: • Aligns with actual human biology • Encourages consistent sleep timing • Reduces long-term fatigue • Matches real-world driver rest patterns • Maintains safety while improving operational stability FMCSA’s previous restart studies found no statistically significant safety improvement specific to 34 hours. There is no scientific justification to maintain a number that creates operational burden without measurable safety benefit. Conclusion Modern science is clear: Circadian alignment, sleep consistency, and adequate rest—not arbitrary hour limits—determine fatigue risk. Updating the HOS regulations to: • Remove the 11-hour driving cap, and • Replace the 34-hour restart with a 24-hour circadian-aligned reset, will create a safer, more flexible, scientifically grounded system that improves driver well-being and reduces fatigue-related crashes without weakening core safety protections already in place. I urge FMCSA to advance this rulemaking and adopt these evidence-based reforms. Respectfully submitted, Micheal Cobb, CEO Federation of Professional Truckers (FOPT) wethefopt@gmail.com https://wethefopt.org