The Federal Motor Carrier Safety Administration (FMCSA) announced final amendments to its “hours of service” regulations. These updates create a more reasonable compliance standard for short and longhaul drivers, including those who deliver manufactured homes and their parts and accessories.
MHI has long advocated for changes to the FMCSA’s “hours of service” regulations to allow greater flexibility for the transportation of manufactured homes without sacrificing safety. In response to the Department of Transportation (DOT) and the FMCSA proposed changes to its “hours of service” requirements for drivers in 2018, MHI submitted comments urging the DOT and FMCSA to ensure requirements take into consideration the unique challenges facing drivers, manufacturers, shipping companies, and others involved in the transportation of manufactured homes.

Several updates to the “hours of service” requirements will benefit our industry and its drivers. The revisions, which go into
effect September 29, 2020, include:

• Expansion of the existing short-haul distance restriction from 100 to 150 air-miles and extension of the maximum
allowable workday from a 12- to a 14-hour period requirement. These changes expand the window of operations for short
-haul operators who also hold a Commercial Driver’s License, which should result in an increased number of deliveries and
less time spent managing administrative overhead resulting from unnecessary delays. MHI’s members who are parts and
equipment suppliers and have drivers who operate as short-haul operators will likely benefit from this expanded operating
window.

• More options available to drivers who encounter adverse driving conditions by allowing up to a 16-hour driving window
for property carriers to complete up to 13 hours of driving. The final rule also amends the definition of ‘‘adverse driving
conditions’’ to clarify the driver’s role in determining when such conditions are identified. These updates strike a balance
between providing the necessary flexibility to manage frequent but unpredictable delays in response to adverse
conditions, while also preserving and continuing to promote road safety.

• The mandatory 30-minute break requirement will now be linked to cumulative driving time, rather than on-duty time.
Going forward, an on-duty/not driving period can qualify as the required break, as long as the break is at least 30
continuous minutes. Manufactured home deliveries necessitate multiple breaks, including periodic stops to check tire
pressure and safety equipment. Drivers also stop to coordinate with the pilot car or police escort before navigating certain
structures or obstructions. These stops naturally help to relieve driver fatigue and, as long as the break is 30 minutes in
duration, would likely satisfy the updated break requirement.

• Provide drivers with additional flexibility to meet the minimum off-duty requirement by spending at least seven
consecutive hours in the sleeper berth coupled with a minimum period of at least two hours in the berth or otherwise
off-duty, as long as the two periods total at least 10 hours. When paired, neither qualifying period will count against the 14
-hour driving window. Prior to this final rule, the shorter two-hour period counted against the window. The new rule
should give drivers the flexibility to use sleeper time for shorter breaks, such as “power naps,” so they can effectively
“pause” the on-duty clock.

MHI will continue to support reasonable standards that promote the safe and secure transportation of manufactured homes, as well as manufactured home parts and supplies, while ensuring that federal regulators are mindful that costly or impractical requirements could price consumers out of the market for manufactured homeownership.

If you have any questions, please contact MHI’s Government Affairs Department at 703-229-6208 or MHIgov@mfghome.org.