Last summer, SC&RA gained a major victory when the Federal Motor Carrier Safety Administration granted the Association’s request for an exemption for specialized carriers to the mandatory 30-minute rest break requirement as part of Hours of Service Rules for drivers. Learn what this development can mean for your company from two carriers that have safely and efficiently taken advantage of the exemption. Speaker: Danny Cain, Safety Director, Edwards Moving & Rigging

1. FMCSA 30-Minute Break
Exemption
DANNY CAIN | Safety/Risk Manager

2. Exemption Overview
The exemption request was filed
by the SC&RA in partnership with
NBIS Specialized Transportation
Risk Management Department
led by Robert C, Moore, Esq.
Docket No. FMCSA-2014-0420

3. Benefits of Exemption
“It enables all specialized carriers and drivers responsible for the
transportation of loads that exceed normal weight and
dimensional limits- oversize/overweight (OS/OW) loads – and
require a permit issued by a government authority, to be exempt
from the 30-minute rest break provision in 49 CFR
395.3(a)(3)(ii)”

4. Effective Dates
The granted exemption is effective from 12:01 a.m.
June 18, 2015 through 11:59 p.m. June 18, 2017.
This is the maximum period allowed by §381.300

5. Reasoning Behind Exemption Request
• 30 Minute Break uniquely affected OS/OW Loads placing tremendous
burden on driver finding a safe haven to stop.
• Exacerbated number of instances where drivers had to park these loads
at roadside, impacting safety of general public and driver.
• Hours of travel restricted by permit from state to state often causing
conflict with timing of required 30-minute rest break.

7. Reasoning Behind Exemption Request
• Nationally, there is a major shortage for parking space especially for
OS/OW loads.
• Some state issued permits prohibit deviation from route for rest break
requirements, fueling, etc.
• Coordination of breaks created delays which ultimately led to permits
expiring.

8. OS/OW Dimensions
• On average OS/OW loads may measure approximately 15-16 feet wide
and high and be in excess of 100 feet in length. Many OS/OW are 20 feet
wide and over 200 feet.
• Often safest option is to park on
shoulders of interstate routes &
other highways and even on ramps
leading to & from these highways.
• Many parked loads occupied an
entire lane.

9. OS/OW Transport Objectives
• Ensure the safety of transport crew and general public
• Protect integrity of cargo & transport equipment
• Protection of Infrastructure – roads, bridges, utilities overpasses, etc.

10. Mitigating Transport Hazards
The order of precedence & effectiveness of hazard control with OS/OW
transports are the following:
• Engineering controls –Substitution of equipment
or process to decrease hazard
• Administrative controls – Safe work practices,
exposure time limitations – control climate
exposure or ergonomic hazards
• Personal protective equipment – Used when
engineering & administrative controls are not
feasible or for additional protection.

11. OS/OW Route Maneuvering
• Used to avoid various route
obstructions when “normal” travel
directions must be altered to allow
safe passage of transporter and
support personnel
Moving east bound in west bound construction zone
Entire west bound traffic shut down.

12. OS/OW Route Maneuvering
Median cross over to bypass construction and low bridges.

13. OS/OW Route Maneuvering

14. Travel Restrictions
Based upon permit approval
which includes:
• Night transport only
• No weekends
• No holidays
• City curfews-A.M. P.M.

15. Traveling at Night

16. Night Hazards = Impaired Drivers!

17. Road & Traffic Conditions Posing Potential Pull Off Hazards
• Grade of road
• Width of road
• Shoulder surfaces
• Traffic congestion
• Overhead energized lines
• Tight and narrow turning lanes
• Parked vehicles
• Shoulder obstructions-
guardrails, fencing, trees

18. Transport Support Activities
Mud mats are laid out to reduce
steep grade over RR tracks

19. Terms of Exemption
1. Drivers of specialized loads moving in interstate commerce that exceed
normal weight and dimensional limits – oversize/overweight (OS/OW) loads
– and require a permit issued by a government authority, are exempt from
the requirement for a 30-minute rest break in
§ 395.3(a)(3)(ii). Drivers of loads not moving in interstate commerce are not
eligible for this exemption.

20. Terms of Exemption
2. Drivers must have a copy of this exemption document in their possession
while operating under the terms of this exemption. The exemption
document must be presented to law enforcement officials upon request.

21. Terms of Exemption
3. All motor carriers operating under this exemption must have a “Satisfactory”
safety rating with FMCSA, or be “Unrated”. Motor carriers with “Conditional” or
“Unsatisfactory” FMCSA safety ratings are prohibited from using this exemption.

22. Terms of Exemption
4. All motor carriers operating under this exemption must have Safety
Measurement System (SMS) scores below FMCSA’s intervention thresholds,
as displayed at http://ai.fmcsa.dot.gov/sms/.
7 BASIC’s – Behavioral Analysis & Safety Improvement Categories
1. Unsafe Driving
2. Hours of Service
3. Driver Fitness
4. Controlled Substances/ETOH
5. Vehicle Maintenance
6. Hazardous Materials
7. Crash Indicator

23. Special Notifications to FMCSA
Any motor carrier utilizing this exemption must notify FMCSA within 5
business days of any accident (as defined in 49 CFR 390.5) involving any of
the motor carrier’s CMV drivers operating under the terms of this exemption.

24. Special Notifications to FMCSA
The notification MUST include the following information:
A. Name of operating motor carrier and USDOT number
B. Date of the accident
C. City or town, and State, in which the accident occurred, or closest to the
accident scene
D. Driver’s name and license number and State of issuance

25. Special Notifications to FMCSA
The notification MUST include the following information:
E. Vehicle number and State license plate number
F. Number of individuals suffering physical injury
G. Number of fatalities
H. The police-reported cause of the accident
Whether the driver was cited for violation of any traffic laws or motor
carrier safety regulations, and
J. The driver’s total driving time and total on-duty time period prior to the
accident

26. Termination
FMCSA will immediately revoke or restrict the exemption for failure to comply
with its terms and conditions.

27. OS/OW Double Wide Loads

28. Turning Obstructions
• Guard rails
• Traffic control devices
• Rail crossing arms
• Trees
Fifty-five feet of guardrail removed
to make this transport.
• Parked Vehicles
• Guide Wires
• Poles
• Billboards
All pose entrapment hazards with ground personnel
• Hydrants
• Buildings
• Embankments
• Utility Lines

29. Temporary Removal of Overhead Obstructions

30. Pre-Trip Safety Briefing

31. Using Spotter to Check Clearance
↑
Higher
Clearance
On This
Side

33. Special Parking Considerations
It’s not easy to find multiple staging areas for transporter 350’ long.

34. Special Equipment Considerations

35. Case Example - Lessons Learned
PROJECT OVERVIEW:
The transport of a 1 reflux vessel measuring 203’ long, 12’9 wide, 14’2” tall and weighing
261,858 lbs. and 1 cold box which measured 54’ long, 16’ wide and 24’8” tall weighing
167,000 lbs.
Both pieces arrived at the Port of Shreveport and were transported 110 miles to Longview,
Texas.
These moves involved numerous amounts of pre-move prep work as well as transport
coordination between Louisiana and Texas DOT authorities.
Massive coordination and planning also involved numerous utility companies, police agencies,
land owners, tree trimming companies, sign removal companies, etc.

37. Logistical Implications & Concerns Experienced
1. Logistics of finding adequate safe haven and pull off for super loads of this magnitude
would have been nearly impossible.
2. Pull off areas for these transports were greatly dictated by the geographical terrain of the
transport route.
3. Long stretches of two lane highways afforded no simple remedy to pull over for break.
4. Restricted two lane highway potentially restricted emergency vehicles responding to 911
calls causing critical and life threatening delays.
5. If transport crew doesn’t reach designated pull off area due to required break then
additional contingency pull off areas would need to be added increasing costs.

39. Logistical Implications & Concerns Experienced
6. Deviation from established pull off areas would possibly jeopardize the integrity of
underground utilities and infrastructures as they would not have been previously
evaluated for ground bearing pressure.
7. Length and weight of our entire transporter took over an hour and half to navigate turns.
Getting off road for a break would have taken longer than the actual 30 minute
requirement.
8. Averaging 1 mile per hour meant that a 30 minute break in all likelihood would have
prevented transport team from reaching designated pull off areas and would have placed
us in violation of permit provisions with regards to curfews.
9. 30 minute break would have adverse effect on traffic congestion as well as increased time
and hazard exposure to escort personnel, utility support workers and police officers.

41. Commercial/Public Relations Implications & Concerns Experienced
1. Project costs would most definitely increase with lengthy delays as support personnel
would require and bill for extra time. (Hourly/OT rates, extra hotel costs, fuel
consumption, meals, etc.)
2. Increased traffic congestion equates to increased agitation on part of general public. In
this day and age of social media, local and DOT personnel would be bombarded by text
messages, twitter feeds and the like.
3. “Negative Press” has the potential to prevent successful approval of OS/OW permits in the
future or restrict previous transport routes through certain communities.
4. Delayed timing of crossing under high voltage transmission lines literally would have
added several days to the transport.

43. Commercial/Public Relations Implications & Concerns Experienced
5. Available electrical clearances were predicated on low peak hours as well as early
morning hours when temperatures are cooler.
6. Delays with outages due to transmission lines being de-energized for height clearance
issues would have greatly affected businesses and residencies along transport route.
7. Outage delays could increase aggravation of public leading to possible law suits.
8. Customer equipment being delivered late potentially affect critical path activities of
project increasing overall costs.

45. Commercial/Public Relations Implications & Concerns Experienced
9. Transport delays as a result of 30 minute break would require more time in the field
with government officials such as bridge engineers, DOT representatives and traffic
control personnel.
10. Unexpected delays due to stoppage time increases misinformation given to general
public by news outlets & DOT PIO’s creating increased concern, confusion and
aggravation.

47. OS/OW Best Practices
Driver’s should maintain copy of exemption as well as OS/OW permits for
at least 7 days beyond the actual transport in case of being audited for HOS
violations.
Motor carriers hauling OS/OW loads should pay extra attention to SMS
scores as to not trigger an Alert status or exceed FMCSA’s intervention
threshold which would forfeit exemption.

48. Questions
DANNY CAIN | Safety/Risk Manager