A New Type Of Organization For Truckers

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Brett Aquila's Comment
member avatar

We've had some amazing discussions lately, and I wanted to follow up with one of the ideas.

Davy mentioned we need a completely new type of organization for truck drivers. I'd like to get some ideas from everyone on what that might look like.

Starting from scratch, what type of organization could we build that would benefit everyone - drivers, companies, customers, and the industry as a whole?

Now, that might sound like some pie-in-the-sky, far-fetched impossibility, but I don't think so. Not if we can start from scratch and build something that reaches those goals and avoids past mistakes.

Here's my initial thought:

We always complain that no one understands truck drivers. They don't take our knowledge or experience into consideration when making decisions. They don't understand where we're coming from because they haven't done the job like we have.

Well, maybe that could be one of the missions of this organization: to give us a stronger voice that gets more respect and consideration amongst major decision-makers than we've had in the past.

We know our knowledge and experience will contribute in a huge way to the health and wellbeing of ourselves, our companies, and our industry, but we have to be someone they can respect, someone they would be willing to listen to.

We want to be at the table when they do anything that affects us, including but not limited to:

  • building highways
  • designing trucks
  • developing safety features in trucks
  • writing traffic laws
  • creating rules at the FMCSA
  • designing pay packages, benefits packages, home time options, and company policies at major carriers
  • creating and managing training programs for new drivers
  • and much more

What if we put together a group of top-tier drivers that must meet a set of minimum standards for membership, and used our proven track records as top-tier drivers as validation for having our voices heard?

In other words:

We're the top-level professionals in this industry. We have a wealth of experience, priceless knowledge, and an understanding of our job and industry that can only come from years of high-level performance behind the wheel. There is no substitute for what we bring to the table, so give us a seat and we'll be happy to join the conversation.

It only stands to reason that our opinions would help across the board in countless ways. But if we don't have credibility in the eyes of the people making the decisions we want to be part of, they simply won't allow it. So, you would need to meet some minimum requirements for safety, experience, and productivity to belong.

This organization would be open to all drivers who meet minimum standards, regardless of the type of freight you haul or how often you get home. It won't matter if you're a company driver, lease driver, or owner-operator. I have no idea how many drivers would meet our criteria, but I would guess at least 250,000 nationwide, possibly many more.

I think if you've been in the industry for at least a year or two, you can imagine the positive force this could be in so many areas of our lives. It would give us a seat at the table for rulemaking, pay packages, truck designs, safety meetings, training programs, home time policies, and so much more.

Top-tier drivers are always in very high demand because our productivity is vital to our companies, our customers, and our industry. I believe a large organization of top-tier drivers would introduce a very interesting dynamic to the industry. You couldn't ignore us. We're the highest producers out there. We have the most knowledge, experience, and insight. We also make our companies the most money and give our customers the best service.

I think it would be very interesting.

What ideas do you guys have? By the way, this isn't idle chatter from me. If we came up with a worthy idea, I'd say it might be worth taking a shot.

CSA:

Compliance, Safety, Accountability (CSA)

The CSA is a Federal Motor Carrier Safety Administration (FMCSA) initiative to improve large truck and bus safety and ultimately reduce crashes, injuries, and fatalities that are related to commercial motor vehicle

FMCSA:

Federal Motor Carrier Safety Administration

The FMCSA was established within the Department of Transportation on January 1, 2000. Their primary mission is to prevent commercial motor vehicle-related fatalities and injuries.

What Does The FMCSA Do?

  • Commercial Drivers' Licenses
  • Data and Analysis
  • Regulatory Compliance and Enforcement
  • Research and Technology
  • Safety Assistance
  • Support and Information Sharing

Fm:

Dispatcher, Fleet Manager, Driver Manager

The primary person a driver communicates with at his/her company. A dispatcher can play many roles, depending on the company's structure. Dispatchers may assign freight, file requests for home time, relay messages between the driver and management, inform customer service of any delays, change appointment times, and report information to the load planners.

HOS:

Hours Of Service

HOS refers to the logbook hours of service regulations.
BK's Comment
member avatar

Interesting idea.

Are there already some organizations with the same objective? And if so, how would a new one be different?

I think Davy envisioned a volunteer leadership group to prevent the inevitable corruption problem with highly paid people with bad motives.

Would this be like a Cesar Chavez (National Farm Workers Association) grass roots effort? Maybe like a Bill W (AA) organization?

Davy A.'s Comment
member avatar

I've been spending considerable time thinking about this, basically a representative based structure that is made up of drivers. The organization would have a set of guidelines similar to the function of the constitution. Leadership would be elected with term limits so that the organization remains by drivers for drivers.

I thought about 3 levels of certification based upon safety, productivity and skills. In order to run for office so to speak, a candidate would have to be at the highest level of certification, meaning no preventables, 0 csa score, demonstrated ability to be productive and on time. And a less tangible one that is the ability to be diplomatic and work with carriers.

Such an organization, that had a focus on education, and fostering top tier drivers would justify the higher labor rates paid to drivers. The carriers would be able to do more with less. It's actually a much higher ROI for them. Walmart obviously has figured this out. It would behoove us to bargain rather than simply attempting to force rates higher. In turn, the carriers would be getting something substantial for the expense.

I envision an organization that works with carriers and authorities to foster safe professional drivers and practices. The certification standards and process would carry weight. Again its a win for both parties. Carriers would be more profitable with a certified safe workforce that was accountable.

The benefit to drivers is obviously higher wages, a sense of pride, numerous studies and companies have borne this out over time. Resources, we could help drivers become better drivers that are struggling but motivated. Drivers would be motivated to attain higher certification because it would mean higher pay, psychologically higher status and respect. It's the very definition of performance dictates pay.

I don't think we could effectively influence driver wages without the ability to collective bargain, but I have very little knowledge of that, much less the process of how it works. It's something that I will dive into because I think it will become necessary to accomplish objectives. Diplomacy with force.

I don't claim to have all the answers, just things that I've been thinking on. I have several areas I don't know, such as, worst case scenario, how does the organization provide for workers in the event that a bargain can't be reached? How is the organization set up, ie 501 c3, non profit, etc? How do we handle growth if happens rapidly especially? It's a mammoth concept to undertake.

Why do existing unions hold pension funds in this day and age of 401k and other retirement plans? I believe it is feasible to leave the pension out of the equation but bargain for more favorable retirement and health care plans to the drivers.

In a broad sense I have a vision of drivers being a professional highly trained group that are known to tbe the good guys again. We were once called the Knights of the highway. A living that were proud to be a part of. There will always be those who don't care, but there are enough of us that do care that I believe change can be fostered.

CSA:

Compliance, Safety, Accountability (CSA)

The CSA is a Federal Motor Carrier Safety Administration (FMCSA) initiative to improve large truck and bus safety and ultimately reduce crashes, injuries, and fatalities that are related to commercial motor vehicle

HOS:

Hours Of Service

HOS refers to the logbook hours of service regulations.
Trucker Kearsey 's Comment
member avatar

A lobbying group? Who can influence state & federal laws, as well as trucking companies and truck manufacturers?

How would we verify employment and "top tier"? Legally, employers can only say certain things about an employee. If including owner ops.. how would you verify their abilities since they only report to themselves. Every driver in the country thinks they are the best. What would be member benefits?

I am intrigued. But who would listen? And having 250,000 drivers and calling them the best of the best. Sounds like a dues paying organization. Unless you want it as a 501c3 which is an enormous amount of time.

What "training" would be better than what companies already do on the equipment which they drive?

Personally, i would tackle one issue at a time. But most of what we want would be what other organziations request.

#1. Parking-- make it illegal to close rest areas and weigh station to parking. Close the buildings if need be, but not the parking. Also make it a law that every industrial park needs some sort of parking area. Fees can be paid by the volume of trucks at each facility.

Have town hall type of meetings in each state with truckers and invite congressmen, senators as well as state reps. Show dash cams of the ramps and ramps of trucks parked illegally. Show closed rest areas. In both NE and NY... i kid you not.. every east bound rest area was closed recently. In winter. Unacceptable. Show how much $ they would save in police man power not having to ticket or write up accidents caused by illlegal parking or fatigue.

Stroke the egos of the politicians. Give them free publicity with fake awards for helping truckers. Push for some sort of tax break to allow truck parking at businesses. Push the urgency for rest and the wasted time finding a spot. Time that could have been used for transport.

We would have to get serious about the podcasts, interviews, and marketing. This is something I would LOVE to do.... wish i had time. The minifleet i am driving for promises i can come off the road for an in house job with them within the next year or two. So i could probablyget time by then. I have great equipment and editing knowledge.

Perhaps interview various companies and see what training programs work and what do not. Analyze them all. Then come up with a program that utilizes all of it. I did something similar after my first year. 5 of my friends and i sat down and wrote what our trainers didnt tell us... and tips we discovered. Then i complied it for my students. Perhaps do paid speaking engagements at local CDL schools? Or recruiting for the organization. A hint at what is waiting for a great driver.

CDL:

Commercial Driver's License (CDL)

A CDL is required to drive any of the following vehicles:

  • Any combination of vehicles with a gross combined weight rating (GCWR) of 26,001 or more pounds, providing the gross vehicle weight rating (GVWR) of the vehicle being towed is in excess of 10,000 pounds.
  • Any single vehicle with a GVWR of 26,001 or more pounds, or any such vehicle towing another not in excess of 10,000 pounds.
  • Any vehicle, regardless of size, designed to transport 16 or more persons, including the driver.
  • Any vehicle required by federal regulations to be placarded while transporting hazardous materials.
Trucker Kearsey 's Comment
member avatar

"We were once called the Knights of the highway"

This is strange to me cause i never heard this until i came OTR and only by truckers. Where I come from, truckers were thought of as dirty, blue collar, chain smoking, uneducated damn near criminals. Probably thanks to the outlaw images of Bandit & BJ and the Bear. It was the last thing you wanted your kid to be. The images in my head as a child were of traveling perverts who gave rides for sex. Or sleazy women who made more money having sex than they did driving. Hitchhikers disappearing in the 70s were often linked to the truckers who gave them rides, later to be found dead. Sorry... but this is honest. Those ideas are still in a lot of people's minds.

There needs to be a professionalism if we are going to combat those images. And though the influx of women and modernized truck stops soften the image a bit... we have a long way to go. I despise the youtube women who climb into their trucks in mini skirts and heels just for views. I habe shown the occasional cleavage, but i don't rely on sexuality to get my point across as some of these women do.

Many of the trucking organziations around dont even involve truckers. But that is due to the drivers not having time to do both the organization and the driving job. I barely have time for Youtube anymore.

OTR:

Over The Road

OTR driving normally means you'll be hauling freight to various customers throughout your company's hauling region. It often entails being gone from home for two to three weeks at a time.

SAP:

Substance Abuse Professional

The Substance Abuse Professional (SAP) is a person who evaluates employees who have violated a DOT drug and alcohol program regulation and makes recommendations concerning education, treatment, follow-up testing, and aftercare.

HOS:

Hours Of Service

HOS refers to the logbook hours of service regulations.
Brett Aquila's Comment
member avatar

Ok, we're off and running!

BK, I'm not sure of the answer to any of your questions, but I like the idea of a grassroots effort.

Davy, a few thoughts about your ideas:

basically a representative based structure that is made up of drivers

You're severely limiting your talent pool if it must be current drivers. I'm a retired driver with 31 years in the industry. I have immensely valuable knowledge, experience, industry connections, top-level computer/photo/video skills, and 15 years of running a trucking community that gets over 2 million visits per year. So you don't want to limit yourself to current drivers. Even if you can find drivers with the needed skills, they simply would not have the time to run an organization like this.

Leadership would be elected with term limits so that the organization remains by drivers for drivers.

That would sound nice on a marketing brochure, but in reality, I'm not sure it's the best approach. For starters, this turns it into a democratic organization and all the fun that comes with politics. You would have to find candidates, educate everyone on the candidates, get everyone to agree on what the organization's agenda should be, allow the candidates to campaign, hold the voting, and much more.

Such an organization, that had a focus on education, and fostering top tier drivers would justify the higher labor rates paid to drivers. The carriers would be able to do more with less. It's actually a much higher ROI for them. Walmart obviously has figured this out.

The Walmart thing is a conversation to itself, but to keep it simple, it's not that simple. Highly experienced drivers are not the best candidates for many trucking jobs because lower-level candidates can often do the job just as well for less pay. Just like with anything in life - sometimes it pays to have the best of the best, sometimes you're better off saving money by using lower-level stuff. Walmart would not exclusively hire top-level drivers if they were going to create a general freight division to compete with the likes of Swift, Schneider, and the rest. They wouldn't be competitive. But for hauling their own freight, it's worth having the best drivers because transportation costs are a very small percentage of the cost of running Walmart as a business. So it helps the business as a whole make more money by investing more in high-quality drivers. Their goal isn't to make a profit moving freight. Their goal is to make a profit as a retailer. Our experienced top-tier drivers would provide an incredible value for the right positions.

It would behoove us to bargain rather than simply attempting to force rates higher. In turn, the carriers would be getting something substantial for the expense.

Unions bargain. They don't just force rates. However, management teams at large corporations are not that cooperative when you suggest they hand over some of their salary to the workers.

rofl-3.gif

If they sense there are no consequences for saying no, they'll just say no. Sometimes, you must show you can make life tough for people who treat you unfairly, or they'll continue to treat you unfairly. So unions strike. Well, the local corporations are the ones advertising on the local news, and advertising pays their salaries. So the news backs the large corporations by making the workers seem unreasonable, as if they're forcing the company to comply. It's propaganda.

Anyhow, negotiations get ugly sometimes. That's business. If your negotiations always go easy and you always get what you want, then you're asking for way too little.

I envision an organization that works with carriers and authorities to foster safe professional drivers and practices. The certification standards and process would carry weight....Drivers would be motivated to attain higher certification because it would mean higher pay, psychologically higher status and respect. It's the very definition of performance dictates pay.

Yes to all of that. One thing we can do is educate experienced drivers to be more efficient. Teach drivers a holistic approach to increasing their productivity. It takes everything from nutrition and fitness to time management strategies, stress management, scheduling, getting in and out of customers faster, mastering logbook rules, communicating better with dispatch, and so much more. If we could prove that our drivers are more efficient, more productive, safer, easier to work with, and they stick around longer, then we have a powerful force for positive change.

In a broad sense I have a vision of drivers being a professional highly trained group that are known to be the good guys again. We were once called the Knights of the highway. A living that were proud to be a part of.

A big 'yes' to this as well.

How is the organization set up, ie 501 c3, non profit, etc?

I'm not sure. As a business owner, I'm always thinking about ways to bring people value and then make a profit from the value I provide. I think there's a lot to be said for finding a profitable way to make something happen.

You mentioned a volunteer management structure, but I can't imagine that happening. No one with the know-how to bring a huge amount of value to tons of people will do it for free. Why would they? The job they're doing is making life better for so many people. Don't they deserve to get paid for that, as well? How would it be fair for the members to benefit but not the people who are making it happen?

Maybe that's why you want the organization run by truck drivers, so the management also benefits from it without being paid directly. That leads back to the problem of finding current truck drivers with the time and expertise to run something like this.

This is great because I can see we have different ideas coming in already. I'm thinking about it being more like a business organization. Davy, you're approaching it more from a union perspective. Kearsey, whom I'm about to reply to, is thinking in terms of a lobbying organization because I mentioned being involved in the lawmaking process. BK mentioned a grassroots effort like the farmers have done over the years.

I love it! I wanted everyone to throw their ideas on the table. Let's hear some more! I'm gonna respond to Kearsey now...

Logbook:

A written or electronic record of a driver's duty status which must be maintained at all times. The driver records the amount of time spent driving, on-duty not driving, in the sleeper berth, or off duty. The enforcement of the Hours Of Service Rules (HOS) are based upon the entries put in a driver's logbook.

Brett Aquila's Comment
member avatar

Kearsey:

A lobbying group? Who can influence state & federal laws, as well as trucking companies and truck manufacturers?

Possibly. I've never been involved in lobbying efforts, so I don't know what that would entail, but we obviously belong at the table for any discussions involving the laws that govern trucking or infrastructure.

For instance, it was painfully obvious they had a ton of sleep experts at the table when they created the 14-hour rule, the 30-minute break rule, and the prior sleeper berth rules, but they didn't have everyone they needed because those rules were complete garbage. I knew it was a joke before I finished reading the new regulations for the first time. Most drivers could easily see that they had made a major mistake, but it still took many years to revise the rules back toward their original state. They should have never changed the logbook rules in the first place, but unless you're a truck driver with years of experience, you wouldn't understand the effect it would have.

So it's in everyone's best interest that we have a seat at the table for these discussions.

How would we verify employment and "top tier"? Legally, employers can only say certain things about an employee. If including owner ops.. how would you verify their abilities since they only report to themselves.

None of that would be difficult. There are extensive systems in place to verify identity, past employment, driving record, criminal record, and more if we want to. We can even get social media histories, personality analyses, and all kinds of stuff. We're living in the age of data. It's all out there.

What would be member benefits?

That, of course, is the million-dollar question. Literally. What would be the point of our existence, and what would be the financial model?

When you assemble a large group of top performers, you have a powerful force. I don't care what area of our society you're in - family life, education, business, sports, politics - an organized group of the top performers is powerful.

So, what is the best use of our strengths?

Kearsey asked:

What "training" would be better than what companies already do on the equipment which they drive?

As an entrepreneur, I always ask this question: What can I build that would create far more value than it would cost to produce?

Well, we can build an online training program to educate our drivers. I'll just copy/paste my previous description:

Teach drivers a holistic approach to increasing their productivity and improving their lives. Includes everything from nutrition and fitness to time management strategies, stress management, scheduling, getting in and out of customers faster, mastering logbook rules, communicating better with dispatch, managing your relationships at home, working through challenges with your employer, and so much more.

We can also build a strong online community (like this one) to exchange ideas and support drivers throughout their careers.

Our drivers will be healthier, safer, more productive, more efficient, easier to work with, and they'll change jobs less often. If we can prove that our drivers help trucking companies make more money and provide better service, they'll gladly pay for that. Just giving them access to a group of high-level, experienced drivers is immensely valuable, even if we provide no training. But add our training to it, and now you have something powerful.

In this model, everyone wins. The trucking companies and their customers, as well as our drivers and our organization. We all win in this scenario. No one makes enemies, no one gets hurt.

I consider this the only type of business model I would participate in. I would never participate in a predatory business. I'm a very competitive person, but not a confrontational person by nature. I love to compete, but I don't want war.

So Kearsey, when you said "lobbying group" my eyes got wide for a moment. I pictured myself in Washington wearing a suit and threw up a little in my mouth. But you're right. If we wanted to be included in lawmaking decisions, we'd have to wiggle our way to the table in Washington. I have zero knowledge or experience in that area, so I would love to learn more about that.

We could lobby as part of our mission, as well. It doesn't have to be the core of what we do, but one of the many services we provide.

So, would we be a lobbying group? An educational organization? A business organization? A non-profit? I'd say it's all on the table, and we could end up a mix.

My nature is to approach things from a business perspective because I like being able to knock on someone's door and say, "I have an idea that will improve your life, and you'll get more from it than it will cost."

Competing in business when you're providing great value is a fun way to live. I enjoy it. What I don't want is courtroom battles, political fights, or enemies.

Logbook:

A written or electronic record of a driver's duty status which must be maintained at all times. The driver records the amount of time spent driving, on-duty not driving, in the sleeper berth, or off duty. The enforcement of the Hours Of Service Rules (HOS) are based upon the entries put in a driver's logbook.

Sleeper Berth:

The portion of the tractor behind the seats which acts as the "living space" for the driver. It generally contains a bed (or bunk beds), cabinets, lights, temperature control knobs, and 12 volt plugs for power.

HOS:

Hours Of Service

HOS refers to the logbook hours of service regulations.
Brett Aquila's Comment
member avatar

Kearsey said:

Push for some sort of tax break to allow truck parking at businesses

Damn, that's a great idea!

See, this is the business perspective I love. This resonates with me. People like to hear feel-good stories on TV, but profits make the world go round. If you can prove it makes financial sense to do something, it's easy to get behind. I could support ideas like this.

Small aside here: you can't believe how many websites email me daily saying, "Would you put a link to our website? It would help us a lot and we'd appreciate it!"

Yeah, I'm sure you would. Yet, it never crossed their mind to even pretend I would get any benefit from helping them. It's amazing how many business people wake up each day asking, "What can I do to get more from people?" instead of "What can I do to provide more value for people?"

This organization, or any organization I'm part of, should easily be able to demonstrate that we're providing far more value than we're asking in return.

Perhaps interview various companies and see what training programs work and what do not. Analyze them all. Then come up with a program that utilizes all of it.

With input from many top-tier drivers and companies, we would build incredibly powerful programs. I believe the drivers who went through our programs would stand out to such a degree that every company would want to put their drivers through it for a small fee or hire our drivers for a better wage.

Again, it's a simple business proposition. If you use our programs and hire our drivers, you'll make more money. No one gets mad at you for helping them make more money.

"We were once called the Knights of the highway"

This is strange to me cause i never heard this until i came OTR and only by truckers

This was before my time in trucking, as well, but the old-timers told me the stories. Here's the short version for those who are interested:

We were called Knights of the Highway back in the '40s through the '60s. Back then, most drivers were owner-operators and worked on their own trucks. You didn't have the vast network of tow trucks and repair shops connected by satellites and cell phones. If you broke down, you tried to fix it yourself. If you couldn't, you hoped someone might come along to help.

So it wasn't uncommon to see small groups of cars and trucks on the side of the road working together on a repair. Almost everyone carried tools and spare parts, so someone was bound to have what you needed, or someone would go pick it up.

We were called Knights of the Highway because truckers were the most capable and willing mechanics on the road. If you broke down in your car and you saw a truck coming, chances are help is on the way. You could almost certainly count on a ride if a repair wasn't possible.

Once commercial towing and repair services became more common and trucks more complex, people started relying more on commercial services and less on each other, which allowed drivers to focus more on running their businesses competitively.

Later still, when they deregulated trucking in 1980, the highways became hyper-competitive. Now, you had to hustle if you wanted to make any money, so the competitiveness skyrocketed. The trucking industry remains hyper-competitive to this day.

The old days on the highways were more a matter of survival, so everyone pitched in and worked together. But life on the highway became far more competitive as technology and business regulations changed, not to mention more dangerous as thieves found more clever ways to target people willing to stop and help.

OTR:

Over The Road

OTR driving normally means you'll be hauling freight to various customers throughout your company's hauling region. It often entails being gone from home for two to three weeks at a time.

HOS:

Hours Of Service

HOS refers to the logbook hours of service regulations.

OWI:

Operating While Intoxicated

BK's Comment
member avatar

Also, the qualification of “no preventables, perfect CSA score”…etc, is not realistic. Too limiting. Sometimes the best people at their jobs are ones who have made mistakes and learned from them. That’s a positive leadership quality for a person to have.

CSA:

Compliance, Safety, Accountability (CSA)

The CSA is a Federal Motor Carrier Safety Administration (FMCSA) initiative to improve large truck and bus safety and ultimately reduce crashes, injuries, and fatalities that are related to commercial motor vehicle

Trucker Kearsey 's Comment
member avatar

Now you are sounding like a consulting firm. And definitely not a non profit. The companies that could afford consulting would be the megas... and many already have driver advisory boards, like Prime does, to give input and feedback. And those people know the company's procedures. Although... many already have firms conduct surveys... but i never heard of a company doing in house interviews at terminals. We have reps from various vendors come to prime all the time. So perhaps offer a brainstorming session with their own drivers. Have a model of questions to ask.

It couldn't be like a hiring agency, because the background checks have to be done within 30 days of a start date. So it couldn't be like "hey... stop paying for recruting money, background checks, ads and MATS tables... we got the people here." You could charge the companies a monthly fee for membership to advertise on our site. Broken down by division. Some kind of statistics with what drivers want and need... be a resource for them.

But hell yeah, i would go to washington and the first thing i would do is make AOC cry.

Lobbyists get paid by a client who wants something. Think NRA memberships... FOP memeberships.. that means the money comes from the truckers. Unless you lobby for clients such as truck makers, trucking companies themselves. Prime has its own inhouse counsel and lobbying board. I am sure most do.

One problem with this... is you have to go from."top tier drivers" running it to "former drivers". Drivers don't like that. Sorry. One reason that WIT isn't popular with a lot of women, there are too many former drivers or non drivers calling the shots. You need non drivers with corporate expertise to navigate certain aspects and details. They feel as though they are a part of the industry... but drivers think.."witch you have never backed a truck...or havent in a decade." So rival groups like "real women of trucking" or "women in motion" spring up.

Terminal:

A facility where trucking companies operate out of, or their "home base" if you will. A lot of major companies have multiple terminals around the country which usually consist of the main office building, a drop lot for trailers, and sometimes a repair shop and wash facilities.

HOS:

Hours Of Service

HOS refers to the logbook hours of service regulations.
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