Greyhound Lines Hours-of-Service Waiver - 395.8(c)

Greyhound drivers operating commercial passenger buses on intercity regular route service are being given level III inspections and are written up for not noting location stops and times of less than 15 minutes on their logs in violation of 395.8(c) when they are dropping off or picking up passengers or freight.

The DOT regulation says all stops of less than fifteen minutes have to have a line drawn down to indicate the stop and time spent at the stop even if a change of duty status is not required 395.8(c). However, Greyhound received a waiver on this requirement for periods of less than 10 minutes on its regular route service based on an interpretation letter from the DOT in 1996. The interpretation and waiver was reinforced again in 2000. Based on this waiver and interpretation Greyhound drivers on regular route runs should not be cited for a violation of their driver logs.

It is requested that the CVSA oommittees for Passenger Carrier, Driver-Traffic Enforcement, Training and Executive Committees review this waiver and honor this interpretation as it applies to regular route passenger common carrier CMV drivers.