Executive Summary, 17-Hour Clock Rule, Rule Proposal

Executive Summary: 17-Hour Clock Rule Proposal
To: FMCSA Policy Review Team / Industry Stakeholders
From: Hiram Oliver, Founder – Trapped by the Clock Campaign
Subject: Proposal for Pilot Implementation of the 17-Hour Clock Rule
Date: February 18, 2025

Dear FMCSA Review Board,
 

The current 14-hour Hours-of-Service (HOS) rule, while designed to manage fatigue and improve safety, has proven to be rigid, outdated, and counterproductive in the face of real-world conditions. Drivers are often forced to operate under pressure, battling fatigue, unpredictable delays, and tight schedules—all while a non-stop clock runs against them.
 

We propose the 17-Hour Clock Rule, a flexible, driver-centered alternative that prioritizes safety without sacrificing productivity. This rule introduces a pausable duty clock, minute-by-minute restoration during sleeper berth use, and a rolling 24-hour sleep compliance threshold to ensure drivers are well-rested and alert when operating.

The 17-Hour Clock Rule is built on four core components:

• Off-Duty Clock Pause – When a driver is off-duty, the 17-hour duty clock pauses.
• Sleeper Berth Time Restoration – When in the sleeper berth, the duty clock is restored minute by minute.
• 2-Hour On-Duty Allowance – The 17-hour duty period includes time for essential non-driving tasks such as inspections, fueling, and paperwork. While drivers may not always use the full two hours, the system structurally accounts for it to ensure safety and compliance are not sacrificed.
• 15-Hour Driving Limit in a Rolling 24-Hour Period – Drivers may not exceed 15 hours of driving within any rolling 24-hour window, regardless of restored duty time.

Supported by both sleep science and real trucker feedback, this system empowers drivers with flexibility, promotes safer roads, and builds long-term sustainability for the industry. Our proposal includes a detailed policy framework, safety justification, visual examples, and 50 real-world Q&As from working drivers across platforms.
We respectfully request FMCSA’s consideration of this model as a pilot program, to be tested with voluntary participants across a range of carrier types and haul categories.

It’s time to give drivers a system built around real rest, real schedules, and real life.

Let’s fix the clock—together.
 

Sincerely,
Hiram Oliver
Founder – Trapped by the Clock

Sleeper Berth Time & Clock Restoration
How rest restores time, and how the 6-hour sleeper requirement keeps drivers fresh.

Off-Duty Time & Clock Pausing
Why true off-duty time pauses the clock without penalty—and how it helps.

The 2-Hour On-Duty Time Framework
Making room for inspections, fueling, and workflow without punishing productivity.

15-Hour Drive Time Limit (Rolling 24-Hour Period)
How the system prevents fatigue and abuse while giving drivers back their control.

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