The thing I never got was how the DOT hours of service grouped package drivers with feeders and over the road drivers.
The rules make sense when you consider long hours driving between points like tractor trailer driving.
But, when you consider the amount of boxes we have to deliver and pick up, the continuous getting on/off the vehicle, and basically the pure physicality of the job in the elements, you'd think that the DOT would group us separately in another tier.
Driving a trailer 60 hours and delivering in a package car 60 hours do not compare at all.
Both have different mental and physical obstacles that shouldn't be affiliated with each other.
I always think about this when I have to sign the DOT hours of service annual paperwork.
395.1 (e) (2) is your other tier, and they don't really emphasize that in your annual HOS certification. It pretty much throws out the 11 hour driving limit. If you were to fill out a logbook for package it should look like this:
8:00 on duty not driving
8:15 on duty, driving
12:15 on duty, not driving (Break, and yes this should be recorded as "off duty" but they don't get that right either)
12:30 off duty (meal)
1:00 on duty, not driving (Break again, and isn't it annoying that the logbooks don't do the 24 hour clock?)
1:15 on duty driving
9:45 on duty, not driving
10:00 off duty (14th hour)
You just had 12.5 hours of driving time, more if you worked up to 16 hours. Most SPARKS reports I've looked at showed more driving time between stops than time spent at stops in Residential areas, so the logic that you're spending more time not driving in Package is flawed especially with the increasing number of stops per car.
You're right about Package being fatiguing in a different sort of way. In Feeders you mostly have rather long stretches of driving periods of 1-5 hours at a time which can easily lead you to fall asleep at the wheel. Package has whatever the return to building stretch is for a particular route (which can also have the same catastrophic result IMO in a warm package car without a/c) but also many more minor operations in driving the vehicle that fatigue could be the cause of an accident. In the summer especially the drain of the long hot day compounding your normal workload many times made me feel so fatigued that I shouldn't have been driving.
Unfortunately, I'm not aware of any comments other than my own being submitted to the FMCSA during the comment period for the new rules on this issue so the matter remains unaddressed.