Compliance, Safety, Accountability (CSA)

Lubana supports the objectives of CSA: the use of performance-based data to create real-time carrier safety measurements and to better identify unsafe behaviour. 

Electronic Logging Devices

We support laws and regulations requiring the use of electronic logging devices (ELDs) for documenting compliance with hours-of-service (HOS) rules. Such requirements should based on the minimal, functional, and performance specifications necessary to accurately record hours-of-service compliance, retain existing record of duty status exceptions, provide relief from supporting document requirements.

Hours of Service

At Lubana we support science-based hours of service regulations that promote the effective management of driver fatigue and do not merely dictate a maximum number of working hours. Hours of service regulations should offer operational flexibility while promoting highway safety; be consistent with scientific principles relating to fatigue, rest and recovery; address the needs of all industry segments; be cost-effective; and be easy to understand, comply with, and enforce.

Medical Qualifications

We support sound minimum medical requirements for ensuring that those with conditions that inhibit the safe operation of commercial motor vehicles are prohibited from driving. 

Drug and Alcohol Testing

Lubana is a strong advocate of mandatory testing of commercial motor vehicle operators for drug and alcohol use. Also, allowing the use of alternative specimens, such as hair, to comply with federal drug testing requirements. 

Driver Training and Licensing

We support national, uniform, performance-based commercial driver’s licensing testing standards. Also, the federal government should require state adoption of stronger CDL skills testing standards that reflect actual on-road driving requirements. Lubana believes entry-level driver training should be focused on minimum, competency-based requirements consisting of both, classroom and behind-the-wheel training.