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Frack sand trailers and the “wait time” exception for drivers of specialized oilfield equipment.

Recently, industry presented a compelling argument that sand vehicles used in fracking operations (frack sand trucks) should be considered specialized oilfield equipment because they fit the criteria in paragraph 1 of Regulatory Guidance Question 8, as follows: (1) specially constructed for use at oil and gas well sites, and (2) for which the operators require extensive training in the operation of the complex equipment, in addition to driving the vehicle.

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