A tired approach

Are HOS and EOBRs a dead end?

We continue to wait for final resolution on hours-of-service rules and related requirements for electronic logs, two issues that seem to defy closure. They’ll be here one day soon, we’re assured, but when they do get here, will drivers be less fatigued and will trucking be safer? Or will all this effort and argument prove to be an enormous waste of time and money?

There is an underlying problem with HOS that regulators seem unwilling to confront in any meaningful way. HOS rules control the number of hours drivers can work and the number they must rest. To some degree they also prescribe when those rest hours must occur. Anything outside of those prescribed parameters is a violation that is legally presumed to negatively impact a driver’s fitness to work.

This results in a fatigue management scheme that’s fairly easy to administer — input the hours driving and not driving, then penalize anything that falls outside of the rules you’ve set up. But does it really improve truck safety by minimizing driver fatigue? Probably not if you believe the research over the last few decades, research that’s already changing the way other industries like rail and pipeline transportation manage worker fatigue.

What these and other 24/7 industries have begun adopting is generally called a fatigue risk management system (FRMS). It is a scientifically based system that acknowledges hours worked is just one factor, an imprecise one, that may be easy for regulators to measure, but that doesn’t tell the real story about an individual’s level of fatigue. Instead FRMS focuses on measurable factors like fatigue-related accident records and actual fatigue levels, factors that are directly related to the problem.

One of the leaders in this research, Circadian Information, identifies eight factors it believes are critical to an effective FRMS. It has to be based on peer-reviewed science; decisions have to be based on the collection and objective analysis of data; everyone involved has to be part of the development; it should be integrated with overall safety and health programs; the goal should be continuous improvement incorporating feedback, evaluation and modification; it should provide a real ROI; and commitment to the program needs to start at the highest levels of company management.

So while an FRMS looks at hours worked, it also needs to include analysis of sleep/work patterns based on time of day, constant monitoring of fatigue-related accidents, fatigue management training for both managers and drivers, and a company environment that holds everyone responsible for reducing those accident records.

Clearly, this is a much more complicated process than simply filling out driver logs and auditing them, simpler for both fleets and regulators. But it’s not impractical.

Dupré Transport, for example, is a tank carrier that has been working with Circadian on an FRMS as part of an overall safety program since 2000. Within three years it had decreased its highway accident rate by 69%, and it now has recorded over 400 million miles using this approach. And there are other carriers working with Circadian and similar providers to institute and maintain effective FRMS programs.

The issue for regulators is that compared to HOS, there’s no simple way to record and enforce FRMS compliance using current techniques like roadside inspections and log audits. What’s needed is a change in mind-set—enforcement based on actual results (i.e., accident records) rather than prescribed work rules and recordkeeping violations. That’s a big change

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