DRIVER SERIES: PART 3
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PREVENTING
DRIVER FATIGUE Don’t focus so much on hours of service compliance and electronic logging devices that you fail to address the underlying causes of drowsy driving. By Jim Park Equipment Editor
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hile fatigue and hours of service are frequently used in the same sentence, there’s often just a very tenuous connection between the two. Drivers and fleets work hard to comply with the rules, but are they actually doing anything to address driver fatigue? It’s being tired that puts truck drivers at risk, not running 10 minutes past the deadline for their 30-minute break. “You’re not going to turn into a pumpkin as the eighth hour ticks over,” says Ron Knipling, noted fatigue and truck safety researcher and author of the truck-safety textbook, Safety for the Long Haul. “The way to approach fatigue management is in terms of health, diet, exercise, lifestyle and conscientious self-management; not externally imposed rules.” One problem fleets and drivers face with fatigue is that compliance with the hours of service rules is not optional — but fatigue management education is. So money, effort, 46
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and time for proper fatigue management education for drivers may take a back seat to compliance training — how to manage hours, how to work the electronic logging device, how to cope with the parking shortage. That can leave drivers in the dark on how to manage the real problem: fatigue. Research from the National Institute for Occupational Safety and Health shows that over 30% of American workers aged 30-64 are short of sleep. The National Sleep Foundation recommends that healthy adults sleep seven to nine hours per day, but a recent survey found that 30% of civilian-employed adults (approximately 40.6 million workers) reported average sleep duration of six hours or less per day. It’s not known precisely where the truck driver population sits in terms actual hours of sleep per day, but it’s probably statistically similar, if not worse. The current HOS rules require 10 hours off duty before driving, eight of which must be in the sleeper berth — but they do not and cannot mandate that drivers actually sleep for the seven to nine recommended hours.
To use Knipling’s term, conscientious selfmanagement compels most drivers to get as much sleep as they can within their offduty period, but not everyone can sleep at a given time of the day. Nor can anyone be assured of a full restful sleep if they have stuff on their minds or some physical or medical issue preventing them from getting proper sleep. Obviously, noisy parking lots or sleeping in a dangerous area can affect the quality of sleep. Short sleep leads inexorably to drowsy driving. The real problem is not that the driver didn’t get enough rest, but failing to recognize that likelihood and to build a little slack into the plan to account for it. “Even among healthy individuals there’s a huge difference in how susceptible people are to drowsiness,” Knipling says. “Some people have no difficulty staying alert all day long, whereas others can really benefit from a mid-day nap. It all depends on their individual patterns of sleep and wakefulness and their susceptibility to drowsiness.” According to Knipling, aside from WWW.TRUCKINGINFO.COM
possible medical issues such as obstructive sleep apnea, the top four predictors of individual sleepiness are: ● individual susceptibility ● the previous amount of sleep ● time of day ● elapsed time since the previous sleep. “We now have a requirement that drivers take a 30-minute break some time before the end of the eighth hour on duty, but that’s not really a practical solution,” Knipling says. “There needs to be more widespread recognition within the industry that being tired and taking breaks and napping are normal parts of people’s lives.”
Fatigue management Drivers taught to recognize the hazards of a poor night sleep can take steps to mitigate the shortfall by napping during the day or requesting a lighter dispatch. Fleets that embrace a fatigue management approach would be likely to accommodate such a driver. But that’s certainly not all fleets. What would you say to a driver who told you that he didn’t sleep well last night and he’s not confident that he’ll make a scheduled delivery because he may have to sleep during the day to remain safe? What do you say to a driver who says she is just too tired to complete a run or make a scheduled appointment? We addressed that question to Steven Garrish, senior vice president of safety and regulatory compliance at SleepSafe Drivers, a company that provides fatigue management and sleep apnea treatments for trucking and other industries. “That doesn’t happen very often,” he said with a chuckle. “In this industry’s culture it’s certainly not very macho to admit you’re tired. But I’d say the best, most forward-looking companies would regard the driver as the captain of the ship and will usually defer to the driver’s judgment on being tired. [Regulations prohibit drivers from driving or fleets forcing them to drive if they do not feel up to it, or if they are ill or fatigued.] So, the company has to take the driver at his or her word and let them rest. “The thing to do is to watch for patterns, to see if this happens frequently with that driver, and if so, to find out why. You don’t want to fire somebody who is having problems, and the better companies are usually willing to try to get to the bottom of the problem.” There could be any number of issues. Maybe it’s obstructive sleep apnea. Maybe he’s having some problems at home or financially that are literally keeping him awake at night. He might be soldiering on because he doesn’t want his income to suffer. “Of course, if you discover that he’s always booking off early on Friday, or not getting the work done on Monday after a weekend, then maybe there are other issues that need WWW.TRUCKINGINFO.COM
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DRIVER SERIES: FATIGUE PHOTO: JIM PARK
Driving at night can be challenging because of the body’s biologically hardwired tendency to sleep when it’s dark. Lighter traffic densities, however, mean it’s statistically safer.
to be dealt with,” Garrish adds. “And that could certainly involve discipline.” It’s important to note that fatigued doesn’t necessarily mean asleep at the wheel. Drowsiness, feeling sleepy, and briefly inattentive behavior are all manifestations of fatigue resulting from any of the four predictors mentioned above. And all it takes sometimes is a moment of inattention to cause a crash. What’s Knipling’s advice for drivers? “Manage the risk factors,” he says. “Try to get as much sleep as you can, be mindful of the time of day as it relates to personal circadian rhythms, consider how long it has been since you last slept and how good a sleep you had previously.” You can learn more about fatigue management through the North American Fatigue Management program, released in 2013 and developed jointly by the Federal Motor Carrier Safety Administration, Transport Canada, several state and provincial
WHERE DID THE HOURS OF SERVICE RULES COME FROM, ANYWAY? How the hours of service rules for truck drivers ever became a safety regulation is a question that has vexed many in the industry. The rules came into being in the 1930s as a combination of labor and economic regulation intended to bring some stability to the nascent trucking industry, and to protect workers from overly demanding employers. There were few rules to speak of at the time, and little was known scientifically about fatigue, sleep, driver performance, or crash causation. The earliest regulations requiring rest for truck drivers, circa 1935, allowed drivers to work 12 hours within a 15-hour period while requiring nine hours of rest and three hours of breaks within a 24-hour day. That rule also established a weekly maximum of 60 hours onduty over seven consecutive days. Sound familiar? A few years later, organized labor petitioned trucking’s regulator, the Interstate Commerce Commission, for a reduction in the hours drivers were required to work, proposing an eight-hour daily limit and 48-hour weekly limit. The ICC, lacking any specific knowledge on the matter, asked the U.S. Public Health Service in 1938 to investigate truck driver hours of work. The resulting report was not very conclusive, but it did note, “... a reasonable limitation of the HOS would ... act in the interest of highway safety.” The rules would not change substantially until 1962, when the ICC eliminated the 24-hour framework and replaced it with a rotation that allowed the driver to drive up to 10 hours within a 15-hour period before being required to take eight hours off. The net effect allowed the work/sleep rotation to slip to as short as 16 hours. This meant drivers could get across the country in fewer days, but they would find themselves with no hours left in their 60-hour, sevenday cycles within five or six days. The split sleeper-berth provision was added in the mid-1960s,
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which allowed drivers to split their sleeper time into two periods. This meant some would log formerly “clock-running” on-duty time as sleeper time, regardless of whether they were in the sleeper resting or not. By the late 1960s, as highways grew more crowded, the number of truck crashes was rising, and several safety groups began calling on government to do something to prevent the carnage. They claimed truck driver fatigue was at the root of many crashes and called for changes to the drivers’ HOS rules. This prompted the first scientific analysis of driver fatigue. Three studies would be conducted in the 1970s that did note a causal relationship between fatigue and truck crashes, but the results were not conclusive enough to justify changes proposed in 1979 by the U.S. Department of Transportation. The HOS rules would remain fundamentally unchanged for almost 60 years until 1995, when Congress directed the DOT to establish a new set of HOS rules incorporating the latest scientific understanding of human fatigue and alertness. DOT published a new rule in 2003 that, again, merely tweaked the rule. Those, and subsequent changes to HOS up to the present, have statistically done little to lower truck crash rates. While many in the industry complain that they did succeed in limiting trucking’s productivity and drivers’ ability to rest when they needed to rest, critics say the rule changes have not addressed the suspected problem of truck driver fatigue as it relates to crashes and to driver well-being. Depending on which of the fatigue experts you believe, the various HOS rules developed over the past 80 years have increased driver fatigue while limiting opportunities for rest, have increased drivers’ alertness but could still be improved upon to reduce crashes, or, have done little to meaningfully reduce truck crash rates.
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DRIVER SERIES: FATIGUE trucking associations, insurance companies and several high-profile motor carriers. There is no charge for the program, and it features instruction modules for drivers, operations personnel, driver spouses and others. It’s available here: www.nafmp.com. Mark Murrell, a co-founder of CarriersEdge and co-creator of the Best Fleets to Drive For program, says in his evaluations of various fleets, he has seen growing attention to programs such as fatigue management for drivers. “The smarter fleets are stepping up and figuring out ways to help look after their drivers,” he says. “They are using fatigue management programs to help drivers realize their potential without putting all the emphasis for performance on the driver. Helping drivers understand what makes them tired, like maybe they aren’t at their best early in the morning, can help in scheduling them on more physiologically compatible operations.”
Old problem, modern solution
PHOTO: JIM PARK
Grabbing a quick nap during a driving shift is a good way to restore alertness. Scheduling should allow drivers time to nap.
Without ignoring the cornerstones of fatigue management, several technologies are proving useful in preventing crashes related to fatigue. According to Knipling, the most useful might be perclose eyelid monitoring systems that record the reflection of
DEALING WITH OBSTRUCTIVE SLEEP APNEA The Federal Motor Carrier Safety Association suspects that about 28% of the commercial driver population may be suffering from some degree of obstructive sleep apnea. That number is in line with the findings of SleepSafe Drivers Inc. Steven Garrish, the company’s senior vice president of safety and regulatory compliance, says that number is in line with his fleet testing. “When we begin a managed program for a fleet, we’ll see about 10% of that fleet’s drivers test positive for sleep apnea in year one,” he says. “In year two, we’ll see another 8-10%, with the other 8% or so in the third year moving forward.” This happens over time because the medical card process involves a maximum two-year cycle. For a fleet of 100 drivers, that would be 10 in the first year, 10 or so in the 2nd year, then 8 and less moving forward, he says. “After this initial cycle, we just test new drivers through the turnover process and treat the incumbent fleet.” OSA needn’t be a career-limiting condition for drivers. With recognition and ongoing treatment, the drivers are fit for duty, and in all likelihood, less fatigued than they were before treatment. But without a managed OSA/Fatigue Management Program, the process is a pain, with the burden falling on the driver for most of the
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expense, Garrish says. “It’s often a long process as well, taking several weeks to get in to see a sleep specialist and then schedule an in-lab test. Even for the lucky ones who have medical insurance, they often have highdeductible plans, so much of the expense comes right out of the driver’s pockets.” Many forward-leaning, safety-conscious fleets are redirecting their current insurance spend for OSA and putting these dollars towards a directly managed OSA/Fatigue Management Program that eliminates wait time and expenses. A cornerstone to saving time and cost involves the use of home sleep tests, which can be performed right away, allowing the driver to wear the device in the comfort of his/her own home or truck. These tests are a fraction of the cost of a typical insurance-ordered in-lab test. But the treatment shouldn’t end with supplying the driver with a continuous positive air pressure (CPAP) device. Follow-up is vital. “Without coaching and support, typical insurance programs only yield 51% compliance,” says Garrish. “All my drivers are 97% compliant with therapy, which translates into lower crash and injury risk, reduced healthcare costs and long-term health and well-being.”
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ing awake the night before a shift. Or never considered the cumulative effect of commuting back and forth to work and spending a little time with the family. That can be a scheduling issue, but drivers need to know about the effects of short sleeps and how that can affect their alertness later in the day. You have to teach drivers this stuff. It’s Fatigue Management 101. A lot of drivers, especially the older ones, treat these problems as just part of the job, the way it has always been. That’s not the right way to look at it anymore. The company can be supportive of the problems drivers may be having, and some willingness to try to solve them can lead to safer, healthier, and happier drivers.
This wraps up our three-part driver series. For the other two installments and additional information on drivers, go to www.truckinginfo.com/Driver2018.
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dilemma: What do you do when drivers have an asleep-at-the-wheel event or even a nodding-off moment? “In some cases, the kneejerk reaction is to fire the driver,” says Garrish. “Is that really the purpose of the technology? The other approach can be to use it as a training tool without disciplining the driver. I don’t think that’s the right approach, either.” Instead, he says, the right approach for forward-looking fleets is to investigate what happened. “Can we rule out a medical condition such as OSA? A test might be required. Was it a scheduling issue? Was the driver having difficulty getting his needed rest? Were there issues at home that prevented proper sleep? Has this sort of thing happened before and what was the driver’s response that time?” asks Garrish. Most drivers have an intrinsic sense of self-preservation, and they want to keep earning money for their families. They don’t want to fall asleep and crash. Maybe they never considered the implications of stay-
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the surface of the eyeball on a camera that can detect the brightness. If the eyelid closes, the reflection dims, triggering a warning. “Pupil measurement (eye closure) combined with lane tracking devices could provide a couple of different forms of feedback,” he says. “They could provide a general status advisory. They could also show, for example, that you have a normal reading of, say, 90, but you’re now at 70. That could indicate a lower level of alertness. They can probably be pretty effective, but people would have to want to use them.” Knipling has also explored the use of wearable devices that claim to measure the quality of a night’s sleep by recording body movement while sleeping. “They could be used as an indicator of the quality of sleep you had, but the measurements tend to be crude because they do not account for individual differences in the need for sleep or the physiology of sleep,” he says. Driver-facing cameras could be useful when used properly, but they can pose a
ELD DATA MAY HELP DRIVE HOURS OF SERVICE REFORM For truckers, it’s the Holy Grail of regulatory reform. Who would not want to see the hours of service rules more closely reflect the real world of driving trucks? And what if a more realistic set of regs further improved safety? But right now, there is no indication any changes are in the works for HOS rules, on the regulatory or legislative fronts. Yet that doesn’t mean trucking should shrug off any hope for change. “Remember, we, as an industry, are just a few months into an ELD mandate that is already beginning to accurately portray the trials and tribulations of the daily life of truckers,” contends David Heller, vice president of government affairs for the Truckload Carriers Association. “In other words, our drivers’ daily logs are more accurate than they have ever been. That’s highlighting problems such as the 14hour clock and its inability to stop when taking a break and the ongoing detention problem. “These problems, over time, will worsen to the point that the Federal Motor Carrier Safety Administration will have to address some of them in order to critically enhance safety performance on our roadways,” he continues. A recent report by the Department of Transportation’s Office of Attorney General found that detention time is estimated to increase truck crash rates and may reduce driver and carrier income by about $1 billion annually. “If FMCSA turns its cheek on an issue that is estimated to increase crash rates, then they would be ignoring the very premise on which the agency was founded: ‘to prevent commercial motor vehicle-related fatalities and injuries.’” Heller points out that the issue of fatigue is always part of discussions to change HOS. For truckload carriers, a key topic is finding ways
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to incorporate flexibility in the sleeper berth rules. “The inability to stop the on-duty clock once it starts continues to stymie true productivity, and often the results are problematic for drivers. Sure, the short answer is almost always, ‘When you get tired, pull off the road and take a nap.’ The reality is that our driver operates in an 80,000-pound office and that is easier said than done. In a nutshell, obtaining greater flexibility in the sleeper berth or advocating for the opportunity to stop that 14-hour on-duty clock would make a dramatic impact in our drivers’ lives.” FMCSA has been slated to take part in a pilot program to study the effects of sleeper berth flexibility for some time now, Heller notes. The pilot should start soon, with the majority of the data collection to begin this summer and conclude in summer of 2019. “Even FMCSA has acknowledged that recent research indicates that the total amount of sleep in a 24-hour period is more important than accumulating sleep in just one period for mitigating fatigue,” Heller says. Current hours-of-service rules allow drivers to take eight hours of consecutive sleeper berth time, and the additional two hours of mandated rest may be taken as off-duty or sleeper berth time. The pilot program is preparing drivers to split their sleep into two periods, with each period being greater than two hours. Neither sleeper berth period will count toward the 14-hour on-duty clock. “We, as an industry, have long advocated for this change in order to provide our drivers ample time to split up their day to address for detention, traffic, weather or any other obstacle that may impede their ability to deliver freight.” —David Cullen
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