Maybe I’m making too much of this (time will tell), but I think the winds of change are beginning to blow in the hours-of-service world. I recently attended the International Conference on Fatigue Management in Transport Operations in Seattle. Speaker after academic speaker presented recent research into fatigue: its causes and effects, as well as ways of reducing fatigue-related crashes.
There seems to be an emerging consensus that prescriptive hours-of-work rules (set start and finish times, with minimums of rest) don’t work. The original objective of HOS was to limit the physical fatigue that resulted from driving those early trucks. It was thought, in the 1930s, that limiting the time drivers spent behind the wheel would minimize fatigue.
We know, now, that fatigue-related crashes are more the result of mental fatigue than physical. And we know that the causes and recovery process of mental fatigue are quite different than those of physical fatigue, but we’re still working with rules that don’t recognize the difference.
So how do you “regulate” fatigue? There’s no objective measurement or test; individuals are susceptible to fatigue in varying degrees and no two persons are the same. It’s been proven that our own abilities to assess personal fatigue levels are poor at best. It’s also recognized that the only reliable cure for fatigue is sleep, but the rules don’t (and can’t) mandate sleep time – just off-duty time. Should we be regulating sleep, or finding a better way to ensure drivers get the rest they need without compromising productivity and earnings?
Having said all that, there’s a movement afoot that could soon see fatigue managed rather than regulated.
Dr. Jillian Dorrian of The Centre for Sleep Research at the University of South Australia presented an interesting paper at the conference. She documented the amount of sleep obtained by drivers in 24- and 48-hour periods immediately preceding actual truck accidents, and used those measurements to predict the likelihood of another group of accidents being fatigue related. Her findings were clear: recent sleep/wake history is a significant predictor of fatigue-related accidents.
She suggested that drivers might be allowed to work an amount of time less than or equal to the amount of sleep they had obtained during the previous 48 hours, which would be an easy way to calculate available working hours. But that’s only one version of a so-called fatigue management plan.
FMCSA has begun working with Transport Canada on other schemes. Alberta has had a pilot project running for the past three years that shows promise, and it will be the focus of the bilateral collaboration between the two regulatory agencies.
True fatigue management programs would come with something we don’t have now: comprehensive training on all aspects of fatigue, personal health and wellness, and time management. Our current system is compliance based; therefore the training we get is generally focused on complying with the rules rather than getting the rest we need. I maintain that the two are not always the same.
I presented a paper at that conference, too, co-authored by Joanne Ritchie of OBAC. It illustrated how strict regulatory compliance can actually reduce safety by forcing drivers into un-natural sleep cycles, and by requiring drivers to choose between making money, meeting customer demands, and following the rules. We used survey information from her members about how they balance those demands, and we concluded that sleep usually suffers.
If we’re to make any real progress in reducing the number of fatigue-related accidents, we need to be allowed to manage our sleep/wake times in a way that meets our personal needs. The regulatory requirements should ensure that, rather than inhibit it.
I returned from the conference optimistic that we’re onto something new and good with fatigue management. The scientists seem to be there. I hope now that our regulators have the wisdom to follow suit.