Back in May I attended a presentation by Dave Osiecki, senior vice president of the American Trucking Associations, where he said that an Electronic On-Board Recorder mandate for all interstate trucks for Hours of Service recordkeeping would be a race by Congress and the Federal Motor Carriers Safety Administration.
Speaking in Little Rock during the Arkansas Trucking Association’s annual meeting, he said that Congress would install the mandate in the Highway Bill.
He was right that Congress would pressure the Department of Transportation to do something, although it didn’t arrive in the Highway Bill. Instead, on Sept. 29 Senators Mark Pryor, D-Ark., and Lamar Alexander, R-Tenn., announced a bill that would mandate EOBRs for HOS in all interstate trucks. (See story page 1.) In addition, the two Senators were joined by an Alliance for Driver Safety & Security, comprising five trucking companies with more to possibly come on board. Those initial companies were: Maverick USA; Knight Transportation; J.B. Hunt Transport Services; Schneider National; and U.S. Xpress.
Congress is in recess until after the November elections and more than likely the bill will have to be reintroduced next year. And as for the race to the mandate, it’s not likely FMCSA will issue one before that as it’s wrapped up in other things, the biggest of which is the court-ordered HOS rule that will be published next month and CSA 2010, which is expected to launch at the end of November. There is a rule that mandates “black boxes” for the worst HOS offenders, but that’s a very small portion of trucks.
After the bill was announced, Osiecki stated that ATA’s preference would be for Congress to focus on safety technologies that would prevent crashes.
And Todd Spencer, executive vice president of the Owner-Operator Independent Drivers Association, has long said that there’s no data anywhere that shows these electronic logs improve safety.
I reached out to Dr. Ron Knipling, a safety consultant and author of the book: “Safety for the Long Haul: Large Truck Crash Risk, Causation, & Prevention.” Kipling shared with me some things that he’d written.
“There are things that work well for companies that have electronic logs and for space reasons I’m not going to go into all those, but I will say that drivers usually spend 20 minutes less per day on log-related activities,” said Knipling. And EOBRs help with other tasks, but do they make the industry safer?
According to an American Transportation Research Institute (ATRI) report that was cited by Knipling, companies “clearly benefit from EOBR adoption, but that’s not the same as showing that imposition of EOBRs would benefit carriers or safety.”
Knipling says the safety rationale for an EOBR mandate rests on a logic chain with some weak links: in theory, EOBR use leads to HOS compliance which reduces driver fatigue and thus crash reduction.
“There is a logical, causal link between EOBR use and truck safety, but it is a tenuous one,” Knipling said. “Suppose you conducted a controlled experiment where 50 percent of a large company’s drivers were randomly selected to use EOBRs and the other 50 percent were not. In this author’s opinion, you might find a marginal reduction in crashes for the EOBR users, or perhaps no reduction at all.”
The problems runs all through the chain mentioned above. For starters EOBRs don’t record non-working time. They detect driving over the allotted 11 hours a day, and would detect driving at times that violate the 10-hour off-duty rule or the 14-hour tour-of-duty rule.
“But EOBRs do not monitor non-driving work, so any rule violations relative to non-driving work are not identified,” Knipling said.
The biggest problem with relying on EOBRs for safety is that they may keep drivers from going over their hours, but they do not measure fatigue. As Knipling said, “hours of driving is not among the strongest fatigue factors.” Instead, the “fatigue ‘gang of four’ [which] is individual susceptibility, circadian valleys, inadequate sleep, and excessive awake time,” cannot be accounted for in a black box that monitors driving time.
“There is some merit to arguments that rigid HOS compliance can be detrimental to safety, as when drivers push themselves harder to limit driving to 11 hours or a tour-of-duty to 14,” Knipling said.
And farther down the chain another problem he sees is that even if EOBRs reduced fatigue and reduced crashes, “a percentage of large truck crashes are fatigue-related, but the vast majority are not,” he said. “In the Large Truck Crash Causation Study, 4.5 percent of large truck crashes had truck driver fatigue as a principal cause.”
Knipling said the links in the chain are not false, they are just limited; especially the link between HOS compliance and fatigue reduction, which he said is particularly very weak and crash reduction through EOBR use depends on all of them.
“Mandating EOBR use may well be good for safety and/or the trucking industry’s image or productivity,” Knipling said. “Widespread EOBR use should not be expected to significantly change truck crash rates, however.”
Knipling presented the following in a column he wrote and allowed me to use it here.
“Here’s a pop quiz: When they are fully engineered, refined, and deployed, which of the following technologies will be least cost-beneficial from a safety perspective?”
• Forward collision warning systems
• Lane departure warning systems
• Electronic stability control
• Roll stability advisor/control
• Driver alertness monitoring systems
• On-board safety monitoring (e.g., speed, hard braking)
• Speed limiters
• Driver medical screenings (e.g., for sleep apnea)
• Smart truck routing software, or
“The answer is EOBR’s,” Knipling said. “All the other technologies directly prevent crashes, directly reduce driver impairment or misbehaviors causing crashes, or significantly reduce exposure to crash risk. EOBRs may benefit safety, but not to the extent of the other technologies on the list.”
So if EOBRs, at least according to Knipling, are last on a list of 10 items that add safety to trucking, why are Congress and some of the largest trucking companies pushing to add them to all interstate trucks and not the other nine safety measures?
Barb Kampbell of The Trucker staff can be reached for comment at firstname.lastname@example.org.
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