Wednesday, February 09, 2005

Six Days On The Road

“I got a ten forward gears and a Georgia overdrive
I take little white pills and my eyes are open wide
I just passed a "Gimmy" and a "White"
I've been smokin' everything in sight
Six days on the road and now I'm gonna make it home tonight”

Six Days on the Road, Recorded by Dave Dudley

Around New Years 2004, two events of safety significance came together. David Darwin Pedruska, better known as Dave Dudley, who made “Six Days on the Road” a trendsetter in truckers’ music, passed away. “Six Days” came back on the air. And, new Hours of Service rules of the Federal Motor Carrier Safety Administration went into effect with some public attention on January 4, 2004. Injury control professionals should consider the implications of these rules off the highway.

Later in the year, a Court of Appeals overturned the new rules, citing a lack of rationale for less than full protection. No one knows what the rules really are now, but the principles remain.
The new FMCSA rules limited truck drivers to 11 hours driving in a 24 hour cycle. More important, driving must cease 14 hours after going on duty, regardless of time behind the wheel. The driver may continue on duty with non-driving tasks. Driving may resume only after 10 hours off duty. Driving must also stop after 60 hours on duty in 7 consecutive days, or 70 hours in 8 days, to start again only after 34 hours off duty.

The clear rationale is that extended duty beyond 14 hours on a single day, and an average of 8.5 hours a day over a calendar week, are sufficient to impair driving performance to the point of creating an injury hazard to the driver and to others. The FMCSA estimates that the rule will cost the public approximately $3.4 billion over 10 years. The agency estimates that the 10-year discounted monetary value of the benefits (fatalities and injuries prevented, property damage savings) is $6.8 billion.

No one would plausibly argue that such a regulation could be implemented, in the Bush Administration no less, if only the drivers were perceived at risk: it is public fear of being squashed by an 18-wheeler which drove this regulation. Despite the positive cost benefit analysis presented by FMCSA, the trucking industry hates this regulation, suggesting it’s cheaper to pay the insurance premiums than make the schedule changes to prevent the injuries. Current drivers fear loss of income from these rules, even though the cost is increased wages for the additional drivers which would be hired to meet these requirements.

These rules apply to people driving a 10,000 lb vehicle over the road. What do they mean for the industrial setting?

Traffic safety analogies come up all the time in discussion of safety culture and philosophy: violating the speed limit, substance impaired driving, compliance with seatbelt usage. For fixed worksite occupational injury control programs, these analogies are distracting.

First, the potential success of any injury control strategy that depends primarily on attention state, reaction time, judgment, motivation, obedience and dexterity is distinctly limited. All workers perform below their median over a hundred days a year, and perform at their lowest 1% on at least 2 days. Given the certain human error at these rates, such a strategy accepts some finite rate of injury in a fixed environment. If one incident is inevitable, why aren’t two acceptable? Yet this is the situation behind the wheel, if the environment is considered fixed.

Secondly, on the highway, we perceive considerable risk to come from second party drivers and unknown environment dangers which can’t be overcome by first party performance.

Finally, culture supports violations of the injury prevention rules. Speeding, and running red lights, can be eliminated nearly 100% by installing camera systems at strategic locations. [This would also catch a large fraction of the impaired driving behavior which causes injury, without the intrusion in privacy of sobriety checkpoints, and minimize the DWB aspect of increased police traffic enforcement.] Even though public authorities would initially make large amounts of money on this equipment, it is rarely installed because the culture which glorifies speeding and evasion of enforcement resists such installations. Finally, most discussions of traffic safety ignore the remarkable unbroken trend of reduction of fatalities per vehicle mile since the 1920’s, when these statistics were started. This trend applies to one car, two car and pedestrian fatalities. These improvements, continued over so long a time, more likely arise from limited access highways, improved traffic signals, better controlled vehicles and better crash survivability than from changes in driving behavior.
Returning to the occupational environment, what are the implications of the assumed the 14 hour day, 60 hour week performance decrement? Obviously, enforcing such a regimen on powered industrial vehicle drivers, skilled trades workers, utility maintenance workers, traveling salesmen and others would have major economic impact under current conditions. Mostly, it would require hiring more workers who would do less overtime.

The scientific question is whether over-the-road truck driving by a professional driver is more subject to performance decrement-induced injury than other tasks. Issues to be evaluated are impact of prolonged static posture and visual surveillance on performance, the control characteristics of the vehicle, falling asleep and pressure to drive at night and in bad weather conditions. These are independent of hours of service.

In the manufacturing environment, second party initiated injuries are rare, other than those associated with PIV’s. Although studies are lacking, it would appear that the driving environment for a PIV is less controlled and more incident prone than driving over the road. PIV collision injuries are best prevented by improving the driving environment, but it appears unlikely that this environment will ever be as collision risk protected as the freeway. Fatigue impaired driver performance within this environment would appear to be subject to similar analysis as the FMCSA rule.

Injury control for skilled trades activities will be most effective by concentrating on identifying guarding opportunities for equipment servicing tasks, fall prevention guarding opportunities, structured hazard identification for high risk tasks leading to environment modification and objectively measurable procedural change. A significant fraction of skilled trades incidents involve powered industrial vehicles, used under more risky conditions than standard PIV operations.

Nevertheless, 80-hour weeks for skilled trades workers are common. Seven day weeks, which eliminate the 34 hour rest period to restart the clock are frequent. Ending at midnight Saturday would mean not starting until 10 am on Monday.

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