INSURANCE INSTITUTE FOR HIGHWAY SAFETY

Transcription

1 INSURANCE INSTITUTE FOR HIGHWAY SAFETY February 26, 2002 Mr. Joseph M. Clapp Administrator Federal Motor Carrier Safety Administration 400 Seventh Street S.W. Washington, D.C Agency Information Collection: Driver s Record of Duty Status OMB Control No Dear Mr. Clapp: Attached is a letter sent to the Office of Management and Budget (OMB) concerning the Federal Motor Carrier Safety Administration s (FMCSA) estimate of the paperwork burden of the requirement for drivers maintaining records of their duty status. Our letter to OMB points out that FMCSA incorrectly stated "it is not economically feasible for medium and small sized carriers" to use electronic onboard recorders (67 Federal Register 1397). In refutation of this statement, our letter includes a table listing three onboard recorders costing $500 or less. All three of these recorders would meet the requirements for automated tamper-resistant recorders that were specified in FMCSA s proposed revision of the hours-of-service rules published during The basis for FMCSA s statement was that only large motor carriers currently use electronic onboard recorders in lieu of logbooks; however, FMCSA should judge economic feasibility based on actual costs of basic recorders rather than by who uses them. Whether motor carriers have chosen to use tamper-resistant electronic recorders to record driving and work hours is influenced by factors in addition to their costs. For example, an increasing number of motor carriers have sophisticated systems to track the movement of shipments and monitor the functional status of tractor equipment; however, these motor carriers do not use these systems to substitute for logbooks although the costs of adding this function would be minimal. To our knowledge, Werner Enterprises is the only motor carrier that signed up for an FMCSA pilot program to use global positioning systems to supervise driving hours despite the widespread use of these systems in response to shipper and receiver demand for just-in-time deliveries. Although some motor carriers simply may be reluctant to change existing methods for recording driving hours, other motor carriers and drivers may prefer logbooks because avoiding detection of hours-ofservice violations is easier when handwritten logbooks are used. There is ample documentation that such violations and falsified logbooks, including multiple logbooks, are common (Braver et al., 1992; Campbell and Belzer, 2000; McCartt et al., 2000; McKane, 1994) N. GLEBE RD., ARLINGTON, VA TEL. 703/ FAX 703/

2 Joseph Clapp February 26, 2002 Page 2 As FMCSA determines the best options for revising the hours-of-service rules for commercial motor vehicle drivers, the agency must consider the totality of evidence concerning automated tamper-resistant recorders the costs of new recorders meeting basic requirements, the potential for existing technology installed for other purposes to track driving hours, and the experience of motor carriers who have successfully substituted automated recorders for logbooks, which has been permissible since Revising hours-of-service limits on driving and rest time would have limited safety benefits if the methods of enforcement continue to be the antiquated handwritten logbooks. Moreover, FMCSA s higher estimates, in response to comments from the trucking industry, of the time necessary for drivers to fill out handwritten logbooks and for carriers to review data from logbooks has the effect of making automated recorders more cost-effective because automated recorders save both drivers and carriers considerable time. Sincerely, Elisa R. Braver, Ph.D. Senior Epidemiologist cc: Docket Clerk, Docket No. FMCSA Docket Clerk, Docket No. FMCSA Attachment References Braver, E.R.; Preusser, C.W.; Preusser, D.F.; Baum, H.M.; Beilock, R.; and Ulmer, R Long hours and fatigue: a survey of tractortrailer drivers. Journal of Public Health Policy 13: Campbell, K.L. and Belzer, M.H Hours of service regulatory evaluation analytical support. task 1: baseline risk estimates and carrier experience. Prepared for the Federal Motor Carrier Safety Administration (UMTRI ). Ann Arbor, MI: University of Michigan. McCartt, A.T.; Rohrbaugh, J.W.; Hammer, M.C.; and Fuller, S.Z Factors associated with falling asleep at the wheel among longdistance truck drivers. Accident Analysis and Prevention 32: McKane, D Three-state effort enforces hours of service regulations. The Guardian 1:4-5.

3 Joseph Clapp February 26, 2002 Page 3 Vendors of Tamper-Resistant Onboard Recording Devices Costing $500 or Less Vendor Cost for New Truck Cost to Retrofit Truck Software Costs Comments Contact Siemens VDO Automotive $500 $500 None Known as digital tachograph. Meets future European standards, including smart cards and a printer. Software packages are optional but not required for base model Actia $500 $500 None Unit meets European standards. If a trucking company purchases a large volume, there will beadiscount. Stoneridge $300 $300 None Unit meets European standards. Stoneridge usually sells electronic tachographs to original equipment manufacturers such as Freightliner but may sell it as aftermarket product in future

4 INSURANCE INSTITUTE FOR HIGHWAY SAFETY Office of Information and Regulatory Affairs Office of Management and Budget 725 Seventeenth St., NW Washington, DC Attention: DOT Desk Officer Agency Information Collection: Driver s Record of Duty Status OMB Control No To the DOT Desk Officer: The Insurance Institute for Highway Safety is responding to a request for comments on requiring drivers and motor carriers to maintain records of driving and work hours. Numerous scientific studies have observed an increased crash risk among drivers operating large trucks for more than 8-10 hours (Campbell, 1988; Frith, 1994; Harris, 1978; Jones and Stein, 1987, 1989; Kaneko and Jovanis, 1992; Lin et al., 1993, 1994; Mackie and Miller, 1978; National Transportation Safety Board, 1995; Saccomanno et al., 1995, 1996; Summala and Mikkola, 1994), even after controlling for the effects of time of day (Frith, 1994; Jones and Stein, 1987, 1989; Lin et al., 1993, 1994; Saccomanno et al., 1995, 1996). Accordingly, continuation of the rules to limit driving hours of commercial drivers and to provide the means to enforce those rules is essential to protecting commercial drivers and those who share the road with them. We wish to draw your attention to an erroneous statement made in the Federal Motor Carrier Safety Administration s (FMCSA) notice of its estimate of the paperwork burden of the requirement for drivers maintaining records of their duty status. FMCSA incorrectly stated "it is not economically feasible for medium and small sized carriers" to use electronic onboard recorders (67 Federal Register 1397). In refutation of this statement, our letter includes a table listing three onboard recorders costing $500 or less. All three of these recorders would meet the requirements for automated tamper-resistant recorders that were specified in FMCSA s proposed revision of the hours-of-service rules published during The basis for FMCSA s statement was that only large motor carriers currently use electronic onboard recorders in lieu of logbooks; however, FMCSA should judge economic feasibility based on actual costs of basic recorders rather than by who uses them. Whether motor 1005 N. GLEBE RD., ARLINGTON, VA TEL. 703/ FAX 703/

5 Office of Management and Budget Page 2 carriers have chosen to use tamper-resistant electronic recorders to record driving and work hours is influenced by factors in addition to their costs. For example, an increasing number of motor carriers have sophisticated systems to track the movement of shipments and monitor the functional status of tractor equipment; however, these motor carriers do not use these systems to substitute for logbooks although the costs of adding this function would be minimal. To our knowledge, Werner Enterprises is the only motor carrier that signed up for an FMCSA pilot program to use global positioning systems to supervise driving hours despite the widespread use of these systems in response to shipper and receiver demand for just-in-time deliveries. Although some motor carriers simply may be reluctant to change existing methods for recording driving hours, other motor carriers and drivers may prefer logbooks because avoiding detection of hours-ofservice violations is easier when handwritten logbooks are used. There is ample documentation that such violations and falsified logbooks, including multiple logbooks, are common (Braver et al., 1992; Campbell and Belzer, 2000; McCartt et al., 2000; McKane, 1994). We anticipate that the Office of Management and Budget will be reviewing future revisions to the proposed hours-of-service rules for commercial motor vehicle drivers. Promulgating new hours-of-service limits on driving and rest time will have limited safety benefits if the methods of enforcement continue to be the antiquated handwritten logbooks. Moreover, FMCSA s higher estimates, in response to comments from the trucking industry, of the time necessary for drivers to fill out handwritten logbooks and for carriers to review data from logbooks has the effect of making automated recorders more cost-effective because automated recorders save both drivers and carriers considerable time. Sincerely, Elisa R. Braver, Ph.D. Senior Epidemiologist

6 Office of Management and Budget Page 3 Vendors of Tamper-Resistant Onboard Recording Devices Costing $500 or Less Vendor Cost for New Truck Cost to Retrofit Truck Software Costs Comments Contact Siemens VDO Automotive $500 $500 None Known as digital tachograph. Meets future European standards, including smart cards and a printer. Software packages are optional but not required for base model Actia $500 $500 None Unit meets European standards. If a trucking company purchases a large volume, there will beadiscount. Stoneridge $300 $300 None Unit meets European standards. Stoneridge usually sells electronic tachographs to original equipment manufacturers such as Freightliner but may sell it as aftermarket product in future

7 Office of Management and Budget Page 4 References Braver, E.R.; Preusser, C.W.; Preusser, D.F.; Baum, H.M.; Beilock, R.; and Ulmer, R Long hours and fatigue: a survey of tractortrailer drivers. Journal of Public Health Policy 13: Campbell, K.L Evidence of fatigue and the circadian rhythm. Proceedings of Federal Highway Administration Symposium on Truck and Bus Driver Fatigue, Washington, DC: U.S. Department of Transportation. Campbell, K.L. and Belzer, M.H Hours of service regulatory evaluation analytical support. task 1: baseline risk estimates and carrier experience. Prepared for the Federal Motor Carrier Safety Administration (UMTRI ). Ann Arbor, MI: University of Michigan. Frith, W.J A case-control study of heavy vehicle drivers working time and safety. Proceedings of the 17th Australian Road Research Board Conference 17: Queensland, Australia: Australian Road Research Board. Harris, W Fatigue, circadian rhythm, and truck accidents. Vigilance: Theory, Operational Performance, and Physiological Correlates (ed. Mackie, R.), New York, NY: Plenum Press. Jones, I.S. and Stein, H.S Effect of driver hours of service on tractor-trailer crash involvement. Arlington, VA: Insurance Institute for Highway Safety. Jones, I.S. and Stein, H.S Defective equipment and tractortrailer crash involvement. Accident Analysis and Prevention 21: Kaneko, T. and Jovanis, P.P Multiday driving patterns and motor carrier accident risk: a disaggregate analysis. Accident Analysis and Prevention 24: Lin, T.D.; Jovanis, P.P.; and Yang, C.Z Modeling the safety of truck driver service hours using time-dependent logistic regression. Transportation Research Record 1407:1-10. Washington, DC: Transportation Research Board. Lin, T.D.; Jovanis, P.P.; and Yang, C.Z Time of day models of motor carrier accident risk. Transportation Research Record 1467:1-8. Washington, DC: Transportation Research Board. Mackie, R.R. and Miller, J.C Effects of hours of service, regularity of schedules, and cargo loading on truck and bus driver fatigue (DOT HS ). Washington, DC: National Highway Traffic Safety Administration.

8 Office of Management and Budget Page 5 McCartt, A.T.; Rohrbaugh, J.W.; Hammer, M.C.; and Fuller, S.Z Factors associated with falling asleep at the wheel among longdistance truck drivers. Accident Analysis and Prevention 32: McKane, D Three-state effort enforces hours of service regulations. The Guardian 1:4-5. National Transportation Safety Board Factors that affect fatigue in heavy truck accidents (vol. I). NTSB/SS Washington, DC: National Transportation Safety Board. Saccomanno, F.F.; Yu, M.; and Shortreed, J.H Effect of driver fatigue on truck accident rates. Urban Transport and the Environment for the 21st Century (ed. Sucharov, L.J.), Southampton, United Kingdom: Computational Mechanics Publications. Saccomanno, F.F.; Shortreed, J.H.; and Yu, M Effect of driver fatigue on commercial vehicle accidents. Truck Safety: Perceptions and Reality, Waterloo, Canada: The Institute for Risk Research. Summala, H. and Mikkola, T Fatal accidents among car and truck drivers: effects of fatigue, age, and alcohol consumption. Human Factors 36: