Remarks of Chairman Jim Hall
National Transportation Safety Board
before the International Conference on Fatigue in Transportation
American Trucking Association
Tampa, Florida, April 30, 1997
Good afternoon. I'd like to thank the American
Trucking Association for inviting me to talk to you about the
dangers of operator fatigue and the actions the National Transportation
Safety Board has taken to combat this problem.
Last week, I presided over a symposium presented
by the Safety Board on the effects of corporate culture on transportation
safety. With 550 participants, it was nearly as large as the fatigue
forum we conducted in 1995 that many of you might have attended.
Over two days, representatives of transportation
industries, unions, regulators and researchers discussed ways
to ensure that a company's organizational mindset is not such
that it breeds an atmosphere that makes an accident almost inevitable.
It was just such a mindset that led to the
TITANIC disaster 85 years ago, and to accidents our agency has
investigated over its 30-year history. And it is just such a mindset
that can produce an environment where fatigue on the part of transportation
operators is considered to be just part of the job.
The work of the ATA, and the recommendations
of the Safety Board over the years, have demonstrated that fatigue
is not part of the job, and that one of the primary responsibilities
of transportation companies is to make sure it doesn't become
part of the job.
Throughout this conference, you have heard
a number of high quality presentations about ways to counter fatigue
and maintain alertness. I am impressed by the international representation
and with the encouraging fact that people from all modes of transportation
are in attendance.
The importance this meeting and the issue of fatigue holds for us is indicated by the number of Safety Board employees who are in attendance and the different areas of the Board that they represent. Let me introduce them to you:
As I am sure you know, the topic of fatigue
has long occupied the interest of the Safety Board. We have been
concerned about the effects of fatigue in all modes of transportation
and have addressed this problem through accident investigations,
safety studies, and safety recommendations. As I mentioned, in
1995, the Safety Board co-sponsored, with the National Aeronautics
and Space Administration, a symposium on fatigue countermeasures.
Nearly 600 people from 16 countries representing all modes of
At the close of that symposium, I charged the
transportation community with taking what we had begun and finding
ways to mitigate the ill effects fatigue has on transportation
safety. I commend the ATA for convening this conference and continuing
that dialogue we started a year and half ago on developing practical
counter-measures to reduce fatigue-related accidents.
As you know, the National Transportation Safety
Board is the eyes and ears of the American people. We have chronicled
a 30-year archive of what not to do in transportation, and have
used that information to issue more than 10,000 recommendations
in all modes of transportation.
Our first recommendation on operator fatigue
was issued to the Coast Guard in 1974. We take this issue so seriously
that operator fatigue has been on the Safety Board's Most Wanted
Safety Improvements List since its inception in 1990.
Unfortunately, the lessons learned are not
always applied. No case is more reflective of the dangers of fatigue
than the grounding of the U.S. tank ship EXXON VALDEZ in Prince
William Sound, on March 2, 1989. The cost of the oil cleanup during
989 alone was almost $2 billion, almost certainly the most expensive
fatigue-related accident in history.
Among other notable fatigue-related accidents
the Board has investigated over the years are the 1988 collision
of two freight trains in Thompsontown, Pennsylvania that killed
4 crewmen, and the 1994 propane truck explosion in White Plains,
New York that killed the truck driver, destroyed a bridge and
7 homes, and closed the White Plains Expressway for over a week.
Although it is the ultimate duty of any transportation
provider, be it the company or the individual, to ensure all persons
having a safety-sensitive position be fit to perform - and that
includes not being fatigued - the U.S. Department of Transportation
has the ultimate responsibility through its oversight and regulation
to make it so. I'm afraid that to date, DOT's record has been
spotty in this area.
Investigations of the Exxon Valdez and other
fatigue-related accidents led the Board in 1989 to issue three
safety recommendations to the U. S. Department of Transportation.
We asked DOT to:
In 1994, following a study on Commuter Airline Safety, the Safety Board asked the Federal Aviation Administration to revise the federal aviation regulations so that all pilot flight time, regardless of its purpose, be counted in determining whether a pilot has had sufficient rest. The Board determined that the risk of a fatigue-related accident is as great whether or not the pilot is conducting a scheduled flight or simply on a check ride.
In 1995, the Safety Board asked the FAA to revise the flight crew duty time regulations in addition to pilot flight time. The Board concluded that the existing rules permitted a substantially reduced flightcrew rest period when conducting the nonrevenue ferry flights, and urged the FAA to revise current flight and duty time regulations within 1 year, taking into consideration research findings in fatigue and sleep issues.
While the FAA issued a Notice of Proposed Rulemaking
for flight crew duty time in December of 1995, no steps have yet
been taken to issue a final rule.
The Board also made specific recommendations
to the Federal Highway Administration to revise the hours of service
regulations for truck drivers. In a January 1995 safety study
on truck driver fatigue, the Board concluded that the most critical
factors in predicting fatigue-related accidents are the duration
of the most recent sleep period, the amount of sleep in the past
24 hours, and whether the sleep was split into shorter periods
of time rather than one long period of time. As a result of the
study's findings, the Board asked the FHWA to revise the hours
of service regulations within 2 years to give drivers the opportunity
to obtain at least 8 continuous hours of sleep. The Safety Board
also recommended elimination of the sleeper berth exemption that
allows drivers to split their 8 hour minimum daily rest between
two separate periods.
Though that two-year time frame has passed, the FHWA is still examining hours-of-service regulations and the sleeper berth exemption. As you know, the FHWA did issue an Advanced Notice of Proposed Rule Making on November 5, 1996 -- 22 months after the Board's recommendation was issued -- requesting additional information on fatigue, but no changes in the regulations have been specified or even suggested. The Safety Board continues to await FHWA action to address these longstanding deficiencies in truck driver hours of service rules.
As you heard yesterday, the FHWA's $4.5 million,
7-year driver fatigue and alertness study found the strongest
and most consistent factor influencing driver fatigue and alertness
to be the time of day, with drowsiness markedly greater driving
during the night than during the daytime. However, trucking is
a 24-hour operation and society demands that goods be shipped
anywhere in the country -- or even around the world -- overnight.
The FHWA will have a challenge reconciling this finding to the
realities of trucking operations. Although regulations cannot
guarantee that someone gets adequate sleep, we believe that they
must provide at least the opportunity to obtain an adequate
amount of sleep.
Combating fatigue is a shared responsibility
among government, industry, and employees. It is incumbent on
transportation companies not to provide the wrong signals to its
employees with respect to safety. In our corporate culture symposium,
we noted that there were some distinct markers that can indicate
a corporate culture problem. For example, one flag for recognizing
potentially unsafe cultures is management thinking and practices
that are antagonistic or indifferent toward their employees in
safety sensitive jobs.
Another flag is an organization's practices
that vary from the accepted standards found in the industry. Third,
an unsafe culture may exist if it is determined that an employee's
operating performance conformed to carrier procedures or reflected
the accepted values and attitudes found in the carrier and yet
an unsafe situation still occurred.
I urge all of you to pay special attention
to these characteristics. Chances are, the fact that you come
to conferences like this is an indication that you are already
sensitive to these matters, but a little self-examination might
be in order if you feel any of these flags pertain to your organization.
Sleep is something we all understand and the
lack of sleep is something we have all experienced. The NTSB and
others have done their part in researching fatigue, its causes
and methods of prevention. It is time for this group and those
like it to use this knowledge to prevent fatigue-related accidents,
making America's highways safer for us all.
Highway accidents cost this country over $150
billion a year and tens of thousands of lives. The price is too
high and, at least for fatigue-related accidents, the answer too
obvious for us not to act.
Thank you for inviting me, and for your continuing
efforts to improve transportation safety. By your rapt attention
to my remarks, you have proved that you are not fatigued, and
for that, too, you should be commended.