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Keynote Speech for the National Sleep Foundation's National Summit to Prevent Drowsy Driving, Washington, DC
Carol Carmody
National Sleep Foundation's National Summit to Prevent Drowsy Driving, Washington, DC

Thank you. I appreciate being asked to be here with such a diverse group of experts to discuss a critical safety issue to us all - drowsy driving on our highways. Both the National Sleep Foundation (NSF) and the Safety Board have highlighted the importance of fatigue as a safety issue for many years and this summit gives all of us a chance to review the progress that has been made to prevent drowsy driving and the deaths and injuries that result from it. Equally important we can examine what actions need to be taken to reduce further operator fatigue-related incidents to improve the safety of our roadways.

I want to thank Jim Hall for inviting me to participate in this important event. As I'm sure you're all aware, Jim is a dedicated advocate on the issues of drowsy driving and operator fatigue, as evidenced during his tenure as Chairman of the Safety Board. In fact, the NSF recognized his extensive contributions in the area of operator fatigue by awarding him its 2000 Person of the Year Award for his promotion of fatigue issues during his eight-year tenure at the NTSB. Jim has continued his commitment to this issue through his honorary chairmanship of this summit and his leadership in many other forums. I'm sure we'll continue to hear from him on this critically important safety issue.


Also in attendance today are a number of members of the Safety Board staff representing our offices of Highway Safety, Safety Recommendations and Accomplishments, Research and Engineering and Railroad, Pipeline and Hazardous Materials. They're the ones responsible for investigating the accidents, conducting the safety studies, developing the recommendations, and then tracking them through implementation. We are very proud of our 81.6% success rate in getting our safety recommendations accepted and implemented - although we're always striving to improve that rate because it means an even safer transportation system.

Over the years, both the NSF and the Safety Board have worked diligently to increase public awareness of the dangers of drowsy driving. Indeed, the NSF continues to be a strong voice through its public education and awareness initiatives such as its National Sleep Awareness Week and its "Drive Alert, Drive Alive" campaign to prevent drowsy driving. In addition, the NSF has reached out to healthcare providers to educate them about sleep-related problems and treatments - an issue I'll discuss in more detail later.

Such efforts are important because the problems associated with fatigue permeate our whole society, from our very youngest citizens to our oldest, and it exacts a heavy toll on our safety, productivity, and quality of life. As your polls and our investigations show, no one is exempt from the effects of too little sleep. As NSF surveys have indicated, about one in ten individuals report symptoms that are consistent with sleep apnea and about half indicate having at least one or more symptoms of insomnia. Drivers report that they have driven while drowsy or have actually fallen asleep. Combine those factors with the increasing amount of time people spend in their vehicles and the result is a growing number of lives affected by fatigue-related highway crashes.

The Safety Board, in its accident investigations has seen the catastrophic consequences that result from fatigued operators. Over the years, we have found fatigue to be a causal or contributing factor in crashes in every mode of transportation -- aircraft crashes, train wrecks, ship incidents, pipeline explosions, and highway crashes - and we have made about 100 recommendations to operators and regulators asking for additional education and research as well as specific regulatory changes.

Recommendations pertaining to operator fatigue in every mode of transportation have been on our "Most Wanted List" of safety improvements since the list's inception in 1990. However, those were not our first recommendations. As early as 1972, the Board issued a recommendation to the Federal Aviation Administration concerning pilot rest and duty limitations.

Since those initial recommendations, Safety Board investigations have identified serious and continuing problems concerning the far-reaching effects of fatigue, sleepiness, sleep disorders, and circadian rhythm disruption in transportation system safety. Over the years, we have made recommendations to operators and regulators on fatigue-related topics including duty schedules, rest periods, training and education on fatigue management, medical standards and certification, fatigue countermeasures, and organizational issues such as shipper demands and compensation structures that may indirectly affect operators' adherence to hours-of-service regulations.

In 1989, the Safety Board issued a series of intermodal safety recommendations to the DOT that called for an aggressive federal program to address the fatigue problem in all sectors of the transportation industry. In 1999, the Board reviewed the status of those recommendations and the progress that had been made to implement them. Although DOT and the modal agencies had addressed the recommendations pertaining to research and education, little action had been taken with respect to revising hours-of-service regulations. As a result, we asked the DOT to require the modal administrations to establish scientifically based hours-of-service regulations, to provide predictable work and rest schedules, and to consider circadian rhythms and human sleep and rest requirements. And, we asked that it be done within two years.

With regard to our highways, in 2000, in response to the Board's recommendations and to calls from Congress and the public, the Federal Motor Carrier Administration (FMCSA) published a notice of proposed rulemaking (NPRM) that proposed to update the hours-of-service regulations for commercial motor vehicle operators. Unfortunately, that rulemaking was suspended and we are still awaiting the release of a revised rulemaking.

Because of DOT's inaction to revise the hours-of-service regulations to date, the Safety Board has encouraged the rest of the transportation community to take the lead in fighting fatigue-related accidents by implementing solutions that are already available such as:

· Installing on-board data recorders on every vehicle that can help enforce hours-of-service violations, identify safety trends, develop corrective actions, and conduct more efficient accident investigations.

· Training drivers about the hazards of driving while fatigued: the need for adequate, quality sleep and strategies for avoiding sleep loss such as strategic napping.

· Restructuring work schedules so that operators can obtain at least eight hours of continuous sleep and maintain a regular schedule and routine.

As a result of several recent accident investigations, the Board has identified other issues related to operator drowsiness that must also be addressed. One of those is the need for a comprehensive medical oversight program to identify drivers with disqualifying medical problems. The Safety Board believes that the medical community can be instrumental in identifying and diagnosing individuals who may be at risk for drowsy driving due to sleep disorders or the use of sedating medications.

Let me give you an example of why we think this is so important. On July 26, 2000, in Jackson, Tennessee, at about 9:00 a.m., a truck tractor pulling a loaded semi-trailer, and traveling at about 65 mph in a 55-mph work zone, collided with a Tennessee Highway Patrol vehicle that was traveling behind some construction vehicles. On impact, the patrol car exploded and caught fire. The tractor-semi-trailer continued through the median, into the westbound lanes, where it collided with a Chevrolet Blazer. The state trooper was killed and the Chevrolet driver was seriously injured.

Our investigation revealed that the 50-year-old truck driver was involved in a similar accident in July 1997, when he struck a stopped highway patrol car in Utah, seriously injuring two troopers. After the Tennessee accident, the driver said that he may have fallen asleep just before the accident. In addition, although the driver had not indicated that he had been diagnosed or treated for a sleep disorder on any of his commercial drive medical examination forms, his medical records indicated that he had been diagnosed with obstructive sleep apnea. Despite his medical history, his medical caretakers had not notified his employer or the state licensing authorities - nor were they required to.

The NTSB determined that the probable cause of the accident was the driver's incapacitation, owing to the failure of the medical certification process to detect and remove a medically unfit driver from service.

The Board had made recommendations to the FMCSA and the American Association of Motor Vehicle Administrators, following the tragic New Orleans bus crash on Mother's Day 1999 that killed 22, asking that those agencies develop a comprehensive medical oversight program for both interstate and intrastate commercial drivers which would prevent such situations. Such an oversight program would:

· ensure that those who perform medical examinations for drivers are qualified to do so and are educated about occupational issues for drivers;

· provide a mechanism for reporting medical conditions to the medical certification and reviewing authority and for evaluating these conditions between medical certification exams;

· enable enforcement authorities to identify invalid medical certification during safety inspections and routine stops; and

· provide a tracking mechanism to ensure that every prior application by an individual for medical certification is recorded and reviewed.

We believe that by raising awareness in the medical community, we can increase the likelihood of the detection and reporting of medical conditions that may affect a driver's ability to stay alert while driving. If such an oversight program had been in place, the driver in Jackson, Tennessee - and others like him - may not have been on our roads - creating a hazard for themselves and others. FMCSA has indicated that it supports some of the recommendations. And, the Safety Board is continuing to work with the agency to ensure that all of the recommended actions are implemented.

Another issue that must be addressed involves the debilitating effects of impairing medications on vehicle operators. Since 1987, the NTSB has investigated over 150 accidents, in all modes of transportation, in which over-the-counter (OTC) medications or prescription drugs have caused or contributed to an accident. In aviation alone, between 1987 and 1995, OTC medicines and prescription drugs played a role in 72 fatal accidents.

In 1998, we investigated a motorcoach accident that highlights the dangers of such medications. About 4:05 a.m., on June 20, 1998, a Greyhound bus traveling from New York City to Pittsburgh, went off the right side of the roadway near Burnt Cabins, Pennsylvania into an emergency parking area, striking the back of a parked tractor-semi-trailer, pushing it forward into the left side of another parked tractor-semi-trailer. The bus driver and six passengers were killed; the other 16 passengers were injured. The two occupants of the first tractor-semi-trailer were injured, and the occupant of the second tractor-semi-trailer was uninjured.

The Safety Board determined that the probable cause of the accident was the bus driver's reduced alertness from ingesting a sedating antihistamine and his fatigued condition as a result of the bus company's irregular work-rest schedules.

In 2000, based on this accident and others in other transport modes, the Board recommended that:

· DOT establish a list of approved medications or classes of medications that may be used safely when operating a vehicle, and expressly prohibit the use of any medication not on that list except in certain situations;

· DOT evaluate the applicability of similar restrictions for transportation employees in all safety-sensitive positions;

· the modal administrations establish procedures so that modal vehicle operators who medically require substances not on the DOT's list of approved medications may be allowed, when appropriate, to use those medications while operating a vehicle;

· the modal administrations educate vehicle operators about the potential for medications to affect adversely their ability to operate vehicles safely, and that the modal administrations that regulate vehicle operators in surface modes work with DOT to obtain more comprehensive data on the nature and extent of medication involvement in fatal surface mode accidents; and

· the Food and Drug Administration (FDA) establish and require the use of a clear warning label for medications that may interfere with an individual's ability to operate a vehicle.

In addition, we held a joint NTSB/FDA public forum in November 2001 on the effects of OTC and prescription medications and efforts to label medications that may lead to fatigue. Many of you were active participants in that forum. It was a very productive meeting in which we discussed ways to work together, conduct more research, expand testing programs, and educate the public.

Accidents are continuing to occur every day on our nation's highways, on its railways, at our ports and in our skies because of fatigued operators. Just yesterday, the Board adopted a report on a collision of two trains near Clarkston, Michigan that occurred on November 15, 2001 that left two crewmembers dead and two seriously injured.

The Board determined that the probable cause of the accident was the train crewmembers' fatigue, which was primarily due to the engineer's untreated; and the conductor's insufficiently treated; obstructive sleep apnea. As a result, we recommended to the Federal Railroad Administration that it:

· develop a standard medical examination form that includes questions regarding sleep problems and require that the form be used to determine the medical fitness of locomotive engineers and other employees in safety-sensitive positions;

· require that any medical condition that could incapacitate, or seriously impair the performance of, an employee in a safety-sensitive position be reported in a timely manner; and

· require that, when a railroad becomes aware that an employee in a safety-sensitive position has a potentially incapacitating or performance-impairing medical condition, the railroad prohibit the employee from performing any safety-sensitive duty until a physician determines that the employee can continue to work safely.

Obviously, our work is not done. Despite all of the research and educational endeavors that have been undertaken over the years, few have translated into meaningful changes in the regulations of any transportation mode. There has been a lot of activity -- rulemaking has been initiated, but not concluded; committees and working groups have been formed, and reformed, to review the regulations. But, many of the same rules remain in effect - some for almost 100 years -- and little progress has been made in addressing these critical issues. We need to continue to work with regulators to effect sound, scientifically based rules.

We must also continue to find ways to raise public awareness about the problem of drowsy driving and to convince people that operating a vehicle while fatigued can lead to the same consequences as driving drunk.

We must also improve the techniques used to determine the role of fatigue in accidents and to track more effectively the magnitude of the problem. The number of motor vehicle accidents attributable to driver drowsiness is difficult to gauge, primarily because of inconsistencies in crash reporting practices and difficulties in determining whether a fatally injured driver was asleep at the time of a crash.

I hope that you will keep that in mind during your work this week, because until we develop better methods for identifying and documenting fatigue-related crashes, we must continue to assume that the statistics we hear about the prevalence of fatigue-related crashes underestimate the true scope of the problem. Furthermore, until we can effectively quantify the rate of accidents caused by drowsy driving, it will be difficult to assess the efficacy of programs designed to prevent drowsy driving.

I want to congratulate the NSF and all of you for your tireless efforts to bring much needed attention to this critical issue. We are making progress, but as we all know, more needs to be done. And, that is why we're all here today.

Thank you, again, for inviting me to be here today.