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Remarks Before the International Conference on Fatigue in Transportation, American Trucking Association, Tampa, Florida
Jim Hall
American Trucking Association, International Conference on Fatigue in Transportation, Tampa, Florida

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:

  • Meg Sweeney from our Safety Studies Division;
  • Joe Osterman and Ken Rogers, from our Highway Division;
  • Gerrit Walhout, Bruce Magladry, Rick Narvell, and Gerald Weeks from our Human Performance Division; and
  • Richard Johnson from our Marine Division.

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 transportation attended.

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:

  • Expedite a coordinated research program on the effects of fatigue, sleepiness, sleep disorders, and circadian factors on transportation system safety. We believe that a concerted effort has been made by DOT to conduct fatigue-related research in all modes of transportation. Representatives of the Department's modal agencies have briefed the Board periodically about their ongoing research project. The Board classified DOT's actions related to this recommendation acceptable and closed the file on it last year.
  • Develop and disseminate educational material for transportation industry personnel and management regarding shift work, work and rest schedules, and proper regimens of health, diet, and rest. DOT has invested significant time and resources in creating videos and brochures to educate operators about fatigue. The Board has been impressed with the level of detail in these educational items but is concerned that these materials address only the aviation and highway modes. I should also note that several other organizations and businesses, including the ATA, are also doing their part in educating the public about fatigue and they should be congratulated for getting this important message out.
  • Review and upgrade regulations governing hours of service for all transportation modes to ensure that they are consistent and incorporate the results of the latest research on fatigue and sleep issues. Although originally issued as a multi-modal recommendation, subsequent specific recommendations on hours of service in the aviation and highway modes were also released.

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.


Jim Hall's Speeches