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Safety Issues and Their Impact Rob Abbott Vice President Safety Policy American Trucking Associations

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Page 1: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

Safety Issues and Their Impact

Rob Abbott

Vice President

Safety Policy

American Trucking Associations

Page 2: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

SAFETY ISSUES Getting Up To Speed… What’s Next… The Impact…

Electronic Logging Devices (EOBRs)

Hours of Service

Sleep Apnea

Compliance, Safety, Accountability (CSA)

Page 3: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

ELECTRONIC LOGGING DEVICES Getting Up To Speed

Final Rule for Non-Compliant Carriers

Proposed Rule for Everyone Else

Harassment Concerns

Technical Issues

Congressional Mandate

Page 4: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

ELECTRONIC LOGGING DEVICES What’s Next

Supplemental Proposed Rule –September 2013

Final Rule - Mid 2014?

Implementation Deadline – Mid 2016?

Legal Challenges

Page 5: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

ELECTRONIC LOGGING DEVICES The Impact

Percentage of Industry Subject to Mandate

• Productive Time Each Day

• Driver Acceptance

• Operational Flexibility

How Will It Impact Capacity? …Productivity?

• The Effect of FMCSA’s Safety Measurement System - CSA

Voluntary Adoption? How Rapid? Why?

Page 6: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

HOURS OF SERVICE Getting Up To Speed

New Rule

Restart Restrictions

Mandatory Rest Breaks

Effective July 2013

Page 7: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

Total Hours

On-Duty In This

7 Day Period = 59

Date Day Hours On Duty

12/1/12 Wednesday 5

12/2/12 Thursday 9

12/3/12 Friday 10

12/4/12 Saturday 9

12/5/12 Sunday 10

12/6/12 Monday 12

12/7/12 Tuesday 4

12/8/12 Wednesday

12/9/12 Thursday

How the 34 Hour Restart Works

34-HOUR RESTART How it Works

Page 8: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

Date Day Hours On Duty

12/1/12 Wednesday 5

12/2/12 Thursday 9

12/3/12 Friday 10

12/4/12 Saturday 9

12/5/12 Sunday 10

12/6/12 Monday 12

12/7/12 Tuesday 4

12/8/12 Wednesday

12/9/12 Thursday

Total Hours

On-Duty In The Previous

6 Days = 54

How the 34 Hour Restart Works

Available hours within the 60 hour

limit on Wednesday = 6

34-HOUR RESTART How it Works

Page 9: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

7 Day Period

Date Day Hours On Duty

12/1/12 Wednesday 5

12/2/12 Thursday 9

12/3/12 Friday 10

12/4/12 Saturday 9

12/5/12 Sunday 10

12/6/12 Monday 12

12/7/12 Tuesday 4

(off at noon)

12/8/12 Wednesday

12/9/12 Thursday Total Hours On-Duty In This 7 Day Period

= 0

How the Current 34 Hour Restart Works

34 Consecutive Hours Off-Duty

34-HOUR RESTART How it Works

Page 10: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

34 Hour Restart – Current Rule

Tues 1 a.m 2 a.m. 3 a.m. 4 a.m. 5 a.m. 6 a.m. 7 a.m. 8 a.m. 9 a.m. 10 a.m. 11 a.m. 12 p.m.

Tues 1 p.m. 2 p.m. 3 p.m. 4 p.m. 5 p.m. 6p.m. 7 p.m. 8 p.m. 9 p.m. 10 p.m. 11 p.m. 12 a.m.

Wed 1 a.m 2 a.m. 3 a.m. 4 a.m. 5 a.m. 6 a.m. 7 a.m. 8 a.m. 9 a.m. 10 a.m. 11 a.m. 12 p.m.

Wed 1 p.m. 2 p.m. 3 p.m. 4 p.m. 5 p.m. 6p.m. 7 p.m. 8 p.m. 9 p.m. 10 p.m. 11 p.m. 12 a.m.

Thurs 1 a.m 2 a.m. 3 a.m. 4 a.m. 5 a.m. 6 a.m. 7 a.m. 8 a.m. 9 a.m. 10 a.m. 11 a.m. 12 p.m.

Thurs 1 p.m. 2 p.m. 3 p.m. 4 p.m. 5 p.m. 6p.m. 7 p.m. 8 p.m. 9 p.m. 10 p.m. 11 p.m. 12 a.m.

Fri 1 a.m 2 a.m. 3 a.m. 4 a.m. 5 a.m. 6 a.m. 7 a.m. 8 a.m. 9 a.m. 10 a.m. 11 a.m. 12 p.m.

Fri 1 p.m. 2 p.m. 3 p.m. 4 p.m. 5 p.m. 6p.m. 7 p.m. 8 p.m. 9 p.m. 10 p.m. 11 p.m. 12 a.m.

34-HOUR RESTART How it Works

Safety Issues and Their Impact

Page 11: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

34 Hour Restart – New Rule

Tues 1 a.m 2 a.m. 3 a.m. 4 a.m. 5 a.m. 6 a.m. 7 a.m. 8 a.m. 9 a.m. 10 a.m. 11 a.m. 12 p.m.

Tues 1 p.m. 2 p.m. 3 p.m. 4 p.m. 5 p.m. 6p.m. 7 p.m. 8 p.m. 9 p.m. 10 p.m. 11 p.m. 12 a.m.

Wed 1 a.m 2 a.m. 3 a.m. 4 a.m. 5 a.m. 6 a.m. 7 a.m. 8 a.m. 9 a.m. 10 a.m. 11 a.m. 12 p.m.

Wed 1 p.m. 2 p.m. 3 p.m. 4 p.m. 5 p.m. 6p.m. 7 p.m. 8 p.m. 9 p.m. 10 p.m. 11 p.m. 12 a.m.

Thurs 1 a.m 2 a.m. 3 a.m. 4 a.m. 5 a.m. 6 a.m. 7 a.m. 8 a.m. 9 a.m. 10 a.m. 11 a.m. 12 p.m.

Thurs 1 p.m. 2 p.m. 3 p.m. 4 p.m. 5 p.m. 6p.m. 7 p.m. 8 p.m. 9 p.m. 10 p.m. 11 p.m. 12 a.m.

Fri 1 a.m 2 a.m. 3 a.m. 4 a.m. 5 a.m. 6 a.m. 7 a.m. 8 a.m. 9 a.m. 10 a.m. 11 a.m. 12 p.m.

Fri 1 p.m. 2 p.m. 3 p.m. 4 p.m. 5 p.m. 6p.m. 7 p.m. 8 p.m. 9 p.m. 10 p.m. 11 p.m. 12 a.m.

RESTART RESTRICTIONS Effective July 2013

RESTART RESTRICTIONS

Page 12: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

HOURS OF SERVICE What’s Next & The Impact

• Lawsuit

• Restart Study

What’s Next

• Productivity Impact

• Percentage of the Industry Affected

• Operational Concerns

Rest Breaks

• Industry Segments Impacted

• How Much?

• Effect on Productivity

Restart Restriction

Page 13: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

SLEEP APNEA Getting Up To Speed

• Repetitive pauses in breathing during sleep

• Can last up to 40 seconds each

• Can occur 20 times or more per hour

• Daytime sleepiness

• Elevated crash risk

What It Is….

• All drivers with BMI >or = 35

• Or other factors

MRB/MCSAC Recommendations

• May be compelled to conduct rulemaking instead

• Would require cost-benefit analysis

• Delayed implementation

Guidance Anticipated In Early 2013

Page 14: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

SLEEP APNEA The Impact

• 17% Mild

• 5.6% Moderate (15-30 AHI)

• 4.7% Severe (30+ AHI)

How Many Drivers Will Be Impacted?

• 35 BMI or Other Factors

• Home Testing

• Physician Monitored CPAP Use

Likely Requirements

• How Many Will Be Discouraged from Entering the Profession?

• Staying?

• Is Discouragement Beneficial?

Effect on Driver Shortage

Page 15: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

CSA Getting Up To Speed

• Prioritize Motor Carriers for Enforcement

• Provide Third Parties with Safety Information

Dual Objectives

• Some Correlate to Crash Risk

• Others Measure Compliance with Regulations

• In Both Cases Outliers Exist

Concerns Over Reliability, Accuracy and Significance of Scores

• Lawsuit

• Congressional Hearings

• Inspector General Investigation

• GAO Report

Focus and Criticism

Page 16: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

CSA

The Impact

“We did not find any meaningful statistical correlation between

BASIC scores and actual accident incidence on the basis of

miles driven or number of power units in our 4,600 carrier

dataset.” Anthony Gallo

Wells Fargo Securities

July 2012

“For many carriers in the MCMIS data, the association between

crash risk and the BASIC scores is so low as to be

irrelevant,...” James Gimpel

University of Maryland

July 2012

Page 17: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

“The analysis showed with high levels of confidence that BASIC

scores are positively related to crashes in the Unsafe Driving,

Fatigued Driving and Vehicle Maintenance BASICs, with the

strongest relationship found for Unsafe Driving.”

Micah Lueck

American Transportation Research Institute

October 2012

“For all BASICs, crash rates were higher for carriers exceeding

SMS thresholds than for carriers not exceeding thresholds. The

crash rate was highest for carriers exceeding the Unsafe Driving

threshold.”

UMTRI/FMCSA

August 2011

CSA

The Impact

CSA

The Impact

Page 18: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

CSA What’s Next

• Severity Weights

• Utilization Factor

• Safety Event Groups

Next Round of Changes

• November 2013

Safety Fitness Rulemaking

MCSAC Subcommittee

FMCSA Effectiveness Evaluation

Page 19: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

“I Can’t Find

Enough Drivers!”

THE AGGREGATE IMPACT

The Aggregate Impact

Page 20: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

Yes, 77%

No, 23%

, 0%

Percentage of Fleets That Say Finding Drivers Is Challenging

All Respondents

Source: ATA Benchmarking Guide for Driver Recruitment & Retention

Driver Hiring

Page 21: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

90%

50%

40%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Truckload LTL Private Source: ATA Benchmarking Guide for Driver Recruitment & Retention

Driver Hiring

Percentage of Fleets That Say Finding Drivers Is Challenging

Page 22: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

Quality 88%

Quantity 4%

Both 8%

Conclusion: 88% of fleets say they are getting enough applicants, but that they can’t hire the vast majority of those applicants. It was common to hear fleets say that they hire less than 10% of applicants.

Is it Quantity or Quality?

Source: ATA Benchmarking Guide for Driver Recruitment & Retention

Driver Hiring

Page 23: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

Yes, 50%

No, 44%

Maybe, 6%

Bottom Line – demand for new drivers will increase at a faster pace than in the past.

Percentage of Fleets Considering Hiring Inexperienced Drivers

Note: Responses from truckload carriers that currently do not hire inexperienced drivers.

Source: ATA Benchmarking Guide for Driver Recruitment & Retention

Driver Hiring

Page 24: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

Trend-Line for Number of Tractor-Trailer Drivers Demanded

Trend-line for Number of Tractor-Trailer Drivers Supplied

Millions

Tractor-Trailer Driver Supply and Demand

239,000 potential shortfall

Source: ATA

1.50

1.75

2.00

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022

Driver Hiring

Driving

Hiring

Page 25: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

Breakdown of New Drivers Needed Per Year: 96,178

Industry Growth36%

Retirements37%

Voluntary Non-Retirement Departures

11%

Non-Voluntary Departures

16%

Source: ATA Benchmarking Guide for Driver Recruitment & Retention

Driver Hiring

Driver Hiring

Page 26: Safety Issues and Their Impact · CSA The Impact “We did not find any meaningful statistical correlation between BASIC scores and actual accident incidence on the basis of miles

Questions and Answers