In March 2011, a tour bus in the Bronx, N.Y., overturned at high speed on Interstate 95 at 5:30 a.m., killing 15 people and injuring dozens more. The ensuing investigation found the driver, Ophadell Williams, suffered from fatigue because he had little sleep over the course of three days except for naps he took on the bus while passengers were inside the Mohegan Sun casino. Williams was well within his federally regulated hours of service (HOS).

Countless stories like the Bronx accident exist in the motorcoach industry, a historically safe mode of transportation that has taken a pretty hard hit of late because of several well-publicized accidents over the last few years. One major cause of these accidents is driver fatigue.

The National Traffic Safety Board (NTSB) investigated 16 fatal motorcoach crashes between June 1998 and January 2008 and found driver fatigue was responsible for a staggering 36% of the fatalities occurring in the crashes investigated and was the number one cause of fatal accidents, far above road conditions (2%) and inattention (6%).

“If you look at the cause of many of these accidents over the years, they are caused by driver error, and often, the major contributing factor is fatigue,” says United Motorcoach Association (UMA) President/CEO Victor Parra.

While the NTSB, the Federal Motor Carrier Safety Administration (FMCSA), politicians and other federal agencies have focused on the HOS rule as a way to combat driver fatigue, many industry experts feel the problem could be more properly addressed through risk management and proper training for owners, drivers and their families.

Aside from discussing the causes and risks of driver fatigue and what can be done by the industry to help improve safety, METRO Magazine also conducted an informal, anonymous survey of motorcoach companies around the nation to see, among other things, how many operations have had accidents caused by driver fatigue, how much training they provide their drivers and what they are doing to manage their risks.

Driving while fatigued
Simply put, a driver of any type of vehicle, whether it’s a personal automobile, train or motorcoach, is at risk to suffer from fatigue.

The easiest way to combat fatigue, of course, is getting the proper amount of rest — between seven to nine hours of restful uninterrupted sleep for adults, according to the National Sleep Foundation. Without sufficient sleep, most aspects of a driver’s performance suffers, including their judgment, decision-making, memory, reaction time and concentration. If a driver is extremely tired, fatigue can cause uncontrolled and involuntary shutdown of the brain. In other words, they can fall asleep.

“The one thing we know about fatigue for sure is that it’s both cumulative and subversive,” explains Jack Burkert, a retired bus safety advisor. “It will sneak up on somebody and cloud his or her judgment long before the individual can perceive the problem, which is the same as alcohol and driving.”

In his book, “Motor Fleet Safety, Standards and Practices,” Burkert explains driver fatigue is commonly perceived as having few consequences unless the driver actually falls asleep, which he says is simply not true because it’s a gradual process that slowly impairs the driver’s ability to perceive, react and avoid problems.

“Falling asleep is just the final step,” he says. “But up to that point, drivers go through several stages of possibly preventing problems and ignore them because they don’t know they are happening.”

According Lancer Insurance, which has studied and provided training on driver fatigue for more than 10 years, specific warning signals of fatigue, both on and off the road, include:

  • Drowsiness.
  • Loss of concentration and attention, or the driver is easily distracted.
  • Slowed responses.
  • Increased desire to sleep.
  • Rapid loss of short-term capability.
  • Frequent mistakes.
  • Slowed speed of eye movement (staring).
  • Increased difficulty to visually focus or keep eyes open.
  • Frequent yawning.
  • Head nodding and/or head shaking to stay awake.
  • Microsleep events averaging five seconds to six seconds.
  • Chronic lateness.
  • Aggressiveness.
  • Frequent bad moods or behavior.

“If you’re not on a regular work and sleep schedule pattern, you will be constantly exhausted,” says Bob Crescenzo, VP, Lancer Insurance. “When you’re tired, you can be driving one hour and run off the road.”[PAGEBREAK]
Learning the human body
One critical component an operation can focus on to combat driver fatigue is managing the risk associated with certain trips, particularly those requiring the driver to be on the road past midnight.

“There are a lot of companies in our industry that really don’t want to drive at night, charter operations in particular, but they are often forced to because schools, for example, often build itineraries that turn the coach into a rolling hotel,” says American Bus Association (ABA) VP, regulatory & industry affairs, Norm Littler. “There is a concern within the industry regarding the practice, and we have really tried to discourage it. A customer may save a few dollars, but they increase their risk of getting in an accident if a driver is fatigued and not fit to operate a motorcoach during those hours.”

The normal adult biological clock runs on a daily cycle, known as a circadian rhythm, that controls alertness, digestion, hormone production, blood pressure and sleep, and is reflected by shifts in body temperature, mood and stages of alertness. Because of this clock, research has shown adults have two down times; post-lunch, between 1 p.m. and 4 p.m., and between 1 a.m. and 5 a.m., when a person’s body temperature is at its lowest point and craves sleep.

More than 10 years ago when it began examining its data, Lancer found a majority of transportation accident claims occurred during the hours where there were low points in alertness, with the highest number of fatal accidents occurring between the hours of 2 a.m. and 6 a.m., even though there are significantly fewer drivers on the road.

Echoing Littler’s sentiments, Crescenzo explains that his company has tried to communicate to its clients that overnight driving is often not a good idea and adds that based on Lancer’s book of business, it seems to be working.
“We have seen a great deal of improvement, because many companies are now refusing to do overnight trips,” he says.

Littler adds that the insistence of customers requesting to drive late at night often puts operators in a difficult position of losing business.

“Customers will approach operators with an itinerary that could be dangerous or is illegal and two out of three operators will tell them ‘no, we can’t do it,’” explains Littler. “Those customers will just keep shopping for the operator that will, because they are just looking for the right price instead of weighing any safety concerns.”

Lifestyles, training and more
According to the experts, a solid driver fatigue training program should communicate the importance of getting the required amount of uninterrupted sleep and the various issues that can arise if a driver doesn’t get that sleep.

While some people may be able to function well on a small amount of sleep, it won’t last long and often results in what is known as “sleep debt,” which causes the body to crave sleep. The only way to satisfy that craving is sleep. Therefore, it is suggested that the drivers’ significant others, whether it be their wife, husband, boyfriend or girlfriend, also take part in the training.

“It’s important to educate the driver and their family to make them aware of the fact that when they are off on their own time they can’t be working the equivalent of an eight hour day, where they mow the lawn, rake the leaves and garden, and then, expect to come back on duty and drive effectively for eight to 10 hours,” ABA President/CEO Peter Pantuso.

Part of the training should also include asking the driver about their lifestyle; whether they drink or smoke, what their sleep patterns are like and their medical history. It may also be important to see if they consider themselves “morning larks” or “night owls.”

Typically, morning larks prefer to go to sleep early in the evening and wake up early in the morning and believe they are most highly productive in those morning hours. Meanwhile, night owls stay up late and have issues getting up early in the morning.

“If you put a lark on a late-night run, you might have a problem,” says Burkert. “If you put a night owl on a run that begins at 4 a.m., you might have a problem.”

A major medical condition an operation should be aware of, or be able to identify if the driver or their significant other suffers from, is sleep apnea.
Sleep apnea is a disorder characterized by abnormal pauses in breathing or instances of abnormally low breathing, during sleep. Each pause in breathing, called an apnea, can last from a few seconds to minutes and may occur five to 30 times or more an hour. Similarly, each abnormally low breathing event is called a hypopnea.

There are three forms of sleep apnea, however, regardless of type, an individual with sleep apnea is rarely aware of having difficulty breathing, even upon awakening.

Sleep apnea can affect anyone, however, there are several risk factors to look for, including:

  • Being male.
  • Being overweight.
  • Being over age 40.
  • Having a large neck size (17 inches or greater in men and 16 inches or greater in women).
  • Having large tonsils, a large tongue or a small jaw bone.
  • Having a family history of sleep apnea.
  • Gastroesophageal reflux, or GERD.
  • Nasal obstruction due to a deviated septum, allergies or sinus problems.

Sleep apnea is recognized as a problem by others witnessing the individual during episodes or is suspected because of its effects on the body. Symptoms may be present for years without identification, during which time the sufferer may become conditioned to the daytime sleepiness and fatigue associated with sleep disturbance.

If left untreated, sleep apnea can result in a growing number of health problems that can impact drivers and their ability to operate a motorcoach, including:

  • High blood pressure.
  • Stroke.
  • Heart failure, irregular heartbeats and heart attacks.
  • Diabetes.
  • Depression.
  • Worsening of Attention Deficit Hyperactivity Disorder.

Sleep apnea is diagnosed with an overnight sleep test called a polysomnogram, or “sleep study” and is generally treatable. There are many third-party providers that will come out to your operation and test drivers for a fee.

Crescenzo says involving the family in their training programs has paid off.

“We found that by including the drivers’ loved ones, we often get drivers to go for their own sleep apnea evaluations to perhaps deal with a sleep apnea problem,” says Crescenzo. “If you talk to people individually it’s one thing, but if you say to a spouse does he or she snore or do you snore, we sometimes find it’s not the driver but the spouse who has sleep apnea, and the driver is not sleeping well because of it.”[PAGEBREAK]
Federal resolutions
Early this year, the FMCSA began holding public listening sessions to solicit concepts, ideas and information on HOS requirements for motorcoach drivers, with the first listening session taking place at ABA’s Marketplace 2012 in Grapevine, Texas.

Through the sessions, the FMCSA is seeking data and answers relating to the following issues and questions as it considers development of a rulemaking on the following requirements:

1. Driving Time - Information or data that examine fatigue and safety differences associated with different driving time periods.

2. Duty Time/Driving Window - Information on patterns of work for motorcoach drivers.

3. Time-On-Task (TOT) Function - Information on methods for evaluating fatigue associated with motorcoach operators’ actual driving time, including suggestions for estimating TOT effects, especially where it might obtain data on exposure and other motorcoach driver characteristics that would enable the FMCSA to estimate how or whether crash risk varies over successive hours of daily driving.

4. Cumulative Fatigue - Information on the effects of cumulative fatigue during the work week, particularly scientific studies or data that would allow evaluation of cumulative fatigue and its impact on workplace safety, motorcoach driver safety performance and productivity.

HOS requirements for motorcoach operators have not been substantially revised in several decades. While FMCSA and other government agencies often point to HOS and the violation of those rules as a major contributor to high-profile motorcoach accidents, those involved in the accidents are often carriers that are operating illegally.

The FMCSA did not include changes to the motorcoach HOS requirements in its April Final Rule (68 FR 22456) concerning HOS requirements for truck drivers or in revisions of that rule following several lawsuits, because it lacked “sufficient data on motorcoach operations to form the basis of a rulemaking.” Therefore, many industry experts feel that revising HOS to further prevent driver fatigue is not necessarily the right direction to move toward.

“If you look back, all of this stuff started in the 1930s. What we knew about fatigue and safe driving then is very different than what we know now, yet you have a government agency that is basically saying that we have to continue these limitations,” says Burkert. “All of this craziness of hours on, hours off, back and forth, is apparently not doing anybody any good.”

Littler agrees that HOS and driver fatigue should not necessarily be tied together.

“Fatigue is not directly related to hours of service,” he says. “Hours of service rules set arbitrary numbers, really. You can have somebody working fully within the hours of service when the crash takes place, but could be fatigued for other reasons.”

Lancer’s Crescenzo says a big issue is assigning a number to the amount of time a driver should be on duty.

“Hours of service should be based on biology and sleep theory; how people sleep and the quality of sleep, not just a number,” he says. “From a business and operational perspective, putting a number is just easier. It’s really a complicated issue.”

Littler adds the industry is open to making changes to HOS but it has not been presented any evidence by the FMCSA, or anyone else, there is a problem with the current hours as written.

“We do not have evidence of buses crashing all over the roads because of drivers falling asleep,” he says. “We have had bus crashes where drivers have fallen asleep documented, but they were well within the hours of service, they just chose not to rest when they were given the opportunity.”

Additionally, Littler says some out-of-the-box solutions have been discussed that would tweak HOS during FMCSA Motor Carrier Safety Advisory Committee meetings, however, there has been little discussion on possibly lowering the amount of hours a driver can be on duty.

Meanwhile, other federal agency attempts to limit driver fatigue, in general, and improve motorcoach safety, specifically, including the FMCSA’s Compliance Safety Accountability (CSA) program, have been met with mixed reviews.

“Obviously, we support efforts to remove unsafe carriers off the road 100 percent and want to make sure FMCSA targets the companies that need to be targeted,” says the UMA’s Parra about CSA. “The CSA scores are very telling in that regard, because driver fatigue is one of the key indicators in there, and so I think it’s smart that the FMCSA is using that as a guide. I mean the whole emphasis, the primary goal of the CSA scoring system, is to prevent accidents.”

CSA builds on the FMCSA’s former processes for assessing and improving the safety performance of motor carriers and drivers, including an enhanced compliance review and more focused and efficient interventions tailored to address specific problems. The centerpiece of CSA is the Safety Measurement System, which analyzes all safety-based violations from inspections and crash data to determine a commercial motor carrier’s on-road performance.

The CSA program recently went through its final revision in August. While the program is widely regarded as a positive step toward improving motorcoach safety, many in the industry feel the Behavior Analysis and Safety Improvement Categories (BASIC), especially the one covering “Fatigued Driving,” are too broad.

“Even if you look in drivers’ records and look at cases where companies have been cited for fatigue, that category is so broad I would guess 80% of the time, if not more, most of those are log violations that are typically mistakes,” says Pantuso. “Because of the way those are categorized, we’re seeing more and more folks raise the question if we’re seeing more fatigue out there? Not at all. We’re seeing a broad category that includes a bunch of things, fatigue of which is one, but the title of the BASIC is called ‘Fatigued Driving,’ and we’ve told FMCSA on many occasions that has to be fixed.”

Over the last several years, the U.S. Department of Transportation (U.S. DOT) has also taken aggressive efforts to strengthen overall motorcoach safety and enforcement by doubling the number of bus inspections of the nation’s estimated 4,000 passenger bus companies — from 12,991 in 2005 to 28,982 in 2011.

In May, FMCSA and its state and local law enforcement partners conducted safety inspections of motorcoaches, tour buses, school buses and other commercial passenger buses in 13 states and the District of Columbia. This effort resulted in over 2,200 safety inspections and the successful removal of 116 commercial motor vehicle drivers and 169 buses from the roadway for substantial safety violations.

Additionally, the new surface transportation bill, Moving Ahead for Progress in the 21st Century (MAP-21), increases federal oversight through a new grading system and a more stringent criterion for entering the industry. It also authorizes the Secretary of Transportation to take more drastic measures to prevent unscrupulous carriers from remaining in business, including impounding the entire fleet.

Littler feels these kinds of measures do more for improving safety and removing so-called “rogue operators,” who often are out of compliance in areas such as HOS, from the industry than focusing on further HOS rulemaking.

“Somebody who’s not willing to follow the rules, is cutting corners and is willing to do illegal trips, that puts the entire compliant industry at a competitive disadvantage because that’s where the customer is going to go,” he says. “We know from the past that they want to go for the cheapest ride, and the companies that provide the cheapest rides are going to cut corners, so they are the ones everybody wants to clean up or get out.”[PAGEBREAK]
Managing risk
Besides proper training for drivers and their families on fatigue and the lifestyle and medical issues associated with lack of sufficient rest, the most important thing an owner must do to try and prevent driver fatigue is manage the risk of a trip and properly schedule drivers.

As mentioned earlier, one of the keys is avoiding trips that require driving overnight or within the dangerous hours of 1 a.m. to 5 a.m.

“There is a consumer demand for these overnight trips, but the question is if your company, fleet and drivers are up to the task of delivering that service safely,” says Burkert. “An important question to ask, though, is how do you define safe? If you do it for five years and have one major loss, is that safe?”

As part of its training, Lancer Insurance suggests that drivers work with management to establish proper work schedules that enable them to get sufficient sleep and minimize their exposure to fatigue.

High-risk scheduling issues both parties should be aware of include:

  • Last-minute trip scheduling that does not allow the driver to get sufficient sleep before a trip.
  • Any schedules that do not allow a break every two to three hours.
  • Flip-flopping schedules that vary start times from day to day and week to week.
  • Schedules with repeated nights of driving.
  • Any schedule that requires the driver to work a night shift following two consecutive days off.
  • Frequent shift changes from days to nights or vice versa.
  • Split shifts.

Any combination of schedules that does not allow for at least two periods of night sleep (10 p.m. to 8 a.m. without work) after four or five periods of night driving.

Lastly, nearly all of the experts METRO spoke to suggest that if you must drive late at night or overnight, be sure to stage drivers properly or schedule two drivers who take turns driving and sleeping throughout the trip.

Onus on drivers
Even with an increased knowledge of how the human body works, proper training, the benefits of a healthy lifestyle, staying within the federally mandated HOS rules, and managing risky trips and scheduling, the onus remains on the driver to recognize when they are tired while driving, and most importantly, sleeping when they are supposed to sleep.

“There have been any number of major bus wrecks where the driver was supposed to get rest and was given the opportunity to do so, but chose to do something other than rest with their time,” says Burkert. “What you end up with when that happens is a situation where no amount of rules or regulations can be made to fix that irresponsible attitude.”

In “Motor Fleet Safety, Standards and Practices,” Burkert suggest that drivers should do the following to manage fatigue, whether they sense it coming on or not:

  • Take regular breaks.
  • Beware the effects of medication.
  • Use caffeine cautiously, expect only a temporary boost.
  • Adjust seat position occasionally.
  • Stop and take a power nap (20 minutes or so).
  • Prepare by obtaining proper rest.
  • If tired, stop and rest.

What makes driver fatigue such a difficult issue to address is you can cover every one of the multiple layers associated with curbing or managing fatigue, but the decision to rest falls solely on the shoulders of the driver. Their choice to not do so can in turn jeopardize the good names of both the operator and the industry. Still, the ABA’s Littler says operators have to do all they can to help drivers make the right decision.

“The drivers have a duty and responsibility to employers, passengers and the general public to rest when they are supposed to, just like an airline pilot or maritime captain,” says Littler. “Do we have technology that can test a driver before he gets behind a wheel? I’m not certain. We’ve heard there are some warning technology products out there, but really, it comes down to continually working with your drivers and stressing the importance of doing the right thing.”