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Focus: Transportation Management

Feature Article from Our Transportation Management Subject Area - See All

From SCDigest's On-Target E-Magazine

Feb. 28, 2011

 
Logistics News: Schneider National Exec Tells FMSCA that New Hours of Service Rules will Drop Productivity 5%, have no Impact on Safety

 

Osterberg Says Better Idea is to Mandate EOBRs Now, and Focus on Issues with Drivers..... Snoring?

 

SCDigest Editorial Staff


The debate continues over proposed changes to the current hours of service (HOS) rules, first released in late December, with the comment period over March 4. (See Proposed New Hours of Service Rules a Lump of Coal in Trucking Industry Stocking, ATA Says)

On Feb. 17, the FMSCA conducted a "listening" session, hearing hours of input from a variety of sources.

Our blogger David Schneider was there in Washington DC, and he says that "By far the loudest and most emotional voices in the listening session comments come from the safety advocates. Some of these organizations are founded and led by parents whose adult children were killed in truck related accidents. Other advocates come from traditional Washington DC based lobbying organizations.".

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Schneider's own modeling tools estimate that it will incur a productivity hit of nearly 5% from the changes, and that it would have to pay drivers and extra $3000.00 per year to keep them whole from the changes. .
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He adds that "The most numerous comments came from the trucking industry, both executives and drivers. While the executives were careful not to lay blame at the feet of the shippers, the drivers were quick to blame delays at shipper loading docks as justification for relaxed rulemaking."

One presenter was Don Osterberg, Sr. VP of Safety and Security at carrier Schneider National. In a detailed and effective presentation, Osterberg says that although he and Schneider are strong safety advocates, he does not believe that the proposed HOS changes will do much of anything to improve safety, based on quite a bit of data on the subject. Schneider's own modeling tools estimate that it will incur a productivity hit of nearly 5% from the changes, and that it would have to pay drivers and extra $3000.00 per year to keep them whole from the changes.

David Schneider notes the impact would likely be higher on carriers that don't have the highly sophisticated network optimization tools that Schneider employs.

The full commentary from Osterberg can be found on the video replay, with his comments starting at about the 22:45 mark: FMSCA HOS Listening Session.


Below is an only modestly abridged transcript of his comments from that listening session.

"I will be providing a truncated version of far more comprehensive comments that will provide [later], We just recently completed the modeling they we've done and are refining it to provide I think specifically what you [the committtee] has asked for in terms of the data that will support our recommendations. and we are going through understand the impact of the new rules.


I think Schneider National has long embraced safety as a core value. I think I could be described as quintessentially an advocate for public safety.

I certainly appreciate the focus on fatigue related crashes. I have said many times I think fatigue is a more significant cause of crashes than is perhaps reported in some of the databases, for the reasons that your proposed rule called out very effectively related to crashes.

I am also excited for the focus on driver health and wellness. Let's face it, commercial drivers generally speaking are unhealthy. We have an over-representation of obesity and tobacco and other things.


Now, if I believed that the current proposal as it stands could improve public safety, I would have the courage to stand up and say that I endorse the proposal. There are many things in the proposal that I like, and I think there is some good in that. However, there are some problematic components, not in terms of the specifics, but in the lack of data to understand what effects they would have.

I can't say today that the proposal as I read it would improve public safety. It certainly won't make it worse. I don't think you can say that it will improve safety either.

I am going to talk briefly about some modeling that we did, and I will provide a detailed report on this. We co-developed a model back nearly 10 years ago with Princeton University. It has an embedded dispatch optimization component to it. We use it to design our networks. It is a very credible model. We actually received in 2009 the Wagner Prize from the Institute for Operations Research and Management Science (INFORUMS) for this model.

I will provide the details of the model to your data modelers and engineers so that you can have confidence in the outputs.

Let me talk to you about the high-level outputs. We looked at our network of freight, and we have a mix of dedicated over the road, random route, irregular drivers as well as liquid bulk and intermodal drivers. We calculated that the productivity impact of the proposed rule would be a negative 4.72%.

That is a number I can provide you the details on.

We can also model driver time at home and frequency that they can be at home under the current proposal - and this is a learning model under several iterations - and we found that we would get drivers home 25% less than they do today.

Interesting, as we looked at the productivity impact, we operate essentially with our baseline of 501.7 miles [we assume per driver per day]. Under the proposed rule, that would reduce to 478.


If you look at the loss of 24 miles per day, and you embrace the need to keep the commercial driver whole from a W-2 perspective, we will need to increase driver pay by about $3000 a year just to offset the negative productivity impact.

(Transportation Management Article Continued Below)

 

CATEGORY SPONSOR: SOFTEON

 

 

Now that's probably appropriate anyway, with the market we are going into, with supply and demand being what it is, I think we are going to have to increase driver pay. That will be a component that will add to cost to the supply chain.

The most important thing is to talk about safety. We looked at our percent of preventable crashes based on hours since last break.

So when you really try to answer the question, Is the 11th hour of driving prohibitively risky, that answer is "It depends." It depends on when that occurs.

If the 11th hour occurs during the red hours of midnight to 5 a.m., certainly I think you will have seen an over-representation there, but if the 11th hour happens to occur during the circadian high based on our data [circadian is a word that related to 24 hour cycles, but the reference/meaning here is not clear to us], we do not see any elevated risk. In fact, I will show you the percentages: hour one has the highest percentage of preventable crashes. Then it drops down. There is a slight increase between hours three and four hours since last break. Then it drops off fairly consistently to a low point at nine hours since last break, then goes up modestly between nine and ten, and then drops off dramatically in the 11th hour of driving.

I have normalized that as well for "exposure" and that is a little bit of a tricky calculation to make. What you will find in the normalization is that 11th hour of driving crash rates are not over-represented relative to other hours of a driver's work day.

Then we looked at crashes by time of day. I think it is important to understand when these crashes are occurring. As we look again as a percentage of preventable crashes, the peak for us happens at 11:00 a.m. It drops off consistently until midnight, and it is flat between midnight and 3 a.m. and goes up slightly from 3 a.m. to 6 a.m.

There is something there, so as you contemplate, and I know there was a question about how we might think about night time driving differently, it's clear to me there is risk in that 3 a.m. to 6 a.m. period.

I want to transition just a little bit and talk about the restart provision. I have perhaps a different view than some based on our modeling. I don't believe that the restart proposal as you currently drafted it will have a significantly negative impact on productivity. It will be a nuisance for drivers who break over the road, but when we look at our fleet, we have 1.73% of our driver's that break between 34 and 40 hours. Those are the folks that are breaking over the road. And I do agree that [the proposed restart rule] can be an issue for them.

But the average restart break that our fleet takes is 62 hours. So certainly well in excess of what the proposal would be, so I don't see a significant issue with the restart proposal.

Let me wrap up with a couple of recommendations. I am not here to suggest that the current hours of service rule is perfect and that it can't be improved upon, because it probably can. However, I believe that we need to be thinking sequentially about some of the priorities as they relate to reducing the fatigue-related crashes and improving driver wellness.

First of all, we have to address the issue of regulatory non-compliance. I applaud the agency for your notification of proposed rulemaking that will mandate electronic logging or EOBRs [electronic on-board recorders] across the industry. There is wisdom in that proposal long overdue.

What I would argue is let's proliferate electronic logging into the industry. Let's measure then based on a compliant driver the effects of the current hours of service rules, and if they need to be changed then let's change them.

So, it would be sequentially, [first] the EOBR mandate, proliferation to that and then revisit the hours of service rule.

And I am going to hit a theme as well - I think this is about fatigue, and driver wellness. If we are serious about fatigue and driver wellness, I have a tremendous amount of data that you may be aware of that if we address the issue of sleep disorder among commercial drivers, we will have a far more significant effect on reducing fatigue-related crashes. What we have found is that drivers once diagnosed and treated for obstructive sleep apnea, they lose weight, they have improved quality of life, improved energy, and there is a much larger issue as its related to fatigue-related crashes than hours of service rules."

Any reaction to Osterberg's comments? Do you agree with his recommendation to drive electronic on-board recorders into the industry first and then look at HOS? Does the sleep apnea issue surprise you? Let us know your thoughts at the Feedback button below.

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Recent Feedback

2011-03-10

 


I agree with Mr. Osterberg that EOBR are a key for ensuring HOS compliance.  Likewise, sleep apnea when diagnosed and treated has a profound effect on fatigue driving; however, not all truck drivers are affected by sleep apnea.  Drivers that drive 11 hours and are on duty for 14 hours (the maximum hours allowed before taking 10 hours off) are going to experience some fatigue and in a period of five to six days the effect is going to be somewhat cumulative.  Driving in itself is stressful enough, especially in cities, but in heavy traffic with cars whipping in and out of lanes it is impossible to maintain a safe following distance, nevertheless, the commercial driver is expected to do so.  And, the commercial driver is expected to watch out for the distracted drivers that are talking on their phones, using their computers, reading documents, eating while driving, etc.  I know the DOT only regulates commercial equipment; however, if you really want to make the roads safe, do something about the non-commercial vehicle drivers.

John Cox
Ceva Logistics

 

 
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