Role of Human Factors in Preventing Cargo Tank Truck Rollovers (2012)

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27 The objective of HMCRP Project 13, “The Role of Human Factors in Preventing Cargo Tank Truck Rollovers,” is to understand root causes and driver influences that are involved in—and good company practices that seek to mitigate—the approximately 1,200 cargo tank truck rollovers that occur each year in the United States. The risks and stakes are high with cargo tank trucks: liquid contents subject the vehicle to higher centrifugal forces than general cargo, leaving the driver with a smaller margin of error. In fact, the dynamics of many incidents are such that the rollover had already begun before the driver was aware. Fleet operators—both private and for-hire carriers—invest in technology, operations, and their drivers to reduce roll- over incidents. According to ATRI (2011), these drivers tend to be both more experienced and higher paid than the indus- try average, but the experience alone cannot be counted upon to effectively manage these risks. Safety training, company culture, the constant reinforcement of awareness, vigilance against distractions and fatigue, health and wellness, and the involvement of driver families are the key ingredients in pre- paring and maintaining drivers for the challenging assign- ment of driving a cargo tank truck. These case studies address the good practices in place within and outside of the motor carrier industry that can be applied by fleet operators in three major focus areas of the project. 6.1 Case Study 1: Training and Safety Programs This case study includes a number of tools for terminal managers or carriers in addressing the human side of rollover prevention. While the second and third case studies explore single topics (e.g., behavior-based safety and fitness for duty) more deeply, this case study touches on five topics that can help the carrier to help the driver in avoiding rollovers. This case study begins with the Australian VicRoads Heavy Vehicle Training Program. The program was developed by VicRoads, a state government roads authority from Victoria, Australia. The discussion of the VicRoads program is fol- lowed by four other related topics: the components of an overall safety program, investigating rollovers, using location data, and available training materials. 6.1.1 Overview The VicRoads program is both a multi-faceted training course and a stepping stone toward developing consistent long-term safety behaviors across the organization. It received highly favorable reviews for its ability to speak to drivers and its results in lowering carriers’ rollover rates. By integrating a conventional slide presentation, a video, personal discus- sions, a model truck on a tilt table for rollover demonstra- tion, and framework to be adapted into a code of behavior, the program communicates through a variety of media and helps the drivers to internalize the message. The largest obstacle to bringing the program to North American cargo tank carriers is not the Australian accents or metric units but the Australian equipment used in the training—logging trucks, agriculture goods, dry freight, and right-hand-drive vehicles. Many in the American test audiences believed that the program is benefi- cial as it is. Others observed that drivers would not connect as well if the trucks do not look like their own. Even those with reservations about the equipment saw merit in the program. The tank trailer for the VicRoads model truck on a tilt table dramatically demonstrates the effects of a dynamic load. 6.1.2 Case Study Methodology Information about the program was obtained from VicRoads, and the curriculum materials themselves were reviewed by the project team. The material was shown to audiences of various perspectives within the North American cargo tank industry for their assessment. The checklists in the remaining portions of this case study draw on the earlier sections of this report and the diverse experience of the project team. C h a p t e r 6 Case Studies

28 ular situation. It includes recommended actions for both management (e.g., vehicle selection and trip planning) and drivers (e.g., the speed of vehicles). Additionally, a guidebook helps managers implement the program. The DVD includes a number of research reports. Many other practices—such as onboard monitors for speed, daily checks of fitness for duty (FFD), and award picnics for safe drivers—are in place or in progress among carriers in Australia. They are not included in the VicRoads program because it is narrowly targeted on the driving itself. Some of the components of the wooden model truck on the tilt table are in Figure 2. Different loads can be put on the trailer to demonstrate different effects. The white rod in the clear cylinder simulates a liquid load. When the tilt table is raised slowly, the rod leans toward the lower side of the cylin- der (see Figure 3), yielding a lower threshold than if it had remained in place. If the person demonstrating the model gets the rod swinging back and forth to simulate sloshing, the truck can tip over at quite a low angle. The bag of sand and the bag of oatmeal each weigh 2 kg. The bag of sand in the box trailer, as in the figure, simulates a load of gravel. Replacing the sand with the oatmeal is the equivalent of a driver’s carrying a load of wood chips instead of gravel. The weight is the same, but the center of gravity is higher, and the roll threshold is notice- ably lower. Figure 4 shows how the trailer wheels lift off the pavement before the tractor wheels, as in a real truck. How the presenters dress is important: mechanics will relate better to someone who is not wearing a suit and tie. 6.1.3 VicRoads The VicRoads Heavy Vehicle Training Program consists of an entire curriculum and includes the media and materi- als for presenting it. In addition to its comprehensive train- ing materials, it includes a model code of behavior. Drivers, managers, and other stakeholders can revise the code of behavior to make it personal and directly applicable to their own operation. Doing so is a step toward implementing a safety culture in an organization (as in Case Study 2) rather than simply having a one-time seminar. The training material integrates many methods of presen- tation, bringing the material to the drivers through a vari- ety of experiences. Like many sets of training materials, it includes a professionally produced video to be interspersed with a set of slides. Its unique and perhaps most powerful fea- ture is a wooden model truck on a tilt table, as shown in Fig- ures 2 through 4. Different types of trailers and loads can be put in the truck to show their effect on the rollover threshold. The model is a way to get the drivers engaged in the training, especially with a skilled presenter. Most carriers have established driver training programs that include a rollover segment. Portions of the VicRoads materials can be used to complement an existing training program. A complete presentation of the VicRoads package can fill a 1-day rollover training seminar. Implementing the code of behavior is a long-term undertaking. Elements of the Program The program consists of four key elements: 1. Model truck: Nothing conveys how easy it is to roll a truck better than seeing one go over. A wooden model truck on a tilt board is weighted so that its trailer will go over at the same angle that would take over a real trailer. The instruc- tor can tip the model several times while the drivers watch and understand. 2. Video: The video has drivers speaking of personal roll- over experiences, other fleet personnel expressing their involvement, and a narrator explaining principles of physics and safety. Footage of several accidental rollovers exemplifies the consequences. Many of the examples are of logging trucks, which also have a high center of gravity, and one of the segments is devoted to tanks. 3. Presentation: A series of slides for the instructor to show the students explains the elements of physics at play (e.g., center of gravity, inertia, and centrifugal force); personal- izes the message; and stimulates discussion. The presenta- tion includes short video segments and animations. 4. Framework to develop a code of behavior: The template is for management and drivers to adapt to their own partic- Figure 2. The VicRoads model truck on the tilt table; three loads are shown.

29 Because drivers sometimes have an antagonistic relationship with law enforcement officers, officers do not wear their uni- form when they meet with drivers. A road agency shirt identi- fies who they are, but has been found to be less intimidating. VicRoads reported the same observation as many others interviewed for this project: the whole organization must be oriented toward allowing the driver to drive safely. From the CEO to the truck washer, all have an equal role to play. Uniqueness of the Program When asked what sets the VicRoads Heavy Vehicle Roll- over Program apart from other rollover programs, the rep- resentative said that the numerous other campaigns and videos are only parts, but not the whole, program. It really is four parts—video, presentation, models, and framework to develop a code of behavior—and the power of it is that all of those parts together are more than the sum of the parts. The objective is to simplify all the parts so that everyone can understand it. No question is regarded as “too dumb” because someone else will always be too scared to ask and someone else will always need to know. The other element is passion. Giving someone a video does nothing more than provide them with something to watch; presenting, answer- ing questions, listening to the problems, and working to fix them really makes the program work better. A good manager will go a step beyond posters and a video and enable employees to carry out their jobs in a way that is safe, has sufficient time, and is in accordance with traffic laws. It is intended that the carrier use the tools to develop, sustain, or improve a safety culture that incorporates these elements. VicRoads does not create the culture for the carrier, but helps it with tools to change the organization and its approach to rollover prevention. Outreach VicRoads currently uses a combination of trade shows and meetings of targeted high-risk groups and industry associa- tions [e.g., the American Trucking Associations (ATA)] to spread the message. They are often asked to do a presentation or information session to help. They also “train the trainer” when asked, typically by safety staff in an organization. The main distribution for these venues is by a DVD pack, which contains the material for the presentation, video clips, the framework code of behavior, model dimensions, research products, supporting information on a DVD, and a guide- book on how to use it. The other method is via VicRoads website, where the material can be downloaded (www.vicro ads.vic.gov.au/Home/Moreinfoandservices/HeavyVehicles/ VehicleManagementAndSafety/HeavyVehicleRolloverPre ventionProgram.htm). To provide for the owner-operators and small carriers, VicRoads asked larger entities to conduct training sessions so that the smaller operators did not lose out on safety. The bigger companies have agreed to run courses at their own expense and to invite the smaller carriers to the presenta- tions, realizing that training the small carriers may save the life of one of their own. A number of approaches have been taken to encourage the smaller companies to attend the training. Smaller players often get their work by sub- contracting from the larger companies. Those with current contracts can be told that attending the training is a condi- tion for renewing the work. Figure 3. The rod in the cylinder simulates a liquid load in a tank. Note that the rod rolls toward the side even when the table is raised slowly. Figure 4. The trailer tips over at a lower angle with the oatmeal in the trailer than it does with an equal weight of sand.

30 Bringing the VicRoads Program to North America The VicRoads material was developed by and for Austra- lians. Part of this project was to study what would be involved in bringing the VicRoads program to the tank carriers of North America. To enable this effort, VicRoads sent a num- ber of DVDs with the curriculum and donated the use of a model truck kit. The materials were presented, in abbreviated form, to a group of safety managers and to two medium-size tank carriers. Presentations were made in both the eastern and western United States. Everyone involved at one carrier—drivers with 3 to 30 years’ experience and a manager—wanted to have a full meeting after seeing a brief introduction. Drivers asked questions and learned something they did not previously know or under- stand. Personnel at another tank carrier said that about a quarter of the VicRoads topics could be highly useful to them. The rest, they thought, do not pertain to them—the logs and hay in the video are not hauled in tanks. They agreed that the discussion of the laws of physics and centrifugal force is germane, but their own in-house material covers those top- ics. More than one viewer observed that their drivers would relate better if they could picture themselves and their own trucks in the video and slides. Managers from one carrier went further and said that the non-tank trucks would be a mild diversion. It would be difficult showing the VicRoads video to their drivers, telling them to pay attention to some parts but not to the non-tank parts. After hearing the discussion about applicability and similar vehicles, one senior driver spoke up: “A rollover is a rollover, and a driver is a driver.” His point was that a driver of any vehicle could benefit by following the material: no special effort is required to bring the curriculum to North America or to tank operations. The model truck helps to engage the audience. A skillful presenter will make the presentation interactive, asking driv- ers to predict the angle where the truck will roll over. Some who saw the presentation liked the tube inside the cylinder to simulate a dynamic load (see Figure 3). Some liked the triangles of different heights (see Figure 5). The models are simple and easy to understand. No reviewer expressed an opinion that the Australian accents in the video were an obstacle, and only a few thought that driving on the left side of the road was a mild hindrance. An American editor going through the slides observed that some of the terminology is distinctly Australian. Appropriate American terms were easily substituted after consulting with the material’s author. Some did suggest that the narrator ought to be an individual with “instant and strong” credibil- ity. A member of the ATA America’s Road Team would be a good candidate. The final step for making the curriculum available to North American tank carriers is to find a distribution channel. Not every carrier can afford to buy the model truck kit, nor does every terminal need one. A central location can serve as a “lend- ing library” to schedule and ship the kit. The videos, slide presen- tation, and other electronic materials need to be made available either through a website or from a vendor selling DVDs. 6.1.4 Components of a Good Overall Safety Program A good overall safety program covers the entire operation. It centers around the driver, but includes everyone else that supports the driver, handles the order, or works with the product. The customer has a role, too. Driver training, such as the VicRoads program, is a key element that must be sup- ported by everything else that happens at the terminal. The spoken message of the training has to be reinforced by every- one’s daily actions. The driver’s good intentions have to be complemented by the right equipment and by safety-minded schedules and policies. Certainly, overall safety is a broad topic that cannot be handled here. This discussion includes the factors that are most relevant to rollovers and parallels the themes of the rest of the report—driver, equipment, environment, and culture. (See Appendix D for this discussion in checklist form.) Adequate, recurrent training is essential. A good safety program engenders a corporate culture in which even small matters are corrected and rules are followed, such as in Case Study 2 in Section 6.2. A corporate safety mindset ensures the Figure 5. Wooden triangles of various heights and widths convey simply the concept that wider and lower is harder to tip over.

31 driver is fit for duty upon arrival at work, as in Case Study 3 in Section 6.3. A good overall safety program evolves, according to the lessons learned from mishaps—either within the com- pany or in others. If there are no rollovers in recent memory, it’s a good thing. The checklist of possible causes under the investigation heading can be a checklist for a model safety pro- gram. Make sure those possible precursors are found as soon as they creep in, and not in the investigation of an incident. The sketch in Figure 6 shows the importance of keeping safety margins in all areas—driver, equipment, culture, and the environment. If all factors are kept in the green zone, then a bad event is unlikely. When only one aspect momentarily lapses into the yellow zone, the protections of the other mar- gins of safety are there to keep trouble at bay. The possibility of a rollover begins to rise when more than one area is in the yellow zone. What may have been a short but adequate fol- lowing distance on a good day may be too little distance on a rainy day with a tired driver. Training needs to be refreshed—principles of safe opera- tion need to be in everyone’s mind, every day. Training spe- cific to rollovers can begin with one of the curricula discussed in Section 6.1.6; this needs to be reinforced by talks with other drivers and seeing everyone in the entire operation taking all aspects of safety seriously. Over time, drivers may learn the limits of their truck with a certain load and drive to those limits. A number of rollovers have followed a change in load, a change in road conditions, or even a change in tires. Driver training is more than watching a video or reading a booklet. To truly embed the principles in a driver’s daily routine, the drivers need to see people at all levels of the com- pany walking the walk. Training should include discussions among several drivers to talk it over and ask questions. There are two points that are important to make to a driver who is transitioning from dry freight to a tanker: 1. The center of gravity of the load in a tanker is almost always higher than it is in other trucks. Trucks need to take curves at slower speeds than do cars, and tankers need to take them even slower. 2. The load in a tanker will shift. The effect in sudden maneu- vers is commonly known, but a moving load in a tanker will lower the rollover threshold even in a smooth, steady curve. Many carriers put a partially filled water bottle in the cab for a trainee to watch. All truck drivers need to keep two caveats constantly in mind: 1. Rollovers, unlike other kinds of crashes, do not warn the driv- er they are coming. An experienced driver can feel when a following distance is too close or see when another driver is erratic. In contrast, because the rollover starts in the semitrailer (or in the pull trailer), the driver in the cab will not sense the impending situation until a rollover is inevi- table. Drivers have to be trained to avoid rollovers not by feel—they need to stay well away from the roll threshold. 2. Excessive speed in a curve is not the primary cause in a major- ity of rollovers. Some tankers have rolled because a driver did not properly “square the corner,” and the trailer tires came across soft ground and rolled to the inside of the curve. Similarly, propane and heating oil deliveries are often on narrow roads where a tire in the soft shoulder can mean a rollover. Many rollovers have occurred when a driver swerves on a straight road segment to avoid stopped traffic ahead. There are a number of potential causes of rollovers, and drivers need to be aware of all of them. Some seasoned veterans even tell of trailers that have rolled after they were dropped. The trailer might be on uneven or soft ground, or the landing gear may have been bent from carelessness. Several contacts said that discussing mistakes in an honest, non-threatening manner is a valuable learning tool. Drivers can appreciate the conditions leading to a rollover through examples of specific rollovers. They learn what happened and can discuss among themselves what the driver involved in the rollover could have done differently. One national company stands down the entire operation following a rollover until every driver has been briefed on it. (This drastic action also brings home the significance of a rollover.) Larger companies would have their own experience as topics for discussion. Figure 6. The four main factors of safety— driver, culture, vehicle, and environment—overlap. A good safety program will keep all factors well into the safe zone and away from the margin.

32 Smaller companies would need to be provided narratives and sketches of rollovers from, perhaps, their insurance carrier. One carrier parked severely damaged vehicles at the terminal before sending them to the salvage yard. It reminds the driver before starting a shift of the malleability of steel. Some emergency actions required of a driver are counter- intuitive. Perhaps the most obvious is steering straight ahead even if a deer is in the road. Similarly, if a tire suddenly drops off the pavement, the initial reflex to steer it back on must be avoided. The work in these cases would be to compile a list of emergency conditions in which even experienced drivers need refresher coaching. Experienced drivers and safety managers will be asked to give a consensus response to each situation. At a minimum, this could be a topic for a safety meeting. One carrier uses a simulator to run drivers through sudden situa- tions several times until the proper response becomes natural. Student pilots are taught to prevent a plane from stalling, but they also must practice controlling a plane that is stalled. For carriers with the resources, the list of emergency situations can be programmed as a set of simulator scenarios. Some examples from experience highlight the importance of making safety the responsibility of everyone in the opera- tion. A scheduler needs to appreciate that a truck traveling more than 1,000 miles would not be able to arrive within a 20-minute window. At some plants, the driver of a late truck may have to wait 20 hours to get the next available unloading slot. Similarly, some consignees have a “clock-watching” men- tality: they would shut the gates at 4 p.m., regardless of the fact that the truck was just a few miles down the road. These reali- ties can encourage drivers to push the limits to arrive in time. Many carriers keep a file of “journey plans” for each cus- tomer so drivers know to what to expect on a delivery. The journey plan specifies a route and identifies possible hazards such as a sharp turn in the road or a grade leading to the cus- tomer’s property. It may list an alternative route. Some carriers provide turn-by-turn directions; others do not, listing only the peculiarities and hazards of the route. The journey plan notes whether deliveries are restricted to certain hours. If the cus- tomer is a retail service station, the map may indicate the loca- tion of vents and overfill indictors. A sample journey plan can be seen in Figure 7. Terminal managers can help drivers to be on guard for systematic causes of rollovers—for example, they can review journey plans with drivers to ensure they are up to date. Managers should ask whether drivers are taking the best route into a service station, or whether they enter from a street that requires the rig be jackknifed as it goes around a curve. 6.1.5 Finding the Root Causes of Rollovers A mishap of any sort is an interruption to business—with both human and property costs—but it is also an opportunity to improve the operation. By figuring out what led to a rollover, a carrier can make adjustments to prevent it from happening again. The findings of the investigation can be incorporated into the driver training. A proper investigation can take time, but is well worth it—an investigation costs less than a repeat. Few incidents are the result of a single causal factor but, rather, a combination of factors. Details of the investigative method can vary, but getting to the true root sources of the incident is crucial to keeping another accident sequence from ever beginning. The purpose of this section is to provide direct guidance to investiga- tors in a series of how-to checklists and observations. After finding a reason, do not be satisfied, but ask why that reason was in place. Realize also that a serious mishap is often the result of many factors all converging at once. It is impor- tant to find other contributors that enabled the primary cause to lead to the rollover. In short, the investigation needs to be a process of digging deeper and going broader. Dig Deeper—Get Beyond the Obvious Many reports list the root cause of the rollover as, for exam- ple, “driver fell asleep.” That information is helpful, but it does not provide much guidance in preventing future rollovers of the same nature. A rule telling drivers not to fall asleep could be a solution, but is not effective. It certainly does not fully reveal the cause of the driver’s falling asleep: • Was the driver ill? • Did the driver stay up to participate in a family activity? • Did the driver have a second job? • Was the driver keeping an inaccurate log? • Does the driver have a medical disorder? – Was it diagnosed? – Was the driver on medication? • Did the boss ask for “just one more load”? • Did the driver recognize the signs of sleepiness, but push on anyway? – Why did the driver make that choice? • Did others in the yard notice signs of fatigue? Without getting to the real causes, it is nearly impossible to develop and implement solutions. Another example is not to be satisfied with speed as the root cause. In one crash, the electronic recorder showed that the rollover occurred when a driver new to the company took a certain curve at 44 mph when most drivers took that same curve at 34 mph. Speed was a problem, but it was not the sole cause. After identifying speed, investigators should ask further questions such as • Was the driver careless on this one trip? – If so, what took the driver’s mind off the job? • Did the driver not know the dangers of speed on this curve? – Did the journey plan indicate that this turn was a hazard? – Why didn’t any senior drivers warn the rookie?

33 – Did the driver ignore available information and road signs? • Was the turn safe at 44 mph when empty, but not when loaded or with a retain? • Was traffic causing the driver to go faster than was prudent? Go Broader—Look for Combinations of Factors Cargo tank rollover accidents, like most incidents, are typ- ically the result of a combination of events. For this reason, it makes sense to view cargo tank rollover accidents as due to factors that collectively erode the safety margin normally associated with routine driving conditions. In planning an investigation, look at the diverse factors at play in prior rollovers. Chapters 2 and 3 of this report have information on these factors. Appendix A of Pape et al. (2007) has statistics on what factors are often present in cargo tank rollovers. The NTSB investigates accidents from all modes of transportation, including those on the highway. The board’s report on the 2009 rollover in Indianapolis (NTSB 2011), Figure 7. A sample journey plan.

34 though more meticulous than most carriers would conduct, is an example of examining all possible contributing factors. Many factors are at work, and the investigator needs to understand how they interact with one another. Generally speaking, these factors can be divided into four categories: 1. Driver, 2. Vehicle and equipment, 3. Roadway environment, and 4. Company culture. Driver. Within this context, there are a number of driver- related factors. These include the following: • Personal (e.g., experience, training, age); • Physiological (e.g., health, visual and cognitive capabili- ties, strength, fitness to drive); • Attitudinal (e.g., commitment to safety, driving habits, frame of mind); • Information gathering (e.g., situational awareness, visual surveillance, hazard recognition); • Driver state (e.g., use of alcohol or medications, alertness, capacity); and • Organizational (e.g., complying with regulations, properly monitored, gets proper rest). Analyses of prior cargo tank rollover accidents have shown that any number of these driver-related considerations are pres- ent as contributing factors. On accident reports, these factors manifest themselves in actions that are direct causes of the acci- dent: operating too fast for conditions, following too closely, making ill-advised lane or turning maneuvers, poor directional control, and failure to heed signage. If fatigue is suspected, a good resource is NTSB’s “Methodology for Investigating Oper- ator Fatigue in a Transportation Accident” (NTSB, 2006). Equipment. Most tank carriers, especially those hauling hazardous materials, can be expected to keep their vehicles in top shape. Even so, investigators should not automatically discount equipment failure. A pre-trip inspection would be expected to find obvious problems, but does the driver have training on how to find more subtle situations? Was there a procedure for a driver to report a worn part that may not need to be fixed immediately, but should be replaced soon? Was the procedure followed and verified? Furthermore, vehicle specifications can affect stability. There may be a systemic problem with old equipment that is not as stable as modern equipment (most notably, leaf springs do not resist roll nearly as well as do air suspensions). Equipment factors to consider in the investigation include • Driver factors: – Driver’s ability to identify equipment faults during inspections, – Tire condition, and – Compartment loading for partial loads. • Mechanical factors: – Brake maintenance, – Suspension maintenance, and – Tire condition. • Corporate factors: – Selection of tires and suspension, – Training of drivers and mechanics, and – Recordkeeping procedures. Environment. The roadway environment by itself is rarely the cause of a rollover, but conditions that are less than ideal can allow other factors to become critical. Consider sur- face conditions, visibility, traffic, and construction. Culture. Company culture may be the most difficult to examine. Objective criticism will certainly be hard for those in the company. Defects in culture are also more subtle to notice than, for example, a de-beaded tire. Consider the following: • Do journey plans include all hazards on the route? • Are journey plans updated with changing traffic patterns, new customers, and so forth? • Do drivers actually consult journey plans? • Is training taken seriously? – Is it merely a box to be checked annually? – Is it crowded out of safety meetings by presentations on revisions to the benefits plan? • Does everyone in the terminal make safety their own job, from the manager to the accountant to the mechanic? • Are the principles of behavior-based safety implemented? – Were there short cuts or bad habits leading up to this incident that should have been caught earlier? – Are there perceived (or worse, real) benefits to cutting corners? – Are messages about safety ambiguous? Tips for Conducting the Investigation A portion of the most valuable information about a roll- over will disappear soon after the rollover, when the vehicle is uprighted and towed. Take photographs, measurements, and interviews promptly. A hazmat carrier would have an established action plan and phone number to call to clean a spill. All carriers should consult with their legal counsel and insurance carrier to develop a similar action plan for gath- ering and preserving information promptly because certain rules need to be followed. The purpose of an investigation is to lead to improved company procedures to prevent another rollover. Whether individuals violated company policies and should be dis- ciplined is a separate question. The root cause report will

35 be more generally useful throughout the organization if it includes titles and positions rather than individual names. Also, the process will be less threatening to individuals if they know their name will not appear. The investigation team should be highly qualified, expe- rienced, and free of apparent conflicts of interest. A driver and a trainer not involved in the incident should be on the team. Smaller organizations may need to bring in a consul- tant. Team members must keep an open mind and remain objective as the information is gathered. The time to write conclusions will come when all information is in hand. The data should determine the answers—investigators should not seek support for pre-conceived conclusions. Honest cooperation from every level of the organization and every individual is essential. The process begins with the knowledge that a bad outcome happened. It is almost cer- tain, then, that mistakes and oversights along the way will be found. All must realize that the goal is the greater good of the organization. At the same time, investigators have to be sen- sitive that egos, reputations, and more are at stake. They need the skill to probe without prying. A way to keep personalities out of the investigation and to ensure the results are credible is to back up comments with records or measurements. Use the information to make a better operation. A terse investigation report that says “(1) pump broke, (2) pump replaced” has no benefit. If you find that the pump broke because the bearings seized, then examine the maintenance plans and life-cycle expectations. Change the schedule so that the next pump is lubricated more frequently, a different lub- ricant is used, or the unit is replaced before it reaches the end of the expected life. If you find that the pump broke because the product that was going through it was corroding the mov- ing parts, then specify a different pump and examine the pro- cess for selecting equipment. The same principle applies for rollovers. If a truck rolled over because the driver missed the customer’s entrance and had to turn around and other drivers agree that the entrance is hard to see, then put better landmarks in the journey plan or change the journey plan to approach the entrance from the other direction. Appendix E (published online) has a simplified investigation report of a fictitious roll- over. It shows how a complex sequence of events led to the event and how possible initial conjectures would not be right. The reason for conducting an investigation is to find the little things that accumulated to lead to the rollover, and then to find a way to stop the little things before they can turn into big things. 6.1.6 List of Available Rollover Training Materials The U.S. DOT released a video on tank truck rollover pre- vention in August 2010. Copies were mailed to tank carri- ers, and it can be downloaded from their website (FMCSA, 2010). The video has been welcomed by many carriers as a fresh, clear presentation of important material. It received a number of compliments. Similarly, the VicRoads Heavy Vehicle Rollover Prevention Program is new. Its freshness and comprehensive approach make it attractive. The video and most of the other VicRoads materials are described on their website: www.vicroads.vic.gov.au/Home/. Some trainers use information from research studies. One trainer reports that video of crash-test dummies in the cab during a tank rollover dramatically conveys the severity of a rollover. For examples of such videos, see the passenger and driver videos (Videos 11 and 12) from the “Cargo Tank Roll- over Force Verification” report (Battelle, 2006). Only a small number of rollover curricula can be purchased as standalone products. One is the “Tanker Safety Awareness Program” (J. J. Keller, 2011). The monthly posters keep the message in front of the minds of all who see them (see Figure 8). Another is the online “Tanker Rollover Training” from LabelMaster. A number of carriers, including some very small ones, have their own training materials for rollovers and other topics. Some of these carriers have privately shared their written materials or videos with members of the research team. These in-house materials may be specific to a particular operation. Often materials of high quality are not widely distributed. There are some videos that are sent on request, but agree- ments with the participants prohibit them from being adver- tised. Other materials are limited to the clients and affiliates of a particular company. 6.1.7 Rollover Crash Location Data Forewarned is forearmed. Local gasoline distributors with a limited number of customers know their routes intimately. Chemical haulers with a multi-state region, especially newer drivers or those delivering to newer customers, will drive particular roads and ramps less often. In preparing for these trips or writing journey plans for them, knowledge of rollover problem spots would be valuable. The American Transportation Research Institute (ATRI) has initiated research to collect and analyze data on rollover crash locations throughout the United States in an effort to mitigate truck rollovers. The objective of ATRI’s research is to explore innovative methods for identifying sites where heavy truck rollovers are prevalent and to develop an information deliv- ery system to disseminate information about such locations to commercial drivers and other transportation stakeholders. As a first step, ATRI is merging state-level data on truck roll- over events with Fatality Analysis Reporting System (FARS) data to develop a national truck rollover database, effectively mapping the digitized locations where truck rollovers have occurred. Additionally, ATRI is analyzing this database of roll- over locations using GIS tools in order to discover truck rollover

36 clusters or patterns that may indicate areas where instances of large truck rollovers are especially likely. Soon, ATRI will release a publication of “truck rollover hot spots” that will highlight the top ten rollover locations for each state in terms of both the raw number of rollover incidents and rollover rates (expressed as the number of trucks experiencing a rollover per one million trucks operating on a road segment). This publication will be updated as current hot spots are addressed and, consequently, drop off the list, as well as when new hot spots are identified. Next, ATRI will begin exploring methods for disseminating this high-risk rollover location data to commercial motor vehi- cle (CMV) operators and transportation stakeholders in two separate phases. In Phase I, the goal is an in-cab warning system to notify CMV operators in real-time when they are nearing a location where truck rollovers are highly likely to occur; doing so will allow drivers to adjust their driving behavior accordingly and lower rollover risk. In Phase II, the focus will be to conduct an analysis of the features of each high-risk location to inform those who have the ability to address infrastructure issues of potential problems related to roadway design or signage. Essen- tially, Phase I will act as a short-term solution directed at the symptoms (i.e., rollovers), while Phase II will be a longer-term treatment of the underlying causes of those rollovers. Although many technology providers do not currently make data easily available, an opportunity exists to work with stability system providers and automatically triggered onboard camera providers to glean data relating to stabil- ity system interventions or camera events triggered by lateral acceleration above a certain threshold. Information on these near-misses and their locations will also help in developing preventive actions and training. 6.2 Case Study 2: Behavior Management Processes Many of the carriers interviewed for this research have adopted a behavior-based safety (BBS) management approach to reduce the likelihood of rollovers. The BBS approach has been adopted by many companies in the motor carrier and other industries. BBS focuses on what people do, analyzes why they do it, and then applies a research- supported intervention technique to improve behavioral processes. CTBSSP Synthesis 11: Impact of Behavior-Based Safety Techniques on Commercial Motor Vehicle Drivers (Hickman et al., 2007) offers a rich discussion of the his- tory and application of this field. Figure 9 depicts a simple way of viewing the behavior management process. First, proper techniques and accept- able behavior for a task are identified. Then, the employee is observed performing that task. Observations are analyzed, and behaviors not aligned with or contradictory to approved © 2011 J.J. Keller & Associates, Inc. Figure 8. Rollover safety posters, Tanker Safety Awareness Program. Figure 9. Five-step behavior management process. OBSERVE IDENTIFY ANALYZE CORRECT MONITOR

37 methods are noted. The driver must be coached to correct inadequate behaviors. Subsequent behavior is monitored. If behavior does not improve, increasing degrees of interven- tion are used until ultimately the company makes the deci- sion as to whether such improper behavior will be further tolerated. Good driving behavior has been proven to reduce the chances for a truck crash. Coaching, counseling, and peer-to-peer observation (without reprisal) are fundamental in helping foster good driving behavior. BBS should blanket the entire organization. BBS helps not only drivers, but also the safety performance of train- ers, mechanics, and office personnel. As applied to drivers, BBS includes what happens on the road and ergonomic issues particularly relating to cab ingress and egress, hose and fitting handling, and so forth. Transportation entities that are well known for having proactive behavior management programs institute a variety of structured and comprehensive strategies. This case study describes recommended behavior management methods, practices, and tools that can lead to improved driver safety and can be employed in a practical manner. While safety is a focus of every aspect of a driver’s duties, this case study focuses exclusively on driver behavior while the vehicle is in motion (e.g., intentionally excluding loading and unloading opera- tions). The guide gives examples of good practices used by carriers in the trucking industry and in other transportation modes, coupled with published research findings. It contains valuable information applicable to any cargo tank truck car- rier, regardless of company size. This case study begins with the methodology to identify the kinds of organizations that contributed. A special section describes the practices of carriers outside the cargo tank truck industry. The following sections discuss the five steps in Fig- ure 9. The final section has tips on implementing a behavior management process. 6.2.1 Case Study Methodology To identify good practices applicable to behavior man- agement in the cargo tank truck industry, the research team conducted in-depth interviews with four for-hire motor car- riers, two petroleum product private fleet operators, two U.S. maritime carriers (one inland and one ocean-going), one of the largest U.S. freight railroad companies, and a utility company. The carriers haul hazardous materials as part of their business. They were selected from a subset of those who participated in Phase I (see Chapters 4 and 5) of the project and were interviewed at length on issues related to collecting behavioral data, analyzing behavioral data, identifying prob- lems, selecting and implementing corrective actions, and continuing to monitor driver improvement. The four motor carriers are safety-award-winning, for- hire companies that run bulk tanker operations. Two haul hazmat, two carry specialized loads, and one is also a truck- load carrier. The sizes of these companies varied, with one carrier having fewer than 50 power units, three of intermedi- ate size, and one with more than 1,000 power units. Three of the carriers are considered long-haul, and the fourth is a short-haul regional carrier. Some of the carriers employ owner-operators in addition to company drivers, and one has a majority of owner-operators. Information from these carriers was supplemented with less formal interviews with other carriers and from publication. 6.2.2 Lessons from Transportation Sectors Other Than Cargo Tank Trucks Much can be learned by observing the practices of carriers in other transportation sectors where behavior management is a fundamental part of an exemplary operational safety pro- gram. Such is the case with certain carriers in the maritime and railroad industries. Maritime Industry Two marine carriers were interviewed for their behavior management practices. An inland marine carrier uses sev- eral sources of information to evaluate wheelhouse operator behavior while the vessel is in motion. These include place- ment of video cameras in the wheelhouse, use of very high frequency (VHF) radio and radar recordings, and access to data archived by an automated navigation system. While much of this information could be used to moni- tor and correct behavior, the culture within the company is not to impose “big brother” surveillance techniques; rather, this information is only accessed and analyzed after the fact and only if there is reason to suspect a problem. Examples include accident investigations and diagnosis of why certain performance indicators, such as travel speed, are outside of an expected range. A manager rides in the wheelhouse with every operator as part of a routine performance assessment, at least annually, and—typically—more frequently. Wheelhouse operators are also strongly encouraged to minimize personal communication while on duty. However, in the case of extenuating circumstances, use of cell phones, including texting, is permitted. When such communication is necessary, a member of the deck crew is expected to be in the wheelhouse to serve as a lookout. Tools and policies to manage the attentiveness of the wheelhouse operator include • A policy in which a member of the deck crew enters the wheel- house every 2 hours to perform an “alertness check” and • Motion detectors—if the detector does not observe suffi- cient motion for a 2-minute period, an alarm rings in the bedroom of the duty officer and then throughout the vessel.

38 These mitigation strategies are indicative of the carrier’s commitment to a “zero harm” policy, in which risk is managed through four essential components: (1) leadership, (2) a car- ing environment, (3) accountability, and (4) developing work plans with risk assessment in mind. Overall, the carrier’s invest- ment in behavior management is considered to be time and money well spent. A deepwater marine operator implemented a personal- based safety program offered by a safety firm. Mid-level management received training and crews received orienta- tion prior to the program go-live date. The company has seen a direct correlation between the implementation of the program and the achievement of a record six consecutive months without a reportable incident. One drawback was that anonymity had been compromised, which diminished crew acceptance of the program. On the other hand, the ter- mination of some who displayed habitually unsafe behaviors subsequently improved both crew acceptance and morale. Railroad Industry A rail carrier employs onboard devices to collect data for monitoring operator behavior. The company relies heavily on the locomotive event recorder as a means of detecting situations such as speeding and emergency braking. It is also used to help re-enact conditions that were present as part of post-incident investigation. In terms of identifying safety problems and causes, the car- rier embraces the concept of BBS, discussed earlier in this report. Within this program, all employees are expected to practice safety by focusing on their surroundings. If they detect a problem, they are encouraged to report it without fear of being viewed as insubordinate. In cases where man- agement has identified a previously unreported operator behavior problem, the carrier employs a “coach and counsel- ing” approach that is part of the company culture. The intent is to help the operator understand and correct the identified problem without the use or fear of disciplinary action. Another behavior management technique is the use of peer observation groups: one employee observes how another is performing work, documenting areas that could be improved. These suggestions are meant to be construc- tive and are non-punitive to the employee whose work habits have been shown to warrant improvement. This process has produced better tools and improved procedures that remove risky behaviors. This carrier, and the railroad industry in general, employs an onboard device that provides an audible alert and flash- ing strobe if there has been a lack of discernible activity by the locomotive engineer over a defined time span. The ratio- nale is that typically an engineer is braking, accelerating, or providing another action during that period of time. If no action is detected, the alarm sounds as a precaution. The engineer can override the alert when it occurs, but if there is no response, an automatic braking application can ensue. This carrier’s investment in behavior management strate- gies is a reflection of the carrier’s belief that safety is the first rule in the railroad industry. As company employees are empowered to work safely, behavior management policies are being employed in a manner consistent with this philoso- phy. The carrier considers its current practices to be effective in achieving these objectives. 6.2.3 Identification Identification of behaviors and actions to monitor are com- mon across the industry. Vehicle telematics are used to detect actions such as hard braking, stability control, lane departure events, and so forth. Behaviors can often only be observed, behaviors such as maintaining following distance, keeping eyes scanning, actions at railroad crossings, and so forth. Appendix F and G include the items that are observed during ride-alongs and check rides. First establishing the behaviors and actions to observe and control is important in determin- ing the methods and tools that will be used. 6.2.4 Tools for Observation There are many approaches to observation, formal and informal, quantitative and qualitative, human and electronic, supervisory and peer-to-peer. When a terminal manager or even a company executive rides with a driver, it tangibly con- veys the message to the driver that the supervisor values the driver as an individual and considers safety to be worthwhile. It is an opportunity for two-way communication. To supplement human observation, a number of electronic means are available for monitoring driving practices. A num- ber of products are on the market to record data and images. Many collision avoidance systems also allow recording of the number of times they are triggered or nearly triggered. In the better BBS systems, anyone’s comment is valuable and any action is fair game. Safety is equally important both inside and outside the cab. However, because this case study focuses on the driving, duties when the truck is parked are not discussed further. Ride-Alongs One practice all carriers had in common was the use of management or trainer ride-alongs with drivers. Ride-alongs are useful for gathering data concerning how each driver behaves in the cab. For some carriers, ride-alongs are used as part of new driver certification and tenured driver train- ing and recertification. For all carriers, trainer ride-alongs

39 are more common than management ride-alongs, although one carrier requires all staff, including the president, to con- duct a designated number (usually 12) of routine ride-alongs each year. Although these are usually short trips, it sends a strong message of support for the driver’s job and it is con- sidered a best practice for developing shared experiences and mutual respect within the company. Ride-alongs can be an evaluation of general behavior (see Appendix F for a check ride form) or an observation of actions (see Appendix G for an observation form). For small carriers who do not use onboard technologies, this may be the key opportunity for identifying problematic behaviors. One carrier stressed the importance of performing peri- odic ride-alongs as opposed to only following safety inci- dents. The rationale is that drivers are more cautious after an incident and tend to be on better than normal behavior. A ride along will tell the supervisor whether the driver knows the right way to do something, but not what the driver will be doing when no one is watching. Carriers have different approaches to announcing the ride- alongs. Some have a calendar, and a driver might know there will be a passenger next Tuesday. Other supervisors might walk up to a driver at the loading rack and say they are com- ing along on that load. Some believe that if drivers learn about a ride-along as they start a shift, they are more likely to act naturally, allowing more accurate observation of their habits. One manager noted that a driver may be on best behavior for the first hour of a ride-along, but then will become accus- tomed to the passenger as the two begin to talk and the driver will revert to normal habits as the shift progresses. Ride-along observations may be performed by peers, des- ignated senior drivers, safety managers, trainers, direct super- visors, third-party trainers, or other management personnel. Ride-alongs with management can be an opportunity to fos- ter relationships and for management to convey their safety and performance commitment to their drivers and custom- ers. These observations also help management stay informed with operations and learn about issues on specific routes or deliveries that can lead to solutions on a broader scale. Direct observation by riding along with the driver not only provides a means for collecting data, but also simultaneously provides a means for analyzing causes and monitoring the impact of past corrective actions. Observation includes not only the individual actions, but also the day-to-day behav- iors that result in those actions. Simple-but-effective obser- vation techniques are more than adequate for immediate feedback and dialogue to encourage appropriate behaviors and discourage unsafe behaviors. Over time, documented observations by different individuals form an effective data- base of driver behavior. Supported by a culture of trust and shared values and objectives, observations become accepted as a means of raising the safety and performance of the entire organization. However, the absence of this culture can irrep- arably damage even the most technically sound program, where drivers may view peer observation’s primary unwrit- ten goal as avoidance of management interference. The effectiveness of peer observations is heavily dependent upon the culture of the organization. Drivers can be skeptical of the safety culture when they become distrustful of manage- ment’s objectives or of the confidentiality of their reporting. At this point, there is no incentive to provide accurate and action- able input leading to performance improvement of the subject driver. Observers can provide critical feedback when the subject driver trusts and accepts the safety culture. Beyond these envi- ronmental issues, personalities or personal conflicts between the participants may limit the effectiveness of the observation. A small carrier in this study reiterated the importance of ride-alongs to its operation, although it had various meth- ods of collecting driver behavior data. Despite not using any onboard recording equipment (e.g., EOBRs, GPS, or video cameras), the carrier documents delivery information on every trip and thoroughly reviews all paperwork daily. Some carriers visually monitor drivers from a “chase” car at random, unannounced times. The monitoring program itself is not a secret. All drivers are made aware of the program when they hire on and are expected to perform their duties know- ing that at any time they might be under observation. This is somewhat akin to the mystery shopper programs in retail organizations. The companies feel that drivers may perform one way when a passenger is in the cab, but differently when they believe no one is around. Drivers seen exhibiting proper performance are positively recognized, and others receive coaching or discipline commensurate with the transgression. Electronic Monitors Electronic monitors can record measurements of the vehi- cle (like speed and acceleration). Others combine measure- ments with video images in the cab and possibly in front of the truck. Also, records from crash avoidance systems can be useful in tracking driver behavior. Innovative approaches can combine data with traditional carrier safety management practices to help deter poor decisions of drivers. Driver Drowsiness Systems Drowsiness and inattention detection systems use camera technology to monitor the driver’s head and eyes and software to analyze the data obtained. Head position and orientation and eyelid blink and eye movement patterns can be analyzed to make allowances (such as brakes or seatbelts) or to alert the driver. Alarms may include sounds; visual displays in the instrument panel; or vibrations in the steering wheel, pedals, or seat (Murphy, 2010).

40 Electronic Data Recorders and Transmitters Information and communication technologies, collectively known as “telematics,” are used in trucks to communicate with drivers away from the terminal and to record informa- tion on driver and vehicle performance. The majority of tele- matics offerings allow at least some form of communication capabilities ranging from simple phone calls, text messages, and e-mails between the driver and dispatcher to more com- plex text-to-speech functions. To prevent driver distraction, many of these systems by default blank their screens and hold messages until the vehicle is stationary. Many telematics systems provide terminals or home offices with near real-time information on truck location, how it is being driven, the amount of fuel being used, and whether there are any (vehicle or driver) compliance issues. Carriers and fleet managers may also be notified when critical events occur (e.g., hard braking, vehicle yaw and pitch motions, driver-initiated alerts) and receive sensor data every second from before, during, and after an incident. Geo- fencing, an enhanced function of some telematics or GPS systems, is used to alert management when a truck strays off an approved route or out of an approved area. This alert helps provide additional security to the cargo and driver and helps ensure that drivers do not deviate from a safe road onto one that might not be as suitable for large vehicles. Most EOBRs have greater functionality than simply record- ing drive time: many capture vehicle motion and are capable of fleet management services, including load assignments, location tracking, vehicle diagnostics, navigation, and mobile communications. These optional features are usually avail- able for a monthly service fee. The most commonly requested metrics were reported to be electronic logs, vehicle speed, engine speed (RPMs), cornering, hard braking, stopping dis- tance, near misses, roll stability triggers, lane departures, GPS tracking information, fuel consumption and shifting patterns, regulatory compliance data, and critical events. Cameras In-cab cameras received mixed reactions from carrier participants. Carriers agreed that the cameras are excellent coaching tools, providing better insight into what actually occurs inside each driver’s cab and revealing any system- atic problems. Cameras also provide more information sur- rounding safety incidents. A few drivers (particularly the more seasoned ones) expressed concern that cameras are an invasion of privacy, and some carriers even cited customer protests against having cameras in their facilities. As is the case with other programs, coaching has to be maintained over the years for effectiveness to be sustained, and feedback has to be equitable and even for all drivers. An onboard camera and recording system cannot prevent a tanker rollover, but it is invaluable in providing objective information about a driver’s behaviors behind the wheel and assisting in incident investigations. Review of triggered record- ings and coaching of drivers with questionable behavior can improve habits and reduce the chances of involvement in a rollover or other highway incident. Collision warning systems have the capability of interceding when a driver does some- thing wrong, but it will not tell the terminal what the driver was doing when the technology intervened. Was the driver nodding off? On the phone? A camera system can help pro- vide the answers to why the technology had to alert or inter- vene. Figure 10 has two examples of images from onboard cameras, along with the speeds recorded by the systems. Of the two primary types of recording systems—one that is constantly on and archives to an onboard storage medium and one that records short-time segments when triggered— the latter is considered more effective in managing driver behavior. With these systems, audio, video, and vehicle data recordings can be triggered manually by a signal from one of the truck’s systems or by sudden vehicle movements (e.g., swerving, hard braking, or lane departures). When triggered, the buffered video is written to a storage device, and record- ing continues for a set number of seconds beyond the trigger point. A few carriers use cameras to reveal what is occurring Figure 10. Examples of behavior that, at a minimum, warrant coaching.

41 inside and in front of the vehicle. Some offerings also use beeps or light-emitting diode (LED) notifications to provide real-time feedback to the driver. Data collected by the various systems can include speed, g-force, and the date and time of the incident, as well as mul- tiple camera angles and other observations pertinent to the safety event (e.g., running a red light). Data from these tech- nologies are uploaded to network databases, where safety ana- lysts can access them in order to see raw frequencies, establish driver and fleet trends, or identify root causes for specific safety events. This data provides fleet managers and coaches with precise information surrounding safety events as well as being a valuable source of training information. One for-hire cargo tank carrier was required by its cus- tomer to install dual lens in-cab cameras in the customer’s dedicated trucks. The customer purchased and installed the equipment for the carrier. With the cameras and stability systems, carrier’s crash rate dropped by 46 percent during the first year. Following this experience, the carrier installed equipment in its dedicated trucks for two other major cus- tomers (ahead of either customer’s contractual requirements for them). The carrier shared the incident reduction fig- ures with its insurance provider. Impressed with the safety improvements and the company’s initiative, the insurance provider made a one-time purchase of cameras for the bal- ance of the fleet (non-dedicated vehicles) and lowered their insurance premiums. In the kick-off meeting involving driv- ers, the carrier conveyed why the cameras were being used, the functionality and how they were going to be used, both to correct bad behavior and to reinforce proper behaviors. The carrier did not face a high level of driver complaints, in part because its initial implementation was contractually mandated. As the systems began to aid drivers in defending against false or exaggerated claims, the acceptance increased. Crash Avoidance Systems A number of devices have become available in the past 10 years for alerting the driver to a developing dangerous situ- ation or actually intervening to control stability. Nearly all of them can be used to record incidents and track lapses in driver behavior. These systems offer a variety of options to provide immediate, objective feedback to drivers concern- ing their behaviors. The goal of these notifications is to alert drivers of impending danger in the short term and help them recognize and change potentially harmful or inefficient driv- ing behaviors in the long term. Many of these systems utilize vehicle sensors that offer collision warning and blind spot warning system functionality, alerting drivers in advance of potentially dangerous vehicle positions. Data may also be transmitted so that driver-specific and fleet-level safety reports can be generated and analyzed. Considerable research has been funded by FMCSA, the National Highway Traffic Safety Administration (NHTSA), and other entities to estimate the benefits of these technologies and analyze the economics of their implementation (Houser, Murray, Shackleford, Kreeb and Dunn, 2009) (Murray, Shackleford, and Houser, 2009a) (Murray, Shackleford, and Houser, 2009b). A separate study (Murray Keppler, Lueck, M. and Fender 2011) assesses the effectiveness of crash warning systems and other non-traditional approaches to both behav- ior-based safety and fatigue management. While these advanced technologies offer beneficial features and services, carriers must take caution to use them in addi- tion to, rather than in place of, regular driver training and coaching. More importantly, drivers must rely on diligence and skill for their safety, rather than develop complacency and reliance on these technologies. Behavior management has been described as more than the sum of its parts, and technol- ogy must be integrated into a company’s existing safety cul- ture. Nonetheless, the following safety systems and telematics offerings have many attractive features that carriers may find appealing, providing additional opportunities to help manage and monitor a variety of in-cab driving behaviors. Collision warning systems emit a series of visual and audi- tory alerts when the truck is operating within a certain dis- tance of the vehicle ahead. They warn the driver when the following distance decreases below a specified threshold. Alerts become more urgent as the following gap diminishes. Lane departure warning systems (LDWS) are forward- looking, vision-based systems, consisting of a main unit and small video camera mounted on the truck’s windshield. The system records data on the truck’s state (e.g., lateral position, speed, heading) and the road alignment (e.g., lane width, road curvature) in order to warn drivers when the truck is traveling above a specified speed threshold and is veering into another lane in the absence of a turn signal or other explicit sign that a lane change or departure is intended. Roll stability control (RSC) systems continuously monitor a moving vehicle’s lateral forces, automatically reducing the throttle and applying engine and foundation brakes when the RSC recognizes characteristics indicative of rollover risk (e.g., excessive speed in a curve). Electronic stability control (ESC) systems have added advanced capabilities to correct for steering in emergency situations—that is, in addition to addressing roll instability, ESC also corrects for yaw instability (i.e., loss of vehicle direc- tional control). Currently, approximately one-quarter of new trucks are sold with some type of roll stability component, usually as an optional feature, however. NHTSA is proposing a rulemaking that will make roll stability systems in (nearly) all new trucks mandatory, while FMCSA may propose that all existing trucks be retrofitted with rollover-prevention technology.

42 Speed limiters and speed governors are used by trucking companies to control maximum vehicle speed at a specified level. Carriers can set governor speeds with the goal of con- serving fuel or preventing speeding. 6.2.5 Methods of Analysis Carriers without onboard technology rely more on obser- vations and reporting by customers, the public, or compli- ance agencies. One carrier takes data from these reports and from roadside inspections to create an “evaluation matrix” for each driver’s safety record. Based on the results, drivers may be required to take training or retraining focusing on the respective problem areas. This carrier noted that near misses and regulatory compliance issues are leading indicators of risky driver behavior. Some vendors of electronic recording technology offer a complete package of sensors, transmitters, and software to track individual drivers’ behavior. Compliance, Safety, and Accountability (CSA) is FMCSA’s new regulatory program, which was launched nationally in December 2010. The program evaluates CMV carrier and driver safety performance by analyzing historical informa- tion from a 24-month period. Primarily, the program consid- ers the recency and severity of previous crashes as well as the driver and vehicle violations reported on roadside inspection (RI) reports. These events are filtered into seven Behavior Analysis and Safety Improvement Categories (BASICs) and entered into FMCSA’s Carrier and Driver Safety Measure- ment Systems (CSMS and DSMS) to rate the relative safety performance of carriers and drivers, respectively. DSMS scores describing driver safety performance are pri- vate and can be viewed only by FMCSA personnel during car- rier investigations. Employers can access only the raw safety data for each driver that goes into his or her DSMS scores. The rationale for making drivers more visible stems from the fact that a small portion of drivers (10%–15%) account for the majority of safety incidents (30%–50%) (FMCSA, 2004). CSA provides only limited driver information to their employers and should not be considered a primary behavior management tool. Several companies are offering products designed to assist carriers in managing the FMCSA’s new CSA scores. Many systems provide carriers with updated informa- tion on the performance of each driver as well as the per- formance of the fleet, including a breakdown of inspection and violation data and how these affect carrier CSA scores. It should be noted that FMCSA does not provide access to the driver violation histories to these companies, nor does FMCSA validate any vendor’s scorecards or data. Table 11 is an example of one carrier’s quantitative analy- sis of data measured on the road, often referred to as a GYR (green, yellow, red) reporting. There are three measurements: the number of hard braking events, the number of times the vehicle speed was above the maximum limit, and the number of times the engine speed was too high. The reporting criteria were selected from various data available because the carrier felt they were symptomatic of risky driving behaviors—for Driver Name Raw Data: Number of . . . Rate per 10,000 miles ScoreHard Decels Over Speeds Over RPMs Miles Hard Decels Over Speeds Over RPMs 50% 35% 15% Weight Moe 2 2 0 4,403 4.5 4.5 0.0 96.1 Larry 2 1 1 3,535 5.7 2.8 2.8 95.8 Curly 1 3 0 3,581 2.8 8.4 0.0 95.7 Shemp 2 2 0 3,889 5.1 5.1 0.0 95.6 Tom 2 2 2 4,397 4.5 4.5 4.5 95.5 Dick 2 1 0 2,788 7.2 3.6 0.0 95.2 Harry 3 1 0 3,652 8.2 2.7 0.0 94.9 Mary 4 1 1 3,864 10.4 2.6 2.6 93.5 Spot 3 0 3 2,923 10.3 0.0 10.3 93.3 George 3 3 0 3,570 8.4 8.4 0.0 92.9 Martha 5 0 0 3,307 15.1 0.0 0.0 92.4 Homer 7 0 0 3,883 18.0 0.0 0.0 91.0 Bart 7 1 0 4,009 17.5 2.5 0.0 90.4 Wilbur 6 2 1 3,677 16.3 5.4 2.7 89.5 Orville 4 2 1 2,630 15.2 7.6 3.8 89.2 Mickey 7 3 3 4,543 15.4 6.6 6.6 89.0 Peter 7 0 0 3,109 22.5 0.0 0.0 88.7 Ringo 4 0 0 1,703 23.5 0.0 0.0 88.3 Table 11. Example of a quantitative score for drivers.

43 example, hard braking can be an indicator of tailgating, inat- tention, or aggressive driving. All measures are normalized to the number of events in 10,000 miles driving. A weighted average of the metrics is subtracted from 100, and that is the score for each driver. A score above 90 is good. Below 90 requires coaching or further monitoring, and drivers with much lower scores may need further training. The carrier that implemented this system found it a use- ful tool, which led to better awareness and smoother driving. After 5 years, most of the fleet was green with a few yellows. Electronics still detected a small number of incidents, and cameras highlighted some opportunities for correction. In an effort to improve further, the safety director examined the cri- teria and modified them to obtain more improvements. The new criteria raised the bar, and the drivers with lower scores were the ones more often in incidents. Reports like this were posted monthly in the terminal. At first, drivers were identi- fied by number. The drivers figured out who was who, so, ulti- mately, the carrier switched to using driver names. This added the elements of peer support, pressure, and bragging rights. Appendix H (published online) has examples of dashboard performance reporting in a graph and a table. Reports can be generated that indicate targeted actions for the driver and when they occur (and even where they occur). Fleet or termi- nal level reporting can also be developed to evaluate perfor- mance against a peer group, such as the fleet or the industry. 6.2.6 Approaches to Correction The carriers interviewed had driver handbooks that com- piled all company policies and procedures, including the consequences of not following them. Along with the written handbook, carriers stressed the importance of making this enforcement visible to all drivers so that they can observe these procedures being actively implemented. Corrective actions depend on the severity and frequency of the action. Carriers that collect data from onboard technology iden- tify drivers with undesirable behaviors and direct them to intervention with supervisors. More frequent and non-life- threatening behaviors typically can be addressed through standardized remedial training modules that can be modi- fied to specific case circumstances. More dangerous behav- iors would require more customized and time-intensive approaches determined on a case-by-case basis. One carrier also keeps track of positive behaviors and uses a comprehensive bonus pay plan to reward behaviors ranging from safe driving performance to the delivery of favorable service and operating efficiencies. Carriers also keep track of the number of miles each driver and each terminal go with- out accidents, and two hold banquets or award ceremonies to recognize positive milestones. Some carriers have different categories by terminal size. Crashes are a vital time to gather data and should be used as a learning opportunity to be fully maximized. Telematics and other vehicle data should be interrogated for information as to the cause and its underlying factors. Case Study 1 of this report provides additional discussion on accident root cause analysis. One carrier circulates “I was there” memos, which associate individuals with stories of safety incidents that can happen when not exercising good behavior, allowing drivers to share their observations and experiences with others. Drivers who have been in safety incidents are also encouraged to share their experience during monthly or quarterly safety meetings so that the group can discuss the issues and learn how to pre- vent similar incidents. Minor incidents have been displayed on posters; major events have been produced as videos. All carriers reported using reactive measures to investigate the basis for rollover crashes and other accidents. They inves- tigate the causes by going to the scene and interviewing wit- nesses. Carriers with telematics utilize data from the onboard equipment immediately before, during, and after the event. Any driver-related contributing factors are addressed by further interviews, warnings, retraining, written records, or other means. 6.2.7 Continued Monitoring Follow-up action is often required in the case of behavioral issues. As initial expectations are revisited, company leaders will schedule meetings to review driver performance and behavioral data to determine whether remedial actions were effective and sufficient in aligning a driver’s behavior with company policies, training, and core values. Carriers use data collection to monitor improvement, including the frequency of target behaviors (e.g., hard braking, roll stability triggers) to determine whether intervention is effective. One carrier uses an evaluation matrix to rate drivers in tracking post- intervention progress. All carriers agreed that the vast majority of drivers respond positively to interventions and trend toward improved work performance. Safety goals need to be appropriate, yet aggres- sive, and must incorporate all employees into the process. The process works better if there is wide acceptance and vis- ible participation from everyone in the organization. 6.2.8 Implementing a Behavior Management Process A strong culture is the most critical success factor identified by the carriers. When asked how a balance is achieved between safety and efficiency, common responses were, “Safety is first, period,” and “Efficiency is not possible without safety.” The bottom line, as some carriers believe, is that by being safe, you are being efficient.

44 Small companies do not have the technological and finan- cial resources of larger companies. They must emphasize hiring, retention, training, and ride-alongs. The small carrier in this study reported the significance of employing safety- conscious drivers, which is why their efforts focus on attract- ing and hiring certain types of drivers who are family oriented. As a result, their staff and drivers know each other well, and most drivers have been with the company for 15 to 20 years. If carriers rely on onboard technology instead of (rather than in addition to) a value-based safety culture, some drivers will try to “beat the system.” A strong safety culture ensures that drivers will do what is in the best interest of the company. Part of safety culture needs to focus on care as for a loved one: carriers encourage their drivers to operate as though the other vehicles they share the road with are occupied by fam- ily members. Carriers also try to involve drivers’ own family members in the company’s safety mission by sending mailings home and inviting family members to award ceremonies and celebration banquets that highlight exceptional performance. An important part of behavior management includes evaluating the success of a company’s behavior management program. All carriers reported that their respective programs were effective in meeting the goals and expectations set at the outset. The practices have more than paid for themselves. Companies report a quantifiable return from their invest- ment in behavior management practices and technologies. Substantial improvements in the rate of accidents, injuries, and workers’ compensation cases were seen. Onboard recorders are often reported as being more cost- effective, less intrusive, and more proactive than in-cab cam- era systems, while also being more efficient than traditional management or trainer ride-alongs. The features help drivers avoid safety incidents as events unfold in real time, and output from the system allows managers to gain more information in less time (than a ride-along) via individualized driver reports, ratings, and performance trends. Useful as it is, however, elec- tronic recording does not get to the root of what the driver was doing to trigger the alert. Carriers that choose not to install cameras should speak with drivers about specific events that were recorded or perform ride-alongs more frequently. For some carriers, the process has evolved over time—no longer using a safety firm, the program is overseen in-house. The carrier has also adopted what is believed to be a more behavior-based approach, with feedback and dialogue being emphasized over completion of the checklist. Contributing factors—such as family, attitude, training, and coaching— are included in the discussion. The Purchase Decision It is important for carriers to determine what uses and outputs are desired from equipment as they make a pur- chase decision. This includes identifying target behaviors to monitor or identify. Electronic data recorders can be triggered by events or actions. Subscription-based service providers will evaluate and forward triggered video footage and accompanying data (speed, location, time) based on behavior-tracking criteria determined by the carrier. Some carriers reached their conclusion qualitatively, whereas other carriers used quantitative approaches to evalu- ation. Leaders of one company meet regularly to assess the effectiveness of practices. Even when progress is positive, they continually seek additional practices and new technologies that can provide further improvement. As a result, they have seen continuous improvement in multiple safety, operational, and productivity metrics measured annually for the past decade. One carrier reported that technology vendors and tools were chosen carefully by many departments within the com- pany, based on an analysis of which types of performance they wanted to measure. Another carrier relied heavily on manu- facturer input (i.e., the truck manufacturer told the carrier which products would be easiest to incorporate) because the number of available products was overwhelming. The procurement decision should involve all affected departments in the organization and should be made only after the team has analyzed and agreed on how the systems will be used and the expected outcomes of introducing them into the fleet. Carriers need to first decide which behaviors are of greatest interest and then decide how to measure or observe those behaviors. Original equipment manufacturers (OEMs) can also provide valuable input on which products are most appropriate to incorporate based on the carrier’s needs— for instance, carriers with access to onboard technology can request frequency data, scorecards, and driver-specific reports that can establish a myriad of driver and fleet trends in need of improvement. Both long- and short-term costs should be analyzed, including those associated with capital, communi- cations, installation, maintenance, lease, training, and inter- nal support. Some insurance carriers will provide purchasing assistance or offer a reduction in premiums. Appendix I (published online) provides purchasing deci- sion guidelines used by one fleet manager for in-cab cameras. Many of these same questions can be applied to the purchas- ing decision for other types of vehicle technology. The key points to consider are life-cycle cost (including maintenance, operations, communications and support) and not just the upfront cost, compatibility with other related systems, and the forms in which data or images can be used for managing driver and operational performance. Pitfalls to Avoid Collision avoidance systems can have the unintended con- sequence of breeding complacency or a false sense of security

45 that the vehicle will self-correct or provide early warning in all dangerous situations. A rollover is a particularly danger- ous event in that it can be inevitable before the driver is even aware it has begun. Some carriers reported that driver behav- ior differed depending on whether the driver believed a truck was equipped with a rollover stability system. Technology is also making cabs and the ride more comfortable. Some driv- ers report feeling “removed from the road.” Ongoing train- ing and safety messages must be employed to help drivers guard against these traps. Two private fleet operators in the petroleum products distribution business have been industry leaders in safety, extending beyond their private fleets to contract carriers. One operator implemented the program in the 1990s. Results can- not be achieved overnight: the company feels it took 5 years to fully adopt the process. The other operator indicated it took as long as 4 years to see improvements, and 8 to 10 years for an overall level of trust to be developed. Companies that expect immediate results will likely be disappointed, which can result in premature loss of management and financial support or program corrections. Companies have worked to resolve the evolution of their program into a “paper-chase,” where more emphasis was placed on the process and metrics of reporting than on the behaviors that influence safety. When formalizing a driver observation program, it is important to be aware of the effect on driver behaviors and incidents, rather than process metrics. Rewarding Good Behavior Carriers create an evaluation matrix from data they have collected and define standards to classify drivers, as was shown in Table 11. A one-size-fits-all approach to behavior management simply does not support strong carrier per- formance in either operations or safety. Training protocols, ride-along observation schedules, one-on-one meetings with supervisors, and other means for monitoring and providing feedback to drivers should be predicated on their classifica- tion. Best class drivers can be in a position to support training and the behavior management process. Safe behaviors can be rewarded in ways other than compen- sation. Among all workers, recognition is found to be a strong motivator. Carriers offer recognition to teams (typically termi- nals) as well as individuals in the form of banquets, company- wide recognition, or names written on the driver’s door. One fleet operator with overseas operations provides appliances to the families of their safest drivers, which is a sign of great prestige in their community. These acts are effective not only in rewarding behavior, but are also a highly visible reflection of management’s commitment to safety as a top priority and reinforce a shared top-down culture of safety as a core value. 6.3 Case Study 3: Fitness-for-Duty Management Programs 6.3.1 Overview Cargo tank truck drivers are among the highest paid in the industry (ATRI, 2011) for a reason—the cargo they haul often contains hazardous materials (hazmat) that can be highly destructive if not properly handled. In addition to offering appropriate compensation to attract the most quali- fied drivers, however, it is also imperative that tank truck car- riers pay attention to the mental and physical well-being of their drivers. There are myriad factors related to a driver’s well-being that can influence behavior and subsequent safety on the road—for instance, it is known that lifestyle, diet and nutrition, weight, fitness, and physiological, mental, and emotional health can each influence what happens inside the cab and can contribute to problems with driver fatigue and distraction. This case study addresses good practices within and outside of the motor carrier industry for companies that have put programs in place to effectively manage driver fit- ness for duty (FFD). Truck driver fatigue is estimated to be an associated (although not necessarily causal) factor in 13% of heavy truck crashes (Blower and Campbell, 2005), while internal or exter- nal distractions may play a role in a similar or even higher proportion of crashes including truck rollovers (Olson et al., 2009). The odds of an incident being attributed to fatigue or distraction rise for at-fault incidents, suggesting that roll- over risk may be greatly mitigated by addressing chief causal factors (Knipling and Bocanegra, 2008) (Knipling, 2009). As a result of these statistics, many motor carriers have begun adopting best practices aimed at improving FFD. These prac- tices are capable of both reducing costs (associated with acci- dents, medical bills, and legal fees, etc.) and increasing driver safety, productivity, and quality of life. Transportation organizations known for designing and implementing good practices relating to FFD programs have instituted structured and comprehensive initiatives. They comprise four major elements: (1) fatigue education and management, (2) general health and wellness, (3) under- standing the effects of off-duty behaviors and scheduling issues, and (4) awareness of mental distractions. Coaching, counseling, and family involvement are fundamental tenets of these programs. The purpose of this case study is to educate cargo tank truck carriers and to provide them with guidance in develop- ing and maintaining effective FFD programs. The highlighted strategies are intended to target cargo tank truck drivers and their families as part of a multi-tiered approach. Managing FFD requires a comprehensive and continuous commit- ment, touching on all aspects of a driver’s daily life. This case

46 study outlines numerous recommended methods, practices, and tools that can achieve that objective and improve driver safety in a practical manner. It contains valuable informa- tion applicable to any cargo truck carrier regardless of size and gives examples of best practices utilized by drivers and carriers in the trucking industry and in other transportation modes, coupled with published research findings and other relevant literature. 6.3.2 Key Industry Initiatives in Fitness-for-Duty Management Fatigue Management Fatigue can be dangerous for any driver to experience, but especially when transporting hazmat in a top-heavy vehicle susceptible to rollovers triggered by even the slightest human error. Fatigue has been associated with poor decisionmaking, impaired reaction time, and difficulty concentrating, which make the job of a cargo tank truck driver extremely challenging. Since long work shifts precipitate fatigue, most countries have rules and regulations dictating HOS, which limit the number of hours per day and week that a driver is allowed to operate a CMV. In the United States, 49 CFR Part 395 limits driving time to a maximum of 11 hours, with no more than 14 hours on-duty, followed by 10 consecutive hours off-duty, among other requirements. Even with these requirements, however, some industry stakeholders view HOS standards as too prescriptive and, therefore, inadequate for ensuring that drivers are properly rested and alert. As a result, Fatigue Management Programs (FMPs) have become a burgeoning trend, particularly in North America and Australia, as a flex- ible and proactive means for dealing with the issue of driver fatigue. Typically, FMPs involve multiple methods and tools that target the entire organization, not just the drivers. In addition to solid HOS compliance monitoring, common fea- tures of an FMP include broad educational efforts on issues related to fatigue; scheduling and dispatching; driver health and wellness; sleep disorder screening and treatment; and fatigue management technologies (FMTs). In Australia, new fatigue management laws were passed by the Australian Transport Council (ATC) in 2007 to recognize the importance of addressing heavy vehicle driver fatigue in a more systematic way (Australian Government, 2007). These laws were backed by years of research demonstrating the posi- tive impact FMPs can have on issues related to fatigue. One 6-year study comparing pre-FMP drivers with FMP drivers found the latter group was less likely to report feeling tired, having difficulty concentrating, or speeding to meet a deadline. They were also more likely to report having an influence over scheduling, having sufficient time for breaks and non-driving work, and having an easier time managing fatigue in general (thanks to management taking an active role) (Smiley, 2010). In addition to Standard Hours, which are equivalent to HOS regulations in the United States, Australia has established a program for carriers to opt-out of the standard rules in pur- suit of either Basic Fatigue Management (BFM) or Advanced Fatigue Management (AFM). BFM adds flexibility to the Stan- dard Hours within determined limits for minimum rest and maximum work hours. AFM takes this a step further and allows operators to propose their own rest and work rules, with further opportunities to extend work hours under specified conditions. In return for the added flexibility of BFMs and AFMs, carriers have greater accountability for managing fatigue risks. BFMs and AFMs both require National Heavy Vehicle Accreditation Scheme (NHVAS) accreditation, which includes training modules on how to manage fatigue. All parties in the distribution chain are required to take reasonable steps to prevent problems related to fatigue—for example, it is management’s responsibility to minimize risk of fatigue by ensuring that scheduling allows for sufficient time to make a delivery as well as to rest and recover during non-shift time. The BFM and AFM programs carry a number of stringent guidelines, and carrier records must be auditable at all times to ensure compliance. These include scheduling, driver FFD, fatigue management performance evaluation, recordkeeping, health management, and workplace conditions, among others. The FMCSA and Transport Canada are jointly sponsoring the North American Fatigue Management Program (NAFMP). The purpose of the NAFMP is to develop, implement, and evaluate a comprehensive, integrated FMP for implementation by motor carriers of any size. Key FMP components include commercial driver training and education on sleep need and fatigue countermeasures; training for dispatchers and driver management personnel on improved scheduling, which takes into account individual sleep need; sleep disorder screening and treatment; and fatigue management technologies. Phases 1–3 of the NAFMP beta tested, pilot tested, and field tested program components with motor carriers in the United States and Canada. Researchers made pre- and post- FMP comparisons of numerous variables related to fatigue and concluded that subjective sleep quality improved and objective sleep duration increased by 20 minutes on on-duty days, with an increased proportion of drivers reporting more than 6 hours of sleep prior to the beginning of their shifts (Smiley, 2010). Reports of fatigue and absenteeism were also lower post-FMP, and critical events dropped by nearly 40%. At the time of this writing, Phase 4—the final phase of the NAFMP—is underway, creating the guidelines and materials that will be needed for motor carriers of any size to imple- ment an FMP within their operations. Fatigue management technologies have already been eval- uated in terms of effectiveness and driver acceptance. One study showed some evidence that technologies could increase driver alertness, fatigue awareness, and sleep time (Dinges

47 et al., 2005). These technologies included driver-interface FMTs, which used body sensors (e.g., wrist watches) or mon- itored the frequency and duration of eyelid closures to alert drivers of possible impairment and sleep need, and vehicle- interface FMTs, which tracked common indicators of fatigue (e.g., lane drifting) or increased the ease of vehicle control. In general, drivers favored a focus on the vehicle rather than on themselves; however, they noted that FMTs could all be beneficial if further improved. General Health and Wellness As a group, commercial truck drivers struggle with a vari- ety of health problems. The typical American truck driver is in his or her mid-forties, which is several years older than the average age of the U.S. workforce (ATA, 2011; Bureau of Labor Statistics, 2010). Obesity rates have also risen faster for truck drivers than for the general population, with close to 50% of truckers having a body mass index (BMI) of higher than 30 (the threshold for distinguishing between overweight and obese) (Truckinginfo, 2011). Truck drivers work long hours with often irregular schedules, are exposed to stress- ful environments with tight deadlines, and experience traffic congestion and dangerous weather conditions. Job demands also play a role in lifestyle decisions, with little opportunity for exercise or proper diet and nutrition, and a culture that fosters a higher proportion of smokers than found outside the trucking industry (Fuetsch, 2011). Driver health issues have been implicated in truck-involved fatal crashes, with the NTSB attributing 10% of accidents directly to truck driver health issues in one study (Krueger et al., 2007). The three biggest healthcare expenditures in the trucking industry are hypertension, diabetes, and cardiovas- cular disease. These conditions are also major risk factors for other crash risk factors such as sleep apnea, which afflicts close to 30% of truck drivers and is more prevalent among obese drivers (Pack et al., 2000; Stoohs et al., 1994). To address these considerations, FMCSA and ATRI have developed a training program called “Gettin’ in Gear,” which teaches company instructors how to proactively manage driver health and wellness (Krueger and Brewster, 2002). Driver fatigue has also been addressed by ATRI in its development of a train- the-trainer course titled “Mastering Alertness and Managing Driver Fatigue” (Brewster and Krueger, 2005). Additionally, FMCSA and the National Sleep Foundation have partnered to launch a “Get on the Road to Better Health” campaign target- ing sleep apnea awareness, diagnosis, and treatment. Formal health and wellness programs are still uncommon, but individual components are beginning to take hold in many companies. Furthermore, carriers that are serious about improving drivers’ health are employing innovative solutions such as creating fitness centers; hiring health professionals and nutritionists; providing tips for better health in news- letters, brochures, and posters; and discounting insurance pre- miums for drivers who participate in healthier lifestyle choices (Fuetsch, 2011). Scheduling and Dispatching Strategies In the trucking industry, fulfilling customer demands while maintaining a balance between one’s work and personal life can be difficult. Poor scheduling practices can exacerbate problems associated with both driver fatigue and health and wellness. Susceptibility to fatigue varies by driver, but it is important for schedules to be tailored to the needs of each individual to provide ample time for rest between shifts. Ide- ally, drivers should obtain at least 7 hours of sleep prior to a shift (Knipling, 2009). Repeatedly failing to do so can con- tribute to severe sleep debt and a subsequent lack of alertness that may trigger serious safety incidents. The body’s circadian rhythms influence optimal times for resting, eating, and other natural functions, with general low points for alertness during the early morning (midnight– 6:00 a.m.) and mid-afternoon (1:00–4:00 p.m.). Disrupting the body’s clock by working odd hours can reduce alertness and performance and can decrease the quality and quantity of sleep through abnormal sleeping times. The potential also exists for a build-up of sleep debt if these patterns continue repeating. Evidence that altering sleeping patterns can impact driving performance can be seen by noting the difference in the types of truck crashes that occur during the day and night. Day crashes are often attributed to traffic and passenger vehi- cle driver behaviors; in contrast, night crashes are more likely to be attributed to driver fatigue (Cades et al., 2011). Driver Distractions Distracted driving is the U.S.DOT’s number one issue and is a major cause of traffic accidents. However, a majority of research efforts have been exclusively targeted at distractions external to the driver such as interfacing with cell phones and other technologies. This case study’s emphasis on distraction focuses on “eyes-on-the-road” mental distractions that steer attention away from the road (e.g., domestic-based stress). When cognitive resources are being used for non-driving purposes, drivers are less able to process information about the roadway and are, therefore, less capable of dealing with safety-critical events (Cades et al., 2011). While this subset of driver distraction is relatively less well researched than “eyes-off-the-road” distraction, the limita- tions imposed are the same (i.e., they are equally capable of impairing a driver’s alertness and judgment while operating the vehicle). In fact, one transportation study in the avia- tion industry revealed that domestic-based stress amplifies

48 pilots’ perceived work stress and negatively influences their self-rated job performance (Transport Canada, 2011). These findings are relevant to the trucking industry, where men- tal distractions relating to home life can be supplemented by other stressors like planning for or dealing with traffic, bad weather, or dangerous road conditions. Mental distraction can also be amplified by sleep debt or health conditions, pre- senting additional safety hazards; therefore, it is critical that trucking companies address the issue of mental distractions in addition to traditional “eyes-off-the-road” distractions in order to reduce the risk for rollovers or other safety incidents. 6.3.3 Good Practices in the Cargo Tank Truck and Other Industries Methodology The research team conducted in-depth interviews with five tank truck operators, an inland marine carrier, and a major U.S. freight railroad to identify good practices in FFD man- agement, including the areas of fatigue, health and wellness, scheduling and dispatching, driver lifestyle, and distractions. The five featured motor carriers are all safety award-winning, for-hire companies that run bulk tanker operations. Some also haul hazmat, carry specialized loads, or operate as truck- load carriers. The sizes of these companies vary widely, rang- ing from operating fewer than 50 power units (PUs) to having a fleet with more than 1,000 PUs. Both long- and short-haul carriers are represented, employing both owner-operators (O-Os) and company drivers. Several cargo tank truck drivers from America’s Road Team, a group of drivers honored by ATA for their superior driving skills and safety records, were also interviewed in an anonymous conference call to provide input from the per- spective of the driver and the driver’s family. They represented medium-size for-hire carriers with bulk tanker, hazmat, and specialized operations. All participants were company drivers as opposed to O-Os or independent contractors, and each had more than 15 years of truck driving experience, with a major- ity of that time spent in the cargo tank truck industry. To better inform practices related to FFD management in the tank truck industry, it is important to consider exem- plary practices taking place in other industries where safety is important and long shifts are a fact of life. One notable marine transport carrier has instituted several successful programs addressing fatigue education and management and health and wellness. The rationale for investing in these programs is the carrier’s commitment to a culture of manag- ing risk so that no injuries to associates, property damage, adverse customer impact, environmental impact, or commu- nity harm occur while work is being performed. Fatigue Management All tank truck carrier interviewees agreed that the basic building block for creating a sustainable FMP begins with educating personnel at all levels of the company on the causes and corollaries of driver fatigue. Roles and responsibilities for addressing the potential for fatigue must then be custom- ized and made explicit for each position within the company: drivers, executives, safety directors, terminal managers, dis- patchers, trainers, and any other personnel who play a role in delivering cargo safely and efficiently. It is important that dis- patchers be trained to recognize signs of fatigue when engag- ing drivers prior to the beginning of a shift. Several carriers described the importance of building a family environment, in which all employees knew each other, as well as their families. None of the carriers interviewed used psychomotor vigi- lance tests (PVTs) or any other formal FFD tests to measure alertness since they felt that engaging the driver in a simple conversation prior to the start of a shift provided indica- tors of fatigue and general demeanor. For one company, if the branch manager or dispatcher is at all uncomfortable about the situation, it is the company’s practice to send the driver home. Likewise, drivers are encouraged to notify the employer and switch shifts with another driver if there is any doubt whether the driver can handle a particular shift for any reason. Not all carriers have personnel at all terminals 24/7, so this method has limitations. This underscores why build- ing strong relationships and trust with drivers is an impor- tant complement to all practices. Several participants noted that onboard systems can also be useful in identifying driver fatigue when on the road. Sys- tems that send real-time information—such as difficulty staying in lanes, progressively declining speeds, or hard braking—are excellent indicators that a driver is either fatigued or distracted. Additionally, participants generally agreed that electronic logging (e-logging) devices have helped reduce fatigue since they automatically record the amount of time a driver has been on duty and when their HOS limit has been reached. One carrier displayed a particular commitment to managing fatigue by issuing weekly and monthly fatigue scorecards for all drivers (based, in part, on e-log data and on- duty history), using predictive analytics to pro actively identify drivers who are most likely to have an accident. Driver Feedback. Implementing an effective FMP is considered a shared responsibility in which management and labor work collaboratively to achieve desired outcomes. While carriers may be responsible for providing the means for the driver to obtain sufficient rest, the responsibility is on the individual to utilize their time in the appropriate manner when given the opportunity. Many drivers have admitted that it is difficult to manage their schedule while at home due to

49 the distractions of family and social events. This makes it easy to ignore work responsibilities by decreasing the likelihood of getting adequate rest. Drivers are encouraged to manage their time more efficiently by prioritizing their social sched- ule with work obligations. More-seasoned drivers reported having a better balance between their work and home life. There are several tactics drivers should utilize and be famil- iar with when managing fatigue. It is imperative that they rec- ognize signs of fatigue such as lack of energy, difficulty keeping their eyes open, difficulty concentrating, and drifting in and out of lanes. If any of these signs are evident, the decision should be made—at the discretion of the driver—to pull over and rest, stretch, or walk around. Regardless of what tactic is most effec- tive for the individual, safety should always be the first priority, despite the pressure felt to continue the journey. By recogniz- ing personal limitations and tendencies, each individual can exercise the best judgment in fatigue-related situations. Other Industries. The railroad industry has also been actively involved in the development of FMPs. This has been motivated in part by recent changes in HOS regulations and other legislation under consideration. Some U.S. rail carri- ers are patterning their FMPs after an initiative that has been undertaken by Transport Canada (2011). This effort utilizes what is known about the causes and consequences of fatigue in crafting guidelines for designing and implementing an effective rail carrier FMP. While it should be emphasized that this study addresses the rail industry, much of the work prod- uct is transferable to the motor carrier industry (see Appen- dix J, published online). It is therefore used as a basis for the following discussion and recommended guidelines: • Extended length of work shift—Drivers should obtain at least 6 to 8 hours of continuous sleep before beginning extended shifts [consistent with the recommended 7 hours by Knipling (2009)]; however, a driver who has been on a reduced or restricted sleep schedule may need to be more closely monitored. • Continuous hours of wakefulness beyond 19 hours—Research indicates that individuals exhibit a decrease in cognitive performance following 19 hours of wakefulness; therefore, the study recommends companies should enable drivers to nap briefly (20–45 minutes) during a period of 19 hours of continuous wakefulness. Scheduling individuals for duty who have had at least 8 hours of sleep during the prior 24-hour period (preferably during the night before) is another effective countermeasure. • Obtaining less than 6 hours of continuous sleep in a 24-hour period—Research suggests that it is unlikely that a person will obtain more than 6 hours of sleep during daylight hours unless they are extremely exhausted. Individuals who have been working regular daylight hours are unlikely to be able to suddenly switch and obtain the proper amount of sleep during the day. Operators may need to have suf- ficient recovery time to adjust to schedule changes. The report recommends at least 2 nights of recovery time when switching between day and night shifts. • Break times that do not permit reasonable recuperation— Having adequate time off to recover from the effects of schedules that induce fatigue is essential to obtain the necessary sleep. However, simply allocating this time may not be sufficient to allow recovery if the period is during daylight hours because individuals who have been accli- mated to night-time sleep will have difficulty falling asleep during the day. Consequently, the report suggests that there should be sufficient time for the person to obtain the needed rest, which is considered to be at least 8 hours of uninterrupted sleep. Special consideration should be given to individuals who have been acclimated to night- time sleep, as they will be unlikely to obtain this amount of rest during the ensuing daylight hours. • Continuous work in a 7-day period—The report recom- mends at least 2 nights of sleep before beginning the next work period when having reached the regulatory limit over a 7- or 8-day period. Most experts refer to this as an anchor sleep that removes sleep debt and prepares the person for subsequent activities. The marine carrier has placed the issue of fatigue high on its list of safety priorities and has invested significant resources in teaming with sleep researchers to understand the fatigue phenomenon and how best to manage this problem. Emerging from this process has been the notion of practicing good sleep hygiene, an approach that improves attentiveness while the individual is performing on-duty. Fatigue is also managed through proactive diagnostics. The carrier believes that an individual’s BMI is a strong predictor of a sleep apnea problem. As a result, company policy is that all vessel operators with a BMI of 40 or higher must undergo a sleep apnea test. The correlation between these individuals and diagnosis of a sleep apnea problem has been so high that the company is considering lowering the testing limit to a BMI of 35 or higher. When a sleep apnea diagnosis is made, the company relies on the sleep researchers to help the individual understand the nature of the problem and how it can be controlled. One par- ticularly effective strategy is to have a member of the research staff who is overweight and using a sleep apnea mitigation device to sit down and talk to the vessel operator who can relate to the problem and is benefiting from the results. Using this approach, the carrier estimates that approximately 50% of its employees are willing recipients of this treatment.

50 General Health and Wellness More than one carrier mentioned the need for a health and wellness focus in the tank truck industry given the aging nature of the workforce. The degree of health and wellness interventions varied widely depending on the carrier, but the major components that were identified included • Fitness and exercise, • Diet and nutrition, • Weight loss, • Smoking cessation, and • Regular physicals and screenings (e.g., sleep apnea, blood pressure, diabetes, and cardiovascular issues). Carriers acknowledge that heart disease, diabetes, and hypertension generate the highest costs from a health stand- point, and these areas need to be systematically addressed. In fact, screening for these health issues, as well as sleep apnea, have proven to be valuable in identifying ailments and enabling intervention. As part of these efforts, several carri- ers stressed the importance of providing affordable medical benefits to company drivers, and most extend these benefits to include all family members. Most carriers expressed concern for sleep apnea given the proportion of drivers who are overweight, although methods for combating sleep apnea varied. Some carriers focus screening on drivers with BMIs higher than 35 or 40 because these drivers are most likely at risk for the disorder. Testing was considered most affordable by using home kits in which the driver takes the testing device home to wear during the night and then brings it back to work for the employer to ship off for results. Aside from diagnosing and treating health problems, most of the participants also incorporated diet and nutrition infor- mation into their health and wellness programs, as well as creating opportunities that encourage drivers to begin exer- cising and quit smoking. As a rudimentary first step, most carriers offered drivers basic instruction in these areas using bulletins, pamphlets, or even CDs or cassettes they could lis- ten to on the road. In an effort to encourage drivers to begin exercising, one carrier offered lifestyle coaches and physical therapists through various resources (in person, by phone, and by email). One carrier provided a worksite fitness center and another offered a discount to a local gym. As an added incentive to eat right and exercise, several carriers created a weight loss competition that offered bonuses and discounted insurance rates to their drivers. Finally, one carrier promoted good health by offering healthy snacks and fruit at their company meetings. Driver Feedback. Drivers should take advantage of pro- grams and benefits their employers offer and be familiar with any health issues they have in order to get proper treatment. According to both the drivers and carriers interviewed in this study, drivers who participated in health and wellness programs had more energy and were more alert. One driver acknowledged that the program was “like a night and day transformation,” noting that results are not immediate, but that the process results in a life change through patience and consistency. Other Industries. Acknowledging that prevention is such a critical part of health care, the marine carrier recently instituted a policy that all preventive health exams would be fully covered at no cost to the employee. Moreover, because the employer is paying the full cost, the employer has enhanced awareness of preventive health maintenance activities. In an attempt to improve health and wellness, the company offered an additional $300 in health benefits if the employee completed a health risk assessment and used the services of an online wellness coach. The response rate was rather poor (10% participation), but when the program was revamped and offered health benefits only to those who participated in the program, participation jumped to 100%. Therefore, making participation a requirement was much more effective than offering an incentive. To encourage physical fitness, the carrier has installed a treadmill, elliptical machine, or exercise bike on each vessel. Each shore-based facility also has an area equipped for fitness workouts. In the area of nutrition, the company has begun to offer healthier dining options on vessels, including work- ing with a local university on food preparation in a galley environment. Scheduling and Lifestyle According to one of the carriers interviewed, “Drivers are the heart of the trucking industry, and the new generation of drivers is very different from the old one, so carriers need to adjust accordingly instead of clinging to outdated practices.” Driver scheduling practices are strongly correlated to suc- cessful FMPs and health and wellness programs. In addition to complying with HOS rules, some proactive measures used by carriers interviewed for this case study include using regu- lar schedules with consistent start times, minimizing driving at night or during heavy traffic, and planning around unfa- miliar or dangerous routes. It is important to recognize, how- ever, that scheduling is often customer-driven, so as much as carriers would like to move driving times away from late night or high traffic periods, it is not always possible. Even when scheduling is out of the employer’s control, carriers have an obligation to inform drivers and other per- sonnel of risks associated with driving during certain times of the day. Some carriers teach drivers methods they can uti- lize to increase alertness during circadian lulls such as tak- ing additional breaks to nap or to walk around. Carriers who

51 had greater flexibility with their schedules report keeping the routes as short and direct as possible. One of the simplest best practices identified in this area was to provide drivers with at least a 24-hour notice before each shift, to ensure sufficient opportunities for drivers to plan for 7 to 8 hours of sleep. Additionally, all of the participants stressed the importance of communicating with drivers to establish the schedule that works best for each driver. Several carriers specifically acknowledged that drivers do not get an adequate amount of rest during holiday hours and have made attempts to provide flexible scheduling or shorter hauls for drivers on these days. It is important that drivers, dispatchers, shippers, and receiv- ers be educated in order to avoid the risk of safety incidents. Drivers need to understand the importance of time manage- ment to ensure adequate amounts of rest during work periods and while off duty. The carrier needs to recognize the unneces- sary pressures that can come from shippers and receivers and to help these parties understand practical limitations and the importance of a well-rested driver. Doing so can lead to more reasonable and realistic schedules that build in greater safety margins to accommodate for unexpected delays and drivers’ needs for breaks. Although seeking outside assistance is recommended if this option is offered by the employer, nothing can replace the natural understanding of one’s own personal limita- tions. The ability to balance the relationship between work- ing hours and time spent outside of work will influence the effectiveness of the driver’s ability to be better rested and operate safely while on the road. As part of this challenge, drivers are encouraged to resist allowing their social life to interfere with needed rest. They are further encouraged to feel comfortable communicating any scheduling concerns with their supervisors. If a specific scheduling issue is pre- venting them from attaining a level of safety or quality, it is in both their and the employer’s interest to amend the schedule. Finally, when working during the most dangerous shift for fatigue (i.e., between midnight and 6:00 a.m.), drivers need to be aware of how to combat the body’s natural circadian rhythm and sleep patterns. One of the highest risk scenarios is for a person to be awake during the daylight hours and then be expected to work during the ensuing period of midnight to 6:00 a.m. (Transport Canada, 2011). For persons working this shift, it is important to acknowledge the need for time to nap during the midnight hours to the extent that it is operationally feasible and compliant with regulations governing hazardous material shipments, as well as broader operations. It should be noted that naps are no substitute for sufficient sleep [7 hours according to Knipling (2009)] prior to the shift. Driver Distractions Carriers must be aware that distractions within the cab include both physical and mental disturbances. The former includes eating and drinking, cell phones, citizen’s band (CB) radios, GPS, onboard technologies, and other hand- held technology; the latter includes mental distractions (e.g., stress, daydreaming, or preoccupation). One carrier stated that there is a correlation between a driver’s family environ- ment and on-duty safety performance—for example, the car- rier noted that the 2008 recession resulted in a higher rate of safety issues, which could likely be attributed to drivers worrying about family members’ job losses, foreclosures, and financial issues. This carrier offers a way to decrease driver disturbance while on duty by encouraging the spouses to contact the company’s terminal for home repair issues and then handles the costs through payroll deductions. Cell phone use remains a top contributor to vehicle acci- dents. Several companies have used outreach methods to ask family members to avoid calling the driver’s cell phone while he or she is on duty. It was discovered that dispatchers can create the greatest distraction for drivers as a result of call- ing driver cell phones while they are traveling. Carriers have begun to require that dispatchers rely solely on the compa- ny’s telematics messaging system to send messages, which are not delivered until the vehicle is stationary. While most of the carriers participating in this study do not directly monitor distraction while the driver is on the road, they do rely on several other indicators such as information provided from dispatchers or onboard safety systems (OSS). Several case study participants stated that hard braking, diffi- culty staying in lanes, and progressively declining speeds were effective indicators of distracted or fatigued driving. One car- rier also reported acting on “How’s my driving?” calls from other motorists and input from customers as effective moni- toring tools of behaviors that may indicate fatigue. Driver Feedback. Drivers reported the natural incli- nation to be less attentive when taking familiar routes. It is important to be diligent and remember that every vehicle handles differently due to different suspensions or weights, so drivers need to stay focused on the vehicle and the type of cargo they are carrying even when familiar with a route. It was noted by a former driver and fleet manager that familiar- ity with an assigned vehicle, while it may have benefits to the driver, can also lull that driver into inattentiveness. Another common distraction is cell phone usage while driving. Every driver should be committed to their work while on duty and should avoid taking calls or checking messages, whether per- sonal or work-related, until the vehicle is parked. Good Practices Involving Driver Families All of the participating motor carriers and drivers stressed how important family involvement and support are to the success of FMPs and health and wellness programs. To ensure

52 that drivers receive proper rest outside of work, it is neces- sary for family members to be sensitive to the obligations that the job entails. This may require spouses to be aware of the driver’s schedule and to organize events in a way that does not conflict with the driver’s sleep regimen. Some of these extra responsibilities might include the spouse participat- ing more in completing household tasks and other domestic obligations. There are times when a personal phone call is inevitable while the driver is on the road, but it is recommended that such calls be limited to emergency situations and that dif- ferent tactics be defined in such cases. For example, one driver said his wife knows to call and hang up if there is an emergency and then he knows to pull over at the next oppor- tunity and call her back from a safe place. Family members can also play a critical role in a driver’s health and wellness. Carriers noted that it is the “little things” that contribute to big improvements. Spousal recognition of health-related symptoms is often a critical first step in identify- ing an unhealthy condition, and the spouse should encourage the driver to seek treatment. Carriers agreed that drivers are more attentive to their spouse than to anyone else, and receiv- ing preventive care is more likely if there is pressure from home. Several carriers and drivers also cited the spouse as one of the major driving forces for successful weight-loss initia- tives, with a driver noting that “the wife is where the pressure comes from—if she isn’t happy, no one is happy.” Drivers did admit struggling to decline prepared meals, making it difficult at times to commit to healthy food choices. They noted that it helps if the spouse is health conscious and pre- pares nutritious meals while discouraging unhealthy foods and products like ice cream and tobacco. Finally, families can take small steps to be active together (e.g., taking the dog for a walk, spending time at the gym, or doing stretches together). Most of the carriers interviewed made some attempt to engage the family in FFD practices. Often, this included mailing newsletters and informational packets to the home and inviting family members to safety meetings. Two com- panies took this further by holding regular award ceremonies or banquets that families were invited to attend. They also noted that it is important for families to read the information that gets sent home and to participate in company events to further a driver and carrier’s sense of commitment toward one another and to share in the FFD process. 6.3.4 Key Components of the Fitness-for-Duty Program This research makes a compelling argument that it is in the best interest of carriers, drivers, and drivers’ families to promote FFD practices in the cargo tank truck industry. It is a shared responsibility, with roles defined for each group that help achieve the overall objective of reducing fatigue, improving health and wellness, and lowering the incidence of safety critical events. The best practices described are achievable for carriers of all sizes, although those who have more resources may have the added benefit of utilizing external contractors that specialize in these areas. For the larger carriers interviewed, it was com- mon to seek outside help during the development of FMPs, health and wellness programs, and scheduling practices. Roles typically shift back to the carrier at some point, although external providers are most likely to remain involved in health and wellness practices due to privacy, confidentiality, and the amount of time required for one-on-one coaching. The primary reason for implementing FFD practices is a desire on the part of the carrier to be proactive in improving driver safety and quality of life. Benefits are also expected to improve carrier operations. One carrier has noted that his company began using an FMP as a result of frequently hav- ing early-morning rollovers, a trend their FMP has erased entirely. Carriers report that their programs meet goals and expectations, and the results generally pay for themselves. The return on investment (ROI) associated with FFD prac- tices can be quantified, with the highest ROIs associated with smoking cessation programs, weight-loss programs, and sleep apnea treatment. According to the carriers inter- viewed, these programs substantially reduce medical insur- ance (particularly related to heart attacks and strokes) and workers’ compensation costs, reduce fatigue-related accidents and injuries, and improve driver retention. In addition, most companies reported happier, more energetic, and more pro- ductive drivers, noting that FMPs and health and wellness programs are an effective way of demonstrating that drivers are cared for outside of just the service they are providing. The drivers interviewed in this case study confirm reports of positive outcomes from participating in FFD activities. They appreciate their carriers for creating programs designed for their personal benefit. One driver commented, “Treating me right makes me want to stay [with my employer] because they care about me as a person and care about my family,” cor- roborating reports that FFD practices foster better relation- ships between workers and employers and reduce turnover. Improving driver retention is especially important in an industry known for traditionally high levels of turnover (Watson, 2011). Concerning FFD, the best practices that have been outlined confirm the importance of a stable work- force in promoting positive behaviors and achieving desired safety outcomes. For instance, carriers stress the importance of open lines of communication among drivers, dispatch- ers, and management, something that comes from getting to know drivers over the years, which makes it difficult for com- panies that have a low retention rate. The study also reveals the importance of employing experienced drivers—experience is the only thing that helps drivers get better at handling

53 work-life balance, knowing personal limitations, and making appropriate choices or decisions. Participation in FFD programs varied among interviewees and types of programs. To improve participation, it is rec- ommended that drivers first be informed of what the carrier offers with regard to FFD, understand the benefits of partici- pation, and recognize that other drivers are participating (as the single biggest influence on participation is peer pressure). Participants must also be continually reminded that benefits are long term and should not be expected to occur overnight. Interactive approaches to FFD (e.g., health screenings or fit- ness centers) were considered to be more effective than pas- sive approaches (e.g., distributing literature). Action Items The following action items are recommended: • Educate employees at all levels of a company how to iden- tify, prevent, and combat driver fatigue: – Interact with drivers prior to each shift (to the extent possible); – Screen for, diagnose, and treat sleep disorders; – Look for patterns of behavior indicative of fatigue or distraction (e.g., unintentional lane changes, progres- sively declining speeds, or hard braking); – Use EOBRs to ensure compliance with HOS regula- tions; and – Teach drivers how to manage free time and obtain suf- ficient rest. • Establish health and wellness goals and inform drivers of the resources available to them for reaching these goals: – Make health screenings a priority to identify drivers who have problems with heart disease, diabetes, hyper- tension, or sleep disorders; – Establish a smoking cessation program; – Increase awareness of healthy eating habits and make healthy snacks available during meetings; and – Provide opportunities and encouragement for exercise and weight loss. • Find optimal schedules that are customized for each indi- vidual driver and try to keep them as consistent as possible. • Provide a resource for driver family members to use in lieu of interrupting the driver while he or she is on duty. • Obtain buy-in and align goals with driver families to ensure that there is 24/7 progress.