The best remedy for fatigue among transportation workers is to ensure that operators who perform critical safety tasks are awake, alert and focused while on the job. This not only protects transportation workers but others as well. The only way to ensure this is to limit the work schedules of commercial drivers, pilots and engineers so they are not fatigued at the end of their work shift, and to provide sufficient off-duty time to ensure that they get adequate rest time for sleep between shifts.

Although operating conditions vary among the modes of transportation, highway, air, rail and pipeline, the response of human beings to prolonged hours of work and inadequate rest does not – they get fatigued, make mistakes and compromise safety. In addition to overly long work days and inadequate rest periods, transportation operators also are subject to disruption of natural circadian rhythms - when work/rest schedules are not on a 24-hour cycle - and fatigue-inducing backward work rotations – in which operators start work at an earlier time each successive shift through the work week, regardless of day or night. These factors are a recipe for danger. Regulations that protect against these scheduling abuses are an investment in public safety and a bulwark against fatigue-related transportation disasters.

In the arena of commercial motor vehicle operations, employing better rested truck drivers who operate on consistent, daily routes is one way to improve working conditions and reduce driver fatigue. A study by the NTSB found that driver fatigue was a factor in 30 to 40 percent of all truck crashes. Even on long-distance trips, getting a rested driver behind the wheel after eight consecutive hours of driving instead of 11 hours would reduce the number of fatigued drivers and achieve significant safety benefits. Studies show that truck crash risk increases dramatically after eight straight hours of driving.

Another way to reduce fatigue is to change the compensation system for most truckers from payment by-the-mile, which encourages drivers to drive as far and as fast as they can, to hourly pay with overtime. This reform would discourage driver fatigue and promote safer operation of large trucks by better-rested, more alert drivers.

Finally, while the trucking industry has adopted modern technology in order to increase operating efficiency, opposition to electronic on-board recording (EOBR) devices to facilitate enforcement of hours of service requirements remains widespread. EOBRs will eliminate cheating on the work rules and improve enforcement of the operating limits. Currently, the enforcement system relies on the paper logbooks of drivers, often called “comic books” because of their false entries, and receipts for gas, tolls and other travel-related payments. This makes enforcement of the hours of service rules a game of cat-and-mouse that often allows drivers to evade the safety limit on driving hours. All of which could be rendered unnecessary by the use of EOBRs in every truck. NTSB first recommended EOBRs in 1977. Today, it is an “open” recommendation on NTSB’s Most Wanted list with the response of DOT listed as “unacceptable”.

The airline industry has long recognized the importance of crew rest and fatigue management as vital components of its safety culture. As the FAA considers modifications to its flight and duty regulations, the industry has taken an active role. ATA and its members airlines were heavily involved in the FAA Flight and Duty Aviation Rulemaking Advisory Committee and put forward a strong set of recommendations for a duty-day regulation based on the principles that any rule must be grounded in the best scientific research, take advantage of the considerable operational experience of the industry, recognize the importance of personal responsibility and demonstrably advance safety. Those recommendations also took into account the very diverse nature of airline operations, running the spectrum from short-duration regional flying to multicontinent, multi-time zone international operations, and the important role to be played by fatigue risk-management programs designed to fit unique operating conditions across that spectrum. We believe that those recommendations continue to provide the best path forward for addressing fatigue-management concerns and we will be applying those underlying principles in evaluating and commenting on the FAA Notice of Proposed Rulemaking.