What’s ‘innovative’ about this fatigue plan is its low-tech approach

February 8, 2019

Greg Grisolano

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Earlier this week, an hours of service exemption request filed by a coalition of livestock and animal haulers caught our attention. No, it wasn’t the fact that yet another group was seeking relief from the one-size-doesn’t-fit-all regulation that made us take notice. It was the following paragraph:

“The applicants cite the following negative impacts to their industry if the exemption is not granted: (1) Livestock haulers would be unable to test innovative fatigue risk-management safety countermeasures.”

“Innovative” is an adjective that can sometimes make one’s blood run cold when its deployed in the arena of trucking safety. It’s usually code for an aggressive or invasive (or both!) technological doodad that purports to increase safety by turning over some aspect of driving to a machine instead of a driver.

Back at the 2016 edition of the Mid-America Trucking Show, I got a firsthand display of some “innovative” fatigue safety measures, courtesy of the folks at Seeing Machines. They were debuting their “Guardian” system. A driver-facing camera constantly scans a driver’s face for signs of inattention, or for drooping eyelids. If the machine sees something it doesn’t like in the driver’s face or posture, a signal is sent to a rumble box under the seat and “gooses” the driver. The alert can be sent back to the fleet HQ and can be logged for driver training purposes.

Fortunately, the innovative countermeasures the folks at the National Cattleman’s Beef Association, American Farm Bureau Federation, et al., are hoping to deploy in this instance are not technocratic ones.

American-based livestock haulers hope to borrow a page from their counterparts in Australia, who, according to the full version of the exemption request, “created a program specifically tailored to livestock haulers, enabling them to drive and remain on duty for additional hours upon agreement to implement certain proven fatigue mitigation countermeasures.”

In 2013, Australia adopted national regulations to deal with fatigue management in heavy vehicle operations. In 2015, they developed a system specifically for livestock haulers.

What’s the key innovation the Aussies have developed that allows their qualifying drivers to operate for 15½ hours in a 24-hour period? A surprisingly low-tech approach involving paper and pens.

No, seriously.

Under the system, drivers fill out a series of forms, including a safe driving plan, and a fitness for duty assessment. They check boxes on forms that are meant to assess how rested they are, how fit they are for duty, whether they’ve imbibed any substances they shouldn’t have. A scheduler/dispatcher also fills out part of the form, signing off on the fact that the driver has had a reset break, and that the plan provides opportunity for “minimum required rest breaks.” Everything is filled out and signed in “blue or black ink.”

There’s credence to the idea that fatigue approaches should look beyond mere hours-of-service limits. The argument underpinning OOIDA’s approach to hours-of-service reform is one that increases flexibility for drivers, rather than a rigid adherence to a clock. And the Australian system does leave drivers with the opportunity to use their own discretion to rest.

Some people might find the idea of filling out more paperwork before a trip to be, ahem, fatiguing. But the animal haulers petition notes that livestock haulers generally undergo specialized training, including extensive route planning in order to minimize stops and deliver the animals safely to their destination. Some of the training programs in certain industry segments, like pork and beef haulers, also address basic principles of driver fatigue management.

While it’s something of a mercy to see that the latest innovation proposed for fatigue management is decidedly old school, it also begs another question. If the folks in the livestock and animal hauling industry are so sure of the effectiveness of this approach, why don’t they just implement it anyway?