Fatigue and Opportunity

I know just what you are thinking: These words do not belong in the same sentence. Or even the same article. For the motorcoach industry, this is clearly not the case.

In the past 20 years, enormous progress has been made in the understanding of sleep, alertness and fatigue. Similarly, a number of approaches, methodologies and tools have been developed to predict fatigue-related safety problems and mitigate them. Many of these tools have been refined for, and applied to, a mix of freight and passenger transportation services around the world. However, the application of these principles and tools to motorcoach service has been difficult and elusive.

Variations and Band-Aids

A primary obstacle to the application of fatigue countermeasures to the motorcoach industry have been its unique structure and the seemingly endless variation of its operations. These characteristics, well-known to industry insiders, include:

  • The industry is has an unusual organization: Until recently, it did not even have its own regulatory agency. Yet is has the luxury of two umbrella organizations.
  • The industry is far more fragmented than other public transportation modes. While two companies own and operate a substantial portion of the nation’s motorcoaches, the average fleet size lies between four and six vehicles. The median fleet size is considerably smaller. More than ninety percent of motorcoach companies are small businesses.
  • Operations are further fragmented by their division into different service formats – charter, tour, intercity, commuter and a small number of which do not even conform to these classification. While there are similarities and overlaps, each format has its own distinct characteristics. Yet many companies of all sizes provide service according to all or most of these formats. Many also provide transit and school bus services. Many coaches operate in multiple formats during the same shift.
  • A disproportionate number of motorcoach companies deploy only a single vehicle where, often, the company’s owner is its only driver.
  • One characteristic common to most formats is long shift. In intercity service, these shifts commonly reflect the considerable distances spanned by the routes. Many routes operate practically around-the-clock. Charter and tour shifts are long because passengers take the same vehicle in both directions – and often do not stay overnight in between. Commuter shifts are long because they encompass both peak periods, while deployment levels are scaled back in between (making it necessary to assign drivers to split shifts).
  • Competing with subsidized intercity passenger rail services, unsubsidized motorcoach service is extremely competitive and price-sensitive. Because the industry is so fragmented, however, motorcoach operators must also compete aggressively with one another.
  • Because long trips place the vehicles far-removed from their storage and maintenance facilities, minor repairs must often be made “on the road.” This means that drivers may have to spend some of their off-hours in service and repairs, fueling and washing, deadheading to and from parts and service centers, standing by while their vehicles are being repaired – and compiling detailed and stringent records covering all of it.
  • Because motorcoach operations are largely unsubsidized (isolated intercity services provide the sole exception), services have been dictated far more by demand than by supply.
  • Because of the large number of tiny, separate fleets and the enormous distances they cover, opportunities to manage or coordinate shift changes, maintenance, spare vehicles and spare drivers are far more limited than those of other passenger transportation services. Two mega-companies, and a few dozen large ones, provide the only exceptions.

Quite simply, motorcoach services are the transit industry’s snowflakes. Of course, their uniqueness enhances service – largely because it translates into flexibility. At the institutional level, having two umbrella organizations yields some unusual benefits, providing two prisms through which industry-wide through, concern and need are, processed, consolidated and articulated. But at the operating level, motorcoach operations are time-and-space band-aids. Understandably, the duty cycles which reflect these spatial and temporal constraints do not coincide with their driver’s physiological capabilities. This is especially true when duty cycles change from day to day – and particularly when drivers sleep on different schedules on off-days than they do on work-days. And it is especially true for certain types of drivers, among whom variation in normal sleep-wakefulness cycles is already considerable.

Because of such variation in motorcoach operations, the derivation of representative or prototypical duty cycles – at least on a national level – has never been accomplished. To some degree, it defies classification. By contrast, most pupil transportation services are provided by school districts or their contractors on a clearly-defined, split-shift format which simply reflects class hours, and where 96 percent of all trips are provided for home-to-school purposes. (Four percent are field or activity trips, many of them provided by motorcoaches.) The transit industry is similarly uniform, with most services provided by a single agency or contractor (or handful of them) in each metropolitan area, operating a combination of peak, base, night and/or owl services, with deployment levels tailored to the corresponding crescendos and decrescendos of demand.

Gauntlets and Contradictions

It was into this environment that the newly-established Federal Motor Carrier Safety Administration (FMCSA) was thrown in 2000, the first institutional child of the millennium. Further complicating matters, the FMCSA’s predecessor department within the Federal Highway Administration had created few operating distinctions between passenger and freight transportation – and none insofar as its regulation of drivers’ operating hours.

The FMCSA has grown up quickly. Partly from its own instincts, partly as the result of pressure from Congress, the National Transportation Safety Board and truck industry labor unions, the FMCSA promulgated a Notice of Proposed Rulemaking to dramatically change its 65-year-old Hours-of-Service Requirements. Designed to elicit comments about the subject area under consideration, and capture insights to improve and refine it, the NPFM unleashed a spate of protect and criticism One of the loudest was the mantra, – “We’re not trucks.” In response, the FMCSA did what a responsible agency should – and what most industry professionals had hoped it would: It initiated a serious study to determine the degree to which this was true. The project was awarded to an internationally-acknowledged sleep and fatigue research organization, Boston-based Circadian Technologies, Inc. (Transportation Alternatives, this author’s consultancy, was given the privilege of serving as a subcontractor.)

To its credit, the FMCSA’s project framework was not restricted solely to the identification of motorcoach duty cycles and their comparison with those of the trucking industry: The FMCSA wanted to know how these cycles and shifts related to fatigue. This single twist jettisoned the agency decades into the future. For it acknowledged, for the first time in U.S. motorcoach history, that a regulatory mechanism based solely on limited hours might be of limited value compared to a performance-based mechanism – both as a matter of business, and as a matter of service. This bold undertaking did not challenge merely the details: It challenged the validity of their application and the validity of the regulatory framework that contained them.

To understand how breathtaking this leap is, one need compare only a single duty cycle prohibited under current Hours-of-Service regulations to one which is permitted:

  • After dumping off their children at Disney World, a coach full of parents leaves Orlando, Florida at 8:00 A.M. for the casinos of Biloxi, Mississippi. After hours of monotonous driving across the Panhandle along the I-10 Freeway, the motorcoach arrives in Biloxi at 2:00 P.M. At 8:00 P.M., the overfed, intoxicated, often penniless passenger board the coach for the trip home. At 2:00 A.M., the coach reaches Orlando. The next morning, the owner-operator begins the same marathon all over again. In between runs, of course, the driver has to park the coach, check in and out of a hotel, shower, eat, fuel the coach, wash the coach, fix the coach, order and retrieve spare parts, record all these activities in painstaking detail, and attend to “bookings” and other marketing activities.
  • At 8:00 A.M., another motorcoach filled with gamblers leaves Chesapeake, Virginia for Atlantic City, racing through the old, signalized, multiple-grade-crossing highways of the Eastern Shore to arrive in Atlantic City by 2:00 P.M. After a long afternoon and evening of sleep, the driver collects the passengers, loads the coach, and departs at 11:55 P.M. for the trip home – during which most of the passengers snooze. He arrives at 6:00 A.M. The driver-employee takes that day off and, the following day, provides the same trip once again.

While these two operating scenarios are similar, superficially, they differ radically in terms of their conformity to both current and proposed hours-of-service requirements and, ergo, their legality:

  • The second scenario is permissible by under both hours-of-service versions, existing or proposed because (a) there are almost 10 hours between the outbound and return portions of the trip, (b) trip segments encompass only six hours each, (c) only six of these hours occur within any 15-hour time span, and (d) the driver takes a full day off between round trips.
  • In contrast, the first scenario would be patently illegal under hours-of-service regulations since (a) the longest gap between the outbound and return trip segments is six hours, (b) no rest period longer than six hours is included, and (c) the driver provides this trip two days in a row.

Far more importantly – and essential to the project at hand – these scenarios differ dramatically in terms of their correspondence to the scientific principles related to sleep and fatigue:

  • A “morning person” driving under the first (illegal) scenario could easily take a long nap between trip segments and, consequently, might require fewer than eight hours’ sleep at night to become fully-rested. Thus, he would be rested and refreshed for both trip segments, and would drive both of them soon after awakening. Further, his repetition of the same pattern day after day would reinforce his circadian rhythm according to his driving schedule – causing his body temperature to dip to its lowest point late at night – while he was sleeping, not while he was driving. Thus, the correlation of the driver’s circadian rhythm with his duty cycle would permit him to both sleep and nap soundly (the sleep-wakefulness rhythm includes a “post-lunch dip”), and would place him on the road when his body temperature was relatively high,\C2 and he was most alert.
  • In contrast, the second (permissible) scenario would only be safe if the driver maintained the same sleeping pattern on his days off. If he did not, his biological clock would be set to the sleep-wakefulness cycle of his not-work days. As a result, his body temperature would dip to its lowest point either during his outbound trip (if he were an “owl” or “night person”) or his return trip (if he were a “lark” or “morning person”) – and his mind and body would be forced to fend off sleep during the very times they would be most in need of it.

These examples illustrate a fundamental enigma for the motorcoach industry and its regulatory agencies under any hours-of-service framework: A work shift that is legal may be dangerous, while one that is illegal may, for many drivers, be safe. These realities are haunting. But they also reek of opportunity.

The fact that these scenarios apply to both current and recently proposed hours-of-service regulations illustrates another important point about such a regulatory framework.: While motorcoach operators clearly prefer the existing version of regulations, this version is hardly a panaceas – and are clearly problematic for the trucking industry, where the sleeper berth exception is, from a scientific perspective, extremely driver-specific: Biologically, the division of eight hours’ sleep into two segments works fine for cats and horses (whose sleep is broken into 16 segments). Unfortunately, it does not work for some primates, many of whom cannot even nap unless they are practically senseless from sleep deprivation.

Of course, under the right conditions, many motorcoach and truck drivers can safety perform well beyond the 10-out-of-15 hours limit. This reality may have only minor impacts on trucking – for example, as it relates to food spoilage and refrigeration costs. But it has enormous implications for motorcoach service, since extending the temporal boundaries of same-day trips would necessarily expand their spatial boundaries – permitting metropolitan areas to overlap and, as a result, thickening the density of same-day origin and destination pairings at both ends of the trip. With only a moderate percentage of drivers capable of this performance, and a limited number of applications in which to apply it, this flexibility could change the dynamics of even a small company. It could translate into survival for many owner-operators.

Challenges, Risks and Courage

By its willingness to explore such issues, the Federal Motor Carrier Safety Administration leapfrogged decades of outdated science and mythology. It opened the door to the consideration of a degree of regulatory flexibility almost unheard of in modern passenger transportation. Of course, because flexibility is a mainstay of motorcoach operations – and one of its principal advantages over passenger rail service – the Administration’s willingness to examine motorcoach operations against the backdrop of modern medical research may lead to changes which help the industry prosper and thrive.

The change from a purely hours-based regulatory framework to a largely-driver-specific, performance-based structure is likely to be both profound and sweeping. Such a framework will almost certainly reward those operators more knowledgeable, more skilled and more creative. It is likely to enhance the industry’s information-sharing organizations – by extending their reach through the provision of information, tools and technical assistance. It will almost certainly change the relationship between the industry and its principal regulatory agency – a relationship which, in recent years, has often been strained, resentful and adversarial.

We can learn important lessons from the pupil transportation and airline industries. Boasting it is the nation’s only transportation community that welcomes regulations, the pupil transportation community operates close to half a million school buses. While the airline industry claims to be the safety mode of transportation “per passenger mile traveled,” the general public clearly attributes this accomplishment to FAA regulations. Until recently, demand had practically outstripped the air line infrastructure. In simple terms, safety sells.

A regulatory agency is defined largely by the projects it undertakes. The first phase of what may someday be called “The Sleep Project” is such an effort. It may be a defining moment in the FMCSA’s history. But it may also be a defining moment in the industry’s evolution. The FMCSA began its tenure with the adventurous objective to reduce motorcoach fatalities by 50 percent. By its willingness to examine motorcoach operations against the backdrop of a growing body of knowledge, it is likely to succeed. However, to do so, all the players must perform. If we do not, we can hardly claim we were not warned. We can hardly claim we were not consulted.

The Shape of Things to Come

In the coming months, motorcoach industry members will have considerable opportunity for input on these issues. A detailed survey available through a variety of forums (including this magazine and its web site) will provide us with a unique and focused opportunity to tell our regulatory agency about things critical to our operations and our needs. Because the FMCSA is poised to listen, we will have a unique chance to shape our future.

Along with an awareness of a new body of knowledge, our vocabulary is likely to change and grow. Terms like circadian rhythm and inverted sleep cycles will become commonplace. There will be talk of owls and larks. And there will be much talk of bio-sensitive scheduling and driver assignment. With the adoption of such concepts, the way motorcoach operations are visualized and articulated is likely to change as well. Accompanying this, of course, will be a slate of new ways to market motorcoach services – and a new perspective on marketing their safety.

We will also find an enormous palate of already-existing approaches, methodologies and technologies designed and proven to combat fatigue. This palate ranges from wrist-mounted fatigue-sensation alarms to napping facilities. (Many European motorcoaches contain sound-proofed, under-floor sleeping compartments near the rear axle – adjacent to four air-bags and below the coach’s un-sprung weight.) A range of mythologies will also be exposed. For example, while studies have shown listening to the radio do not combat fatigue, two studies found that one item which does is peppermint.

During a decade operating a large paratransit system, and continually refining its routes and schedules, I taught my staff that every change is an opportunity for productivity improvement. This principle will be unleaded by structure changes in the motorcoach service regulatory framework. Of course, in order to realize opportunities, one must explore and implement them. With increasing recognition of the principles involved in sleep and fatigue by the railroad and trucking industries, and more recently the transit industry, their acknowledgement by the motorcoach industry cannot lie far behind – like it or not. They are ideas whose time has simply come.

With complete assurance, any historian can begin a speech about any period of history by proclaiming that, “It was a period of great change.” For the changes certain to come, I tip my hat to the FMCSA.

After all, I have history on my side.

Publications: National Bus Trader.