What is written below is not about FedEx Custom Critical per se, FDCC is used as an example only because of timing, as explained below.
I post this to submit for debate the assertion that the FMCSA's fatigued driving BASIC score is a lie. It is a lie for two reasons.
First, violations that are cited uncer this category are mostly log book violations. Drivers can be wide awake when they make log book errors or false entries. The violations have nothing to do with driver fatigue. A violation where a driver is cited for driving or being on duty over the allowed HOS hours could be legitimately about fatigue. But violations cited for paperwork errors are not.
Second, it is a lie to suggest that the mis-named fatigued driving BASIC has any impact on safety results. While there is no question that log book errors are reduced by EOBR's and fatigued driving BASIC scores decline as a result, that score decline does not translate into meaningful and observable safety improvements for truck drivers or the motoring public.
In support of the second point, I offer the following.
In January, 2011, when the FMCSA first published the BASIC scores for carriers, I looked up the numbers for the top 25 expedite carriers by fleet size and put them into a spreadsheet.
At that time, FedEx Custom Critical was making the transition from paper logs to to EOBR's. The FMCSA numbers covered the previous 24 months, so the FDCC numbers showed the results for a mostly paper log company. Two years after that, the numbers would be for an EOBR company, making it handy to compare the results.
When the FMCSA published its first set of numbers, I thought it would be interesting to use FedEx Custom Critical as a case study on the effect of EOBR's on safety; not on fatigued driving lies (the notion that a log book violation automatically means the driver is fatigued), but on safety itself.
To do that, I recorded the then-available BASIC scores and crash numbers, and would let time pass so the company could complete its transition to EOBR's. The BASIC scores and crash numbers could then be compared and see what effect, if any, EOBR's had on the results. Twenty-four months have not gone by since January, 2011, but we are close enough to take a peek.
As expected, the fatigued driving BASIC scores dramatically improved after FDCC transitioned to EOBR's (lower is better). Other carriers that have adopted EOBR's report the same results.
Since EOBR's helped FDCC reduce its fatigued driving score by nearly half, can we then conclude that FDCC drivers as a group are twice as awake as they were before?
We cannot because the violations that EOBR's reduce are PAPERWORK violations. They have nothing do do with how drowsy or alert a driver may be. Indeed, it is physically impossible to commit come of the fatigued driving violations while driving a truck. The violations have nothing to do with fatigue or driving, but the FMCSA insists on calling them fatigued driving violations. The agency then takes another false leap by trumpeting the great progress EOBR's can make in getting tired drivers off the road.
But notice that nothing else significantly changed. If fatigued driving was really about fatigued driving, crash rates would improve, would they not? But this does not seem to be the case. Regardless of the major improvements in the (meaningless) fatigued driving BASIC, the other BASIC scores remained more or less the same, as did the crash rate (meaningful).
Note that the FDCC transition to EOBR's was not instantaneous. It took place over several months after the company mandate went out. So the following data cannot be taken as true before-and-after snapshots. We might need to let 36 months go by to get more accurate picture. But at this early point, the numbers provide interesting food for thought if nothing else.
Also note that the crash rate number shown below is not an FMCSA number. It is a calculation done by me. The number is obtained by dividing the number of crashes (an FMCSA number) by the number of power units in the fleet (also an FMCSA number) to provide a crash rate percentage.
(The crash number in the FMCSA's reporting system is itself controversial because no provision is made for screening out crashes in which the truck is not at fault. That's another major flaw in the CSA system but that's another story.)
The before/after numbers shown below are the first-published FMCSA data (before) and the most-recent data (after).
FDCC Numbers Before and After EOBR's
(Before EOBR's/After EOBR's)
Unsafe Driving: 53.1%/50.5%
Fatigued Driving (HOS): 51.8%/26.9%
Driver Fitness: 32.1%/33.0%
Controlled Substances and Alcohol: 5.7%/No Violations
Vehicle Maintenance: 24.9%/28.6%
Number of Vehicle Inspections: 2379/2291
Number of Driver Inspections: 3464/3216
Total Crashes: 57/57
Power Units: 1395/1459
Drivers: 2452/2567
Crash rate (my number, not an FMCSA stat, see above): 4.1%/3.9%
My tentative observations based on these numbers:
EOBR's are effective in reducing driver log book violations (as are other methods not involvoing EOBR's), but because most log book violations have nothing to do with actual driver fatigue, there is no way to know that EOBR's do anything at all to keep tired drivers off the road.
It is also interesting to note that the vehicle inspection rate (number of inspections divided by the number of power units) has changed little since EOBR's were adopted fleet-wide. Before EOBR's, on average, a FDCC truck was inspected 1.7 times in 24 months. After EOBR's it was 1.6 times.
So too with the driver inspection rate. Before EOBR's, on average, drivers were inspected 1.4 times in 24 months. After EOBR's it was 1.3 times.
It is sometimes suggested that having an EOBR in your truck will result in fewer roadside inspections. This limited sampling of one carrier's numbers do not bear that out. If it was true, the before and after difference in numbers would be significantly greater.
My research into this is not thorough. While the numbers are accurate, my methodology and conclusions may be flawed. While sharing my views here, I remain open to criticism and alternative points of view.
Again, the assertion, submitted for debate, is that the FMCSA's fatigued driving BASIC score is a lie.
I post this to submit for debate the assertion that the FMCSA's fatigued driving BASIC score is a lie. It is a lie for two reasons.
First, violations that are cited uncer this category are mostly log book violations. Drivers can be wide awake when they make log book errors or false entries. The violations have nothing to do with driver fatigue. A violation where a driver is cited for driving or being on duty over the allowed HOS hours could be legitimately about fatigue. But violations cited for paperwork errors are not.
Second, it is a lie to suggest that the mis-named fatigued driving BASIC has any impact on safety results. While there is no question that log book errors are reduced by EOBR's and fatigued driving BASIC scores decline as a result, that score decline does not translate into meaningful and observable safety improvements for truck drivers or the motoring public.
In support of the second point, I offer the following.
In January, 2011, when the FMCSA first published the BASIC scores for carriers, I looked up the numbers for the top 25 expedite carriers by fleet size and put them into a spreadsheet.
At that time, FedEx Custom Critical was making the transition from paper logs to to EOBR's. The FMCSA numbers covered the previous 24 months, so the FDCC numbers showed the results for a mostly paper log company. Two years after that, the numbers would be for an EOBR company, making it handy to compare the results.
When the FMCSA published its first set of numbers, I thought it would be interesting to use FedEx Custom Critical as a case study on the effect of EOBR's on safety; not on fatigued driving lies (the notion that a log book violation automatically means the driver is fatigued), but on safety itself.
To do that, I recorded the then-available BASIC scores and crash numbers, and would let time pass so the company could complete its transition to EOBR's. The BASIC scores and crash numbers could then be compared and see what effect, if any, EOBR's had on the results. Twenty-four months have not gone by since January, 2011, but we are close enough to take a peek.
As expected, the fatigued driving BASIC scores dramatically improved after FDCC transitioned to EOBR's (lower is better). Other carriers that have adopted EOBR's report the same results.
Since EOBR's helped FDCC reduce its fatigued driving score by nearly half, can we then conclude that FDCC drivers as a group are twice as awake as they were before?
We cannot because the violations that EOBR's reduce are PAPERWORK violations. They have nothing do do with how drowsy or alert a driver may be. Indeed, it is physically impossible to commit come of the fatigued driving violations while driving a truck. The violations have nothing to do with fatigue or driving, but the FMCSA insists on calling them fatigued driving violations. The agency then takes another false leap by trumpeting the great progress EOBR's can make in getting tired drivers off the road.
But notice that nothing else significantly changed. If fatigued driving was really about fatigued driving, crash rates would improve, would they not? But this does not seem to be the case. Regardless of the major improvements in the (meaningless) fatigued driving BASIC, the other BASIC scores remained more or less the same, as did the crash rate (meaningful).
Note that the FDCC transition to EOBR's was not instantaneous. It took place over several months after the company mandate went out. So the following data cannot be taken as true before-and-after snapshots. We might need to let 36 months go by to get more accurate picture. But at this early point, the numbers provide interesting food for thought if nothing else.
Also note that the crash rate number shown below is not an FMCSA number. It is a calculation done by me. The number is obtained by dividing the number of crashes (an FMCSA number) by the number of power units in the fleet (also an FMCSA number) to provide a crash rate percentage.
(The crash number in the FMCSA's reporting system is itself controversial because no provision is made for screening out crashes in which the truck is not at fault. That's another major flaw in the CSA system but that's another story.)
The before/after numbers shown below are the first-published FMCSA data (before) and the most-recent data (after).
FDCC Numbers Before and After EOBR's
(Before EOBR's/After EOBR's)
Unsafe Driving: 53.1%/50.5%
Fatigued Driving (HOS): 51.8%/26.9%
Driver Fitness: 32.1%/33.0%
Controlled Substances and Alcohol: 5.7%/No Violations
Vehicle Maintenance: 24.9%/28.6%
Number of Vehicle Inspections: 2379/2291
Number of Driver Inspections: 3464/3216
Total Crashes: 57/57
Power Units: 1395/1459
Drivers: 2452/2567
Crash rate (my number, not an FMCSA stat, see above): 4.1%/3.9%
My tentative observations based on these numbers:
EOBR's are effective in reducing driver log book violations (as are other methods not involvoing EOBR's), but because most log book violations have nothing to do with actual driver fatigue, there is no way to know that EOBR's do anything at all to keep tired drivers off the road.
It is also interesting to note that the vehicle inspection rate (number of inspections divided by the number of power units) has changed little since EOBR's were adopted fleet-wide. Before EOBR's, on average, a FDCC truck was inspected 1.7 times in 24 months. After EOBR's it was 1.6 times.
So too with the driver inspection rate. Before EOBR's, on average, drivers were inspected 1.4 times in 24 months. After EOBR's it was 1.3 times.
It is sometimes suggested that having an EOBR in your truck will result in fewer roadside inspections. This limited sampling of one carrier's numbers do not bear that out. If it was true, the before and after difference in numbers would be significantly greater.
My research into this is not thorough. While the numbers are accurate, my methodology and conclusions may be flawed. While sharing my views here, I remain open to criticism and alternative points of view.
Again, the assertion, submitted for debate, is that the FMCSA's fatigued driving BASIC score is a lie.
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