Bus Driver Fatigue – A Wake-Up Call

We all know it. We have all, at some point or another, felt its effects, wishing to succumb to its entrancing form of temptation. Though we may attribute various appellations to this state, fatigue does not discriminate, it debilitates. Whatever our profession, our position, once the symptoms of that familiar sense of drowsiness and lethargy arises, our level of alertness diminishes and, consequently, our performances suffer significantly. When the eyes begin to grow heavy, we become helpless as we slowly slip into unconsciousness.

According to the Canadian Centre for Occupational Health and Safety (CCOHS), “fatigue is the state of feeling very tired, weary or sleepy resulting from insufficient sleep, prolonged mental or physical work, or extended periods of stress or anxiety. Boring or repetitive tasks can intensity feelings of fatigue.”

Though never agreeable, fatigue is often discarded as a mere inconvenience, a brief, temporary excursion into the realms of discomfort. However, consider professions which necessitate long hours of uninterrupted concentration, those occupations where alertness operates concurrently with responsibility. In such cases, the manifestation of fatigue can place individuals in potentially mortal danger.

Bus drivers work primarily in liminal zones, operating their vehicle along all manners of roads with the aim of safely transporting passengers to their final destination. Ignoring the droning lull of the engine’s persistent hum and the monotonous view from the windshield, a recurring procession of the repetitious, the bus driver must maintain a steady, forward motion in a state of vigilant attentiveness.

Accidents are unavoidable; one cannot anticipate the unexpected, and despite adequate preparation, the spontaneous can veer its evil head without notice, transforming travel into tragedy. The key, however, is prevention.

Due to the pressures from some operators, driver fatigue has become an increasingly important area of concern, albeit a potentially preventable one. Current legislation can have drivers working 16-hour days, 13 of those hours behind the wheel, with only 8 hours between shifts. Those 8 hours between shifts do not, many argue, allow drivers to have sufficient time to drive home, – or to their accommodation – sleep and drive back to work for the next scheduled shift. According to the Amalgamated Transit Union (ATU) Local 1624, this work cycle can continue for 14 consecutive days. Such schedules are fodder for fatigue and thereby pose a significant threat to roadway safety.

The CCOHS provide the results of research on the subject of fatigue which “say we need at least 7.5 to 8.5 hours every day. Studies have reported that most night workers get about 5 to 7 hours less sleep per week than the day shift. (You can accumulate a sleep debt, but not a surplus).” Considering the immense responsibility placed on the shoulders of bus drivers, proper rest ranks as a chief priority to ensure safety.

Though difficult to measure, the consequences of fatigue are clear. According to the CCOHS, studies report the effects of fatigue as “reduced attention and vigilance, reduced reaction time – both in speed and thought, failure to respond to changes in surroundings, [an inability] to stay awake (e.g., falling asleep while operating machinery or driving a vehicle), and increased accident rates,” among others.

Bus driver fatigue is a serious public policy matter and Transport Canada is also investigating the potential threat of fatigue. “Transport Canada recognizes that reducing driver fatigue is an important issue and has been involved in fatigue research and regulatory developments on road safety issues over the past 15 years,” says the Honourable Lisa Raitt, Minister of Transport. “The regulations that address the maximum hours that a commercial motor vehicle (bus and truck) operator can drive were amended in 2005 after more than 10 years of review and deliberation. During that time, the Department consulted with experts in the field of fatigue, provincial and territorial representatives and with industry to assist in the development of the amended rules. The template for the review was National Safety Code (NSC) Standard #9 – Hours of Service which falls under the Canadian Council of Motor Transport Administrators (CCMTA). The federal and provincial/territorial hours of service regulations are patterned after the NSC standard. Many changes were implemented in the revised NSC standard and subsequently incorporated into the federal and provincial/territorial regulations that respected the science on fatigue but still provided the industry with a reasonable level of flexibility in which to operate.”

There are two types of fatigue: chronic and acute. The fatigue experienced by drivers falls under the category of acute – chronic referring to a constant, severe syndrome. Acute fatigue is temporary and, according to the CCOHS, “results from shortterm sleep loss or from short periods of heavy physical or mental work. The effects of acute fatigue are of short duration and usually can be reversed by sleep and relaxation.”

Driver fatigue is not a recent area of concern for Transport Canada, the issue having been under investigation for some time.

“Transport Canada developed the North American Fatigue Management Program (NAFMP) over the past 10 years with Government, academia and industry partners from Alberta, Quebec and the United States,” says Raitt. “The NAFMP is the result of an evidence-based scientific multiphased development process. It is a voluntary, free of charge, fully interactive, bilingual, web-based education program that provides carrier management, shippers, drivers and their families with resources and tools to help them to understand the science of fatigue and how to best mitigate it. The NAFMP provides a return on investment calculator and knowledge about fatigue. It has the potential to alter attitudes, change motivations and shape a carrier’s safety culture. It is an ideal complement to hours of service regulations. The number of visitors to the program website remains strong. Transport Canada has not, however, received any direct feedback from ATU on this subject.”

Recently, Allan Medd, president and business agent of ATU Local 1624, launched a petition addressed to Raitt calling for changes to the legislation. The proposed amendments are “10 hour-maximum driver time per day, 14 hour-maximum on duty per day, [and] 10 hour-maximum guarantee for rest between shifts.”

A rested driver, one can argue, is an alert driver. In response to the ATU’s call for change, Raitt says: “The regulations set the minimum level of off-duty time at eight consecutive hours between shifts, with a minimum of 10 hours of rest per day. The regulations do not restrict a driver from obtaining the amount of off-duty time that he/she believes is necessary to minimize or reduce fatigue. The key is for drivers to obtain the amount of rest required to minimize or eliminate fatigue. The regulations contain limits on the amount of driving or work as a safety measure to restrict drivers from working beyond generally accepted limits.”

Raitt adds, “the enforcement of the hours of service is a joint federal/ provincial/territorial activity. The provinces and territories enforce the federal regulations in addition to their own respective regulations. Any further review of the hours of service would be undertaken under the auspices of the CCMTA and centred on NSC Standard #9 – Hours of Service. At the present time, there are no plans to revisit the NSC hours of service standard or the federal/ provincial/territorial regulations.”

Like all manner of societal organizations and procedures, operators are bound by legislations and laws. Despite the ATU’s call for amendments in current legislation, Raitt argues that proper investigations into the issue of fatigue itself should not be bypassed and that regulations do not reveal all facets of the issue.

“Regulations represent a necessary and fundamental part of fatigue management,” says Raitt. “They provide legal limits to the amount of work that can be done given specific timeframes and they preserve a driver’s off-duty time. Regulations, however, do not represent the complete solution to addressing the issue of driver fatigue. Regulations do not provide knowledge about fatigue and they do not change driver attitudes, motivations or the safety culture in a company. It is widely understood today that in order for a fatigue mitigation approach to be comprehensive, all of these issues should be addressed. The current thinking is that regulations should be complemented by other interventions that could be adopted voluntarily. It is for these reasons that Transport Canada developed the NAFMP.”

The ATU’s petition also requests that “all motor coach vehicles be equipped with electronic logging technology” which will monitor every movement that the bus makes through a graphic system, capturing speed, distance covered, and location. Accurate logging is a significant component of a bus driver’s responsibilities for it details the activities of the operator and the vehicle. An electronic logging system would ensure that truths are not being bent for financial gain and that all procedures are being followed.

“Transport Canada is also participating on a CCMTA Project Group that is developing a new NSC technical standard for the use of electronic on-board recorders,” says Raitt. “These devices reduce the opportunity for commercial drivers to falsify logbooks and as a result, exceed regulated driving hours, which may then contribute to driver fatigue. Transport Canada supports the development of an electronic onboard recorder technical standard that is operationally feasible for both industry and government regulators and implemented consistently across all jurisdictions.”

Regulated, electronic logging and the debate about work hours are part and parcel of the issue. Driver fatigue is but one potential area of concern when it comes to roadway safety. “For driver behaviour issues, there are a host of tools that can be used,” says Raitt. “The key issues are fatigue, distraction, driving under the influence of alcohol or drugs and aggressive driving. Through the CCMTA, Transport Canada continues to be involved with its stakeholders in a number of ways to address these issues.”

Driver fatigue in the motor coach industry is a serious public policy matter. A single crash can result in countless casualties. The potential for prevention remains a recurring note, a rally for change. Both the ATU Local 1624 and Raitt wish to promote safety and measures are being taken to investigate the issue. Medd’s petition promotes change and reveals the pressures which bus drivers must face on a daily basis. For years now, Transport Canada has been tasked with investigating the issue, an issue which they are not near ready to ignore.

“Transport Canada takes the issue of driver fatigue very seriously and has been leading research and regulatory initiatives to address this for more than 15 years,” says Raitt. “We are continually analyzing the evolution of scientific knowledge and conducting research so that we are positioned to support our regulatory activities and provide credible scientific advice.”