Before the 34-hour restart study has even gotten started, it’s already drawing criticism from a lawmaker who is calling for steps to ensure confidence in the study’s validity and objectivity.
Rep. Richard Hanna, R-N.Y., sent a letter to Department of Transportation Secretary Anthony Foxx calling out the agency’s decision in selecting Virginia Tech Transportation Institute to conduct the study.
“It’s surprising and troubling that the department once again hired Virginia Tech Transportation Institute to complete this study, as this is the same entity which conducted a highly criticized 2011 study on hours of service for commercial truck drivers,” Hanna wrote to Foxx.
“While I fundamentally disagree with the department awarding the study to VTTI, I respectfully recommend that you support four specific actions that would increase congressional and stakeholder confidence in the final study product.”
Hanna recommends that there should be a peer review team for the VTTI study, and that team should be selected by the Committee on Truck and Bus Safety of the National Academies Transportation Research Board and staff of relevant congressional committees. He contends this will show a commitment on the part of the DOT that objective analysis of the data will actually happen.
Beyond review of the research, Hanna also made recommendations related to driver selection for the study, to the number of overnights included during restarts and collection of “safety critical event” data.
Hanna pressed the agency to make sure that the drivers participating in the study were “truly representative of the industry.”
As teed up, VTTI is recruiting drivers who routinely work between 60 and 70 hours per week and who typically work at night.
“This is concerning because it indicates that the researchers do not understand how the 34-hour restart is being used in practice,” Hanna wrote. “Most drivers use the restart not to maximize weekly work hours, but rather as a record-keeping tool to make it easier to log hours and to ensure that operational flexibility comes at the start of their workweek. … More typical truck drivers must be included in the research.”
Moving to what is actually being tracked and studied, Hanna wants VTTI and the DOT to limit the number of overnights in a restart. Currently, the plan is to compare restarts with one overnight to restarts with two or more overnights.
“This is consistent with the previous flawed restart field study that was criticized by stakeholders. If the research is indeed intended to study the relative benefits and drawbacks of the two rules, then restarts of more than two nights are not representative of the actual restart restrictions being studied,” Hanna wrote.
The lawmaker also wants a “safety critical event” data collected specifically from 5 a.m. to 9 a.m.
“I have heard from constituents and industry stakeholders that the 2013 restart rule forces additional drivers onto the road during the morning rush when children are traveling to school, workers are commuting, and there is generally higher traffic level on our roads,” Hanna wrote. “The impact of more commercial drivers on our roads during this window of time must be honestly assessed in order for the study to be legitimate and reflective of the real-world application of the restart rules.”
The Owner-Operator Independent Drivers Association has been critical of much of the research conducted by the agency in recent years and appreciates Hanna taking the initiative to hold the agency to a higher standard.
“We greatly appreciate Rep. Hanna’s direct and thorough comments we agree that while truckers are held to an extremely high standard by FMCSA, the agency appears to be totally missing the mark with this study. Regulatory impact studies should truly investigate the issues at hand and be representative of our nation’s trucking industry,” said OOIDA Executive Vice President Todd Spencer.
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