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ATRI says FMCSA's HOS Field Study Report is flawed

by Vicki Simons

The news release states (in part),

MAP-21 required that the field study be “representative of the drivers and motor carriers regulated by the hours of service regulations” but the study includes, on average, less than 12 days’ worth of data for each of only 106 drivers.

Every scientist knows that to get an accurate measurement, one needs a "representative sample." If the sample is too small, the conclusion drawn can be badly skewed.

In this particular case, not only were there not enough drivers in the pool being surveyed, but there were not enough days' worth of data studied.

Behind the data problem, one has to ask who authorized the study to be so small and what he/she/they wished to gain from it. Surely someone at the FMCSA suspected that such a radical change in the Hours of Service regulation as what took place in July 2013 was going to prompt a deeper investigation of the details involved in the study! Or were the powers that be at the FMCSA so egotistical as to think that their idea would never be challenged?

It has been over 9 months since the new HOS regulation was put in place, which means that there is now 9 months' worth of truck crash data to examine. We would be very interested to learn if the number of trucker-caused truck crashes since the new HOS regulation was put in place went up, went down or stayed the same as before the regulation was changed.

As I asked in an August 1, 2013 guest blog,
“What if the new HOS rules don’t reduce truck driver fatigue or improve safety? What if the ‘common sense, data-driven changes’ and reduced work hours back fire? Will the FMCSA be willing to reverse course? How long will it take before we know?”

This is critical because it affects the operation of every commercial motor vehicle in the USA.

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