By Sandy Long
The definition of Gobbledegook is: Gobbledygook or gobbledegook (sometimes gobbledegoo) is any text containing jargon or especially convoluted English that results in it being excessively hard to understand or even incomprehensible. “Bureaucratese” is one form of gobbledygook.” In doing some research at the FMCSA website, I found a good example of ‘goobledygook’ in the postponed proposed rule making for mandatory EOBRS. https://www.federalregister.gov/articles/2011/02/01/2011-2093/electronic-on-board-recorders-and-hours-of-service-supporting-documents#p-212
“The agency recognizes that using share of crashes that are fatigue-coded could have two possible problems: Accident inspectors may be more likely to code crashes as fatigue-related if the driver has been on the road longer.”
Well then, if a driver has been driving nine hours and is involved in a wreck, he/she may be cited as being fatigued whether they are or are not actually fatigued. Theoretically, if a driver has only been driving one hour, they cannot be fatigued? Maybe that is why there are so many ‘fatigued’ related crashes then, because we drive for over an hour.
“ Also, the share of crashes that are coded as fatigue-related may conceivably increase simply because the share of crashes caused by other factors goes down. There could be no increase in the risk of a fatigue-related crash (the central question), but an increase in the share of fatigue-related crashes.”
The statistics may, because of using the time of driving criteria and a lessening of other causes of crashes, falsely report the incidence of fatigue related crashes thereby showing an increase of fatigue related crashes. So we are in a no win situation then as far as more and more regulations about fatigue coming along? Talk about making one’s job a necessity as more people are put on at the FMCSA et al and researchers hired to find out what else can be done to stop fatigued drivers, it is self perpetuating!
“The Agency has little evidence that either of these factors is a significant problem. Nonetheless, while the data are not as complete as FMCSA would like them to be, the Agency aimed to limit, to the extent possible, the likelihood that drivers will be fatigued, either when they come on duty or during or at the end of a working period. Safety benefits are based on this reduction in fatigue and an associated reduction in fatigue-coded crashes.”
The FMCSA has little basis in fact for many of the regulations it proposes and puts into effect, this is another one. There is no way to determine what a driver’s metabolism is and how that it may affect his/her fatigue levels even after a full night’s sleep. There are also too many causes of fatigue in humans to be able to even “…limit, to the extent possible…” the likelihood of any driver, whether of car or truck, being fatigued no matter how long they have been driving. Stress, how heavy of a meal was recently eaten; length of time sitting at a dock, family issues, depression, or even a dark and dreary day can all lead to fatigue, not to mention the hypnotic effect of white lines and windshield wipers.
EOBRs are not going to eliminate in any way, shape, or form, driver fatigue if that in itself is a real issue in crashes or just a perception by FMCSA or special interest groups from a few select accidents where a driver fell asleep. You cannot regulate the human body outside of a hospital with any sort of machine or electronic device. That is what we are talking about when we talk about fatigue, how each individual’s body reacts to certain conditions beyond lack of sleep. It is all just more goobledygook to further agendas hidden behind the fatigue issue.