Sent to BBC "Midlands Report" in response to programme about "cowboy" HGV drivers.
										15-1-98

	Dear Sir,

			I have just watched your Midlands Report on the subject of driver fatigue, which I thought was very good, and having been an HGV driver for 15 years I would like to make a few comments.

	Your report said that lorry drivers are allowed to work for nine hours with a 45 minute break in the middle. This may give the public the idea that that is all a lorry driver is allowed to do. In fact that relates only to driving time, not overall work. A lorry driver can work for up to 16 hours, of which ten can be driving, then have eight hours break, (not eight hours sleep, but eight hours total break in which time he also has to eat, wash, etc), then be back behind the wheel and do it all again.

	The 45 minute break must be taken after 4½ hours driving. Other work is not taken into account, and it is common, in my experience, for drivers to work for seven or eight hours before taking a break. The rest of the time is usually spent loading or carrying out other duties. To make matters worse the European Court has imposed an interpretation of the rules which, taken to extremes, allows a driver to drive for nine hours with only a fifteen minute break in the middle. The British Government, to their credit, fought for an interpretation which would force the full 45 minutes, but they were over-ruled by the court.

	The regulations used to cover all work, not just driving, and there also used to be a restriction on total duty time. A driver had to have a break (a full hour in the case of articulated lorries) after four hours driving or 5½ hours total work, whichever came first, and was also only allowed a total duty time of 11 hours, although this could be stretched to 12½ hours twice a week provided that the following day was reduced by the same amount to compensate. These rules were scrapped in 1987 in favour of the new rules which allow drivers to work for 80 hours a week quite legally.

	The relaxation of the rules, and the European Court's interpretation which makes a bad situation worse, is exploited even by large well-known companies who would never dream of calling themselves "cowboy operators" but will use every minute (and more) of their drivers' permitted working hours, regardless of safety considerations, and the prospect of a lorry operator (or his customer) accepting that a load is late because the driver stopped to have a nap to relieve tiredness is, frankly, laughable. Road safety is all very well, and operators may pay lip-service to it by supporting pressure groups such as Brake and putting "How's my driving" stickers on the backs of their lorries, but if there's a load waiting to be delivered...

	Road haulage is now a 24-hour a day operation. Twenty years ago a 6am start was early, and the relatively few night drivers usually started around teatime and had fairly easy inter-depot trunks with plenty of time in which to do them. Nowadays, however, drivers start at all hours of the day and night, (the 2am start is not uncommon), and may well be doing a full day's work, including a high mileage, multiple drops, and unloading his own vehicle, during the hours of darkness.

	Finally there is another factor which I believe to be instrumental in causing tiredness and fatigue among lorry drivers. For the last few years lorries and coaches have had to be fitted with electronic speed limiters, set to 56mph and 65mph respectively. This means that drivers now travel for hours on end at an unvarying, fairly slow, speed, which is maintained without any input from them at all. This, in my experience, causes tiredness, loss of concentration, and a feeling of detachment from the vehicle, and I find I make many more unforced errors whilst driving with a speed limiter than I ever did before. In the first year after they became compulsory the number of lorry drivers killed rose by 24% and the number of coach drivers killed rose by 67%, reversing the previous downward trend. The EU has plans to fit them to cars, set to 62mph, (some cars appear to already have them as part of the engine management system, although they aren't set), and to lower the set speed for lorries to 50mph and for coaches to 55mph. The consequences when this happens don't bear thinking about.

	Over the last couple of years I have had several articles published in magazines on the dangers of speed limiters, and I have taken the liberty of enclosing copies of some of them, along with copies of  tachograph charts showing how the limiter holds the speed constant for long periods. There is also one chart taken from a vehicle on which the limiter had temporarily escaped being set, showing how the speed varies when the driver is in control of the vehicle.

	Your programme has done a very useful job in raising the issue of driver fatigue, but I hope that I have shown that, with ridiculously lax regulations, drivers increasingly working at unnatural times of the day, and the fitment of devices which seem purpose-designed to cause fatigue and inattention in drivers, there is more to solving the problem than fitting high-tech sleep detectors and increased policing to catch the "cowboys".

	
		Yours Faithfully,





				C. A. Lamb