Safety Challenges and Oversight in the Motorcoach Industry: Attitudes and Perceptions of Drivers, Roadside Inspectors, and Federal Investigators

Abstract

Interstate motorcoach travel has been the fastest-growing transportation mode in recent years. To identify challenges to monitoring compliance with motorcoach safety regulations and to examine factors affecting safety, four focus groups with a total of 32 participants were conducted during 2011, one with federal safety investigators, one with state motor carrier inspectors, and two with motorcoach drivers. Investigators and inspectors expressed concern about falsified logbooks, inadequate sleep among motorcoach drivers, hazards from speeding motorcoaches, practices by motorcoach carriers to mask ownership and avoid oversight, and difficulties keeping up with rapid motorcoach industry growth. Drivers described problems with getting sufficient sleep, pressure to drive longer than permitted, and fears of motor carriers giving them less work if they turned down driving jobs. Drivers said that driving 72–74 mph was acceptable in light traffic. To help assess workload among personnel performing safety oversight, data on numbers of motor carriers, commercial motor vehicles, federal investigators, and state inspectors were obtained from the Federal Motor Carrier Safety Administration (FMCSA). The data suggested a heavy workload (2.13 inspectors per 1,000 commercial motor vehicles). The focus groups of inspectors, investigators, and drivers indicated the existence of serious motorcoach safety problems, provided insight about the multiple factors contributing to them, and described major obstacles to effective safety oversight. The qualitative nature of focus group research means that these notable findings will need to be measured using other methods such as surveys and observational studies.

INTRODUCTION

The safety of motorcoaches – buses designed for long-distance travel that typically carry 40–60 passengers – has been a subject of concern for the public, legislators, and federal and state agencies for many years and this concern increased during 2011 after several fatal crashes. Testifying at a hearing held by the U.S. House of Representatives, the Administrator of the Federal Motor Carrier Safety Administration (FMCSA) stated: “This year has been the worst period in recent history for motorcoach safety. . .” [Ferro, 2011(a)]. A National Motorcoach Safety Summit and regional roundtables were held during September 2011 to address these concerns [FMCSA, 2011(a)].

The motorcoach industry transports hundreds of millions of passengers every year [Klein, 2009; O’Toole, 2011; Schwieterman and Fischer, 2010; Bourquin, 2010]. Charter operations carry groups that have hired them for custom trips, whereas scheduled operations provide regularly scheduled trips, publicized online or through other means, open to any passenger who purchases a ticket. A popular service, referred to as curbside service, consists of providing scheduled service between cities or from a city to a popular destination, picking up or discharging passengers at places other than traditional terminals, and charging low fares.

After years of declining ridership from 1960 to 2005, annual growth rates for scheduled intercity motorcoach service ranged from 5.1 to 9.8 percent between 2006 and 2011 [Schwieterman and Fischer, 2010; Schwieterman et al., 2011]. Between 2010 and 2011, the 7.1 percent growth rate for scheduled intercity motorcoach service eclipsed the growth rates for air service (1.5 percent) and rail service (1.2 percent).

The charter bus industry is larger than the scheduled bus industry, employing about 31,000 people in 2009, compared with about 15,000 in the interurban and rural bus transportation sector [U.S. Census Bureau, 2011]. During 2009, the National Household travel survey estimated that 241 million person-trips occurred on charter and tour buses and 60 million occurred on intercity buses in the United States [Federal Highway Administration, 2011].

Although fatal crashes involving motorcoaches are relatively uncommon in the United States compared with large trucks or passenger vehicles, averaging 47 per year [Matteson et al., 2011], each individual event carries the potential for a large number of deaths and non-fatal serious injuries. The most deadly motorcoach crash in 2011 resulted in 15 fatalities and 17 non-fatal injuries among occupants [National Transportation Safety Board (NTSB), 2011]. Other motorcoach events investigated by the NTSB have resulted in even greater numbers of lives lost, including one in Texas where 23 occupants died [NTSB, 2007]. Occupants of passenger vehicles involved in collisions with motorcoaches have a higher risk of death and injury than motorcoach occupants due to the disparity in size and weight [NTSB, 2011(a)].

The federal responsibility for motorcoach safety is split between two agencies within the U.S. Department of Transportation (2009). The National Highway Traffic Safety Administration is responsible for mandating what equipment is installed on newly-manufactured vehicles and for safety recalls. The FMCSA is responsible for developing and enforcing safety operational regulations for the interstate motor carrier industry, including freight carriers and passenger carriers, as well as intrastate carriers of hazardous materials. States are responsible for safety oversight of all other intrastate carriers.

The FMCSA has the authority to grant approval for motor carriers to begin operations and also can shut them down if they pose an imminent hazard or have a pattern of serious violations of safety rules. The FMCSA intermittently performs comprehensive compliance reviews that involve visiting the headquarters of a motor carrier to examine adherence to Federal Motor Carrier Safety Regulations and Federal Hazardous Material Regulations. Motor carriers often receive advance notice of a compliance review, but this is not always the case.

The requirements for becoming a new interstate passenger carrier are relatively few. New entrants are required to fill out one registration form (MCS-150) to obtain a U.S. Department of Transportation (DOT) number, fill out a second registration form (OP-1(P)) to obtain a motor carrier number granting authority to transport passengers, pay a $300 fee, and arrange for their insurers to file a form indicating that mandatory insurance has been obtained. FMCSA then issues a Certificate of Operating Authority if all forms have been submitted and if no objections have been received during a 10-day period during which the applicant has been listed in the FMCSA Register (FMCSA, 2011(b)). As part of their oversight responsibility, the FMCSA is required to closely monitor the safety performance of new entrants for 18 months from their receipt of operating authority to decide whether continued operating authority is warranted. The agency’s policy is to try to perform safety audits of new passenger carriers within 6 to 9 months of their start date. The safety audits are less comprehensive than a compliance review (they may last only a few hours) and aim to see whether a passenger carrier understands safety regulations and has basic safety management controls in place.

Roadside inspections are essential for assessing whether motor carriers are following safety rules. States have the primary responsibility for roadside inspections of commercial vehicle driver logbooks, driver qualifications, and vehicle condition for motor carriers. The FMCSA provides financial assistance under the auspices of the Motor Carrier Safety Assistance Program to states to carry out inspections and perform other activities to promote motor carrier safety. Inspections vary in terms of how comprehensive they are and whether they focus on the drivers, vehicles, or both [FMCSA, 2007]. Level I inspections are the most thorough and take about 30 minutes.

The FMCSA has the Compliance, Safety, Accountability program, which seeks to identify the motor carriers most in need of state inspections and federal oversight through using data available from state databases. These data include roadside inspection results, moving traffic violations, and police-reported crashes. Motor carriers are stratified by size of the motor carrier and operational characteristics and then ranked against each other. Motorcoach carriers do not have a separate category. Pilot data suggested that CSA is an effective tool for improving motor carrier compliance, particularly warning letters triggered by CSA rankings [Green and Blower, 2011].

Driver fatigue is a major focus of actions by enforcement personnel. Interstate motorcoach drivers are subject to rules limiting how long they can drive. Specifically, motorcoach drivers must be off duty for 8 hours before they are allowed to drive 10 nonconsecutive hours. Driving is not permitted after logging 15 hours of on-duty time, but the 15 hours may not always be consecutive, and the hours can extend over a longer time period if the driver takes breaks. Specifically, motorcoach drivers can log themselves off duty between driving periods and can legally lengthen their work day by doing so; this means they may be allowed to drive even if more than 14 hours have elapsed since starting their work day.

Speeding is another concern applicable to motorcoaches. Speeding makes the risk posed to occupants of lighter vehicles even greater. One study found that motor carriers that are in the 50th percentile or higher for unsafe driving performance, which primarily reflects speeding tickets, have a significantly higher crash risk than those in lower percentiles [Green and Blower, 2011].

Motorcoach safety depends on multiple factors, including drivers and passenger carriers being willing and able to comply with safety rules and how consistently those rules are enforced. The National Transportation Safety Board (NTSB) (2011(a)) conducted an investigation concerning motorcoach safety in response to a request from Congress. This paper reports on one component of the NTSB investigation in which perspectives of both the motorcoach drivers and the enforcement personnel were sought in order to better understand the safety challenges and difficulties encountered when trying to exercise oversight in the motorcoach industry. Areas examined included driver fatigue, opportunities for sleep, hours-of-service (HOS) enforcement, carrier practices that can impede oversight, enforcement staffing, speeding, vehicle maintenance, safety violations, and driver working conditions. Participants volunteered suggestions for improvements.

METHODS

Qualitative methods were used, including focus groups and non-structured interviews with FMCSA safety investigators. The NTSB conducted four focus groups, each of which lasted two hours. The first focus group consisted of nine state personnel from two New Jersey law enforcement agencies whose work included performing roadside inspections and some compliance reviews of interstate motorcoach carriers. Several supervisors of state inspectors observed the first focus group. The second focus group consisted of 12 FMCSA safety investigators based in New Jersey, New York, and Pennsylvania whose work included performing compliance reviews. FMCSA supervisory personnel participated in this focus group alongside investigators. Both the inspector and safety investigator focus groups were conducted at the New Jersey headquarters of the FMCSA in June 2011. Participants provided NTSB staff with their experience in performing safety oversight of motorcoaches using an anonymous questionnaire. No remuneration was provided.

The other two focus groups included a total of 11 motorcoach drivers who had a broad range of driving experience. Their work involved charter/tour operations and scheduled motorcoach operations. The two motorcoach driver focus groups were conducted during July 2011 at the sole legal motorcoach parking/rest facility in Atlantic City, New Jersey. A voluntary anonymous background questionnaire was filled out by participants concerning their experience as motorcoach drivers. Drivers were given a $10 gift card to thank them for participating.

All of the focus group participants were volunteers. Inspector and investigator participants were recruited through an announcement made by the FMCSA New Jersey office on the behalf of NTSB. Some enforcement personnel said they had switched their schedules so they could participate and make their views known. Drivers were recruited in person by the moderator and an assistant at the Atlantic City rest facility. To avoid interfering with rest, drivers were approached to participate only if they were not attempting to sleep in the lounge at the rest facility.

At the beginning of each focus group, the NTSB moderator explained the purpose of the focus group and the procedures to be followed, including that the discussion would be audio-recorded but that the recordings would be destroyed once the conversation was transcribed. The participants’ names were not collected nor were the names of the carriers employing the participating motorcoach drivers. Open-ended questions were asked by the moderator, who attempted to ensure that all participants had an opportunity to express their views on the topics of interest. The transcriptions and notes taken by the assistant in each group were analyzed and then summarized. A separate summary was generated for inspectors, investigators, and motorcoach drivers [NTSB, 2011(b); NTSB, 2011(c)].

Quantitative data on safety enforcement workloads were examined to supplement focus group findings and individual interviews. Data were obtained from FMCSA about the total number of state inspectors certified to do motor carrier inspections and the total number of federal safety investigators certified to do compliance reviews. NTSB extracted total numbers of motor carriers over which FMCSA had jurisdiction and total commercial motor vehicles reported as being owned or leased by these carriers from FMCSA databases. FMCSA had incomplete data for commercial motor vehicles falling solely under state jurisdiction, namely those operated by intrastate motor carriers that did not carry hazardous materials.

RESULTS

Description of Focus Group Participants

Among roadside inspectors, about half of the participants had more than five years of experience. Over half of the participants had performed at least 300 motorcoach inspections.

Among federal safety investigators, almost all reported having had more than five years of experience with motorcoach oversight. The majority had performed at least 200 compliance reviews.

All but one driver had at least fifteen years experience driving motorcoaches and nearly all drivers indicated they worked full-time for their current employer. Half of the drivers reported that they usually went home every night after work and the other half said they alternated between going home and spending nights on the road. About half of the drivers worked for companies with ten or fewer motorcoaches, while the other half worked for larger companies. The drivers mostly worked for charter passenger carriers, although they were driving regularly scheduled routes to Atlantic City and had prior experience working for scheduled-service passenger carriers.

The themes that emerged from the focus groups are summarized below. Both enforcement personnel and drivers discussed working conditions, logistics of safety oversight, and safety concerns (see Table 1 listing).

Table 1.

List of safety concerns and challenges to oversight

Safety concerns and enforcement challenges	Enforcement personnel	Drivers
Enforcement workload	X
Retirements, budget constraints on replacing staff	X
Rapid growth of motorcoach industry	X
Obstacles to effective oversight	X	X
En route inspection prohibition	X
Motorcoach industry practices, including reincarnation and affiliated carriers	X	X
Safety audits: limitations	X
Required form (MCS-150) not updated or inaccurate	X
Fines may be too low	X
Motorcoach driver fatigue	X	X
Inadequate rest, no sleeper berth or facilities	X	X
Negative consequences if turn down trips due to fatigue		X
Falsified logbooks	X	X
Speeding	X	X
Other safety concerns	X	X
Varying state requirements	X
Small motorcoach carriers, new motorcoach carriers	X
Curbside service carriers	X	X

Workload of State Inspectors and Federal Safety Inspectors

State-based federal safety investigators are given targets for the number of compliance reviews to be completed by each investigator, typically about four reviews per month. There is some flexibility in meeting this target if a compliance review turns out to be particularly complicated and time-consuming; however, the investigator may be expected to complete more than four compliance reviews during the following month. Investigators said that they are sometimes not given adequate time to perform compliance reviews and that they have been pressured at least once or twice by their managers to complete a review before they were ready to move onto their next assignment.

Some federal investigators stated that they had a hard time keeping up with the rapid growth of the motorcoach industry, indicating that the FMCSA might only have one or two investigators assigned to a major metropolitan area with many passenger and trucking carriers. State and federal enforcement personnel said that there were not enough state inspectors and federal safety investigators to perform inspections and compliance reviews. The enforcement personnel indicated that many state and federal employee retirements are or will be occurring and that hiring at the state level is not keeping up with the number of departures partly because of budget cuts.

A total of 878 FMCSA and state personnel were qualified to perform compliance reviews for all 765,221 U.S. motor carriers, resulting in a ratio of 1.15 investigators per 1,000 motor carriers. A thorough compliance review is resource-intensive, taking 1 to 2 weeks or even longer when motor carriers have 10 or more vehicles, have records that are not well organized, or when an investigator encounters lack of cooperation.

Altogether, there were 10,273 federal and state personnel certified to conduct commercial motor vehicle inspections for the 4,830,972 commercial motor vehicles controlled by 765,221 motor carriers, resulting in a ratio of 2.13 inspectors per 1,000 commercial motor vehicles. Among these personnel, 2,327 are qualified to conduct motorcoach inspections for the 53,097 motorcoaches for which the FMCSA exercises oversight, but they also are responsible for performing inspections and oversight for other types of motor carriers.

Obstacles to Effective Safety Oversight

En route inspections while carrying passengers are prohibited by law unless federal or state officials suspect an imminent hazard or they observe a moving traffic violation. This constraint hampers oversight because drivers on particular routes or nighttime trips might be able to avoid inspections, especially those conducted at fixed sites that can be bypassed, such as rest stops. Another challenge is that inspections of carriers that do not use traditional terminals must take place on streets, which poses logistical problems. In addition, drivers in focus groups mentioned instances of companies communicating with each other about the locations of inspection personnel to avoid inspections.

State inspectors said that level II inspections (examination of a driver’s credentials and logbook and a walk-around inspection of the motorcoach) could be performed with passengers aboard the vehicle. Federal safety investigators pointed out the need to look after passengers if a driver is placed out of service. Passengers may have health problems and need adequate shelter and other facilities while waiting for a replacement motorcoach and driver.

Some motorcoach carriers were described as engaging in practices that make oversight difficult. Focus group participants reported that some drivers make false claims that a bus conducts intrastate operations (which are not subject to federal oversight) when the bus actually conducts interstate operations. Another oversight challenge involves detecting carriers that have been shut down due to safety violations, but have reopened under a different name (reincarnated carriers). Placing company ownership in a relative’s name are common practices for reincarnated carriers.

Drivers participating in focus groups also discussed reincarnated carriers. The drivers used the term “ghost buses” to refer to motorcoaches that were simply painted white or black with minimal transportation information on the outside of the vehicle, which allows carriers to easily paint over a company name and DOT number with new information.

State inspectors and federal safety investigators said that some motorcoach carriers hold multiple DOT numbers and are able to transfer their vehicles and drivers after receiving bad safety ratings. A frequently-repeated statement was that it was too easy to get DOT operating authority. The inspectors and investigators believed that holding multiple DOT numbers was more common among small low-cost carriers. Federal investigators also said that an existing carrier might decide to reincarnate as a new company if its insurer were to raise rates or refuse to provide insurance because of a less-than-satisfactory safety rating or multiple violations.

Investigators and inspectors think that some motorcoach carriers are legally independent entities but are not fully independent. Inspector and federal investigators also face challenges in dealing with groups of motorcoach carriers that have different names but are essentially managed by the same people. Vehicle identification numbers are currently not recorded by the FMCSA unless a passenger carrier has been inspected or has received a compliance review; inspectors would like to know these numbers sooner to help identify the carrier that actually is operating the vehicle.

Federal safety investigators and state inspectors reported difficulties contacting some owners or managers of motorcoach carriers to schedule a compliance review due to incorrect addresses or telephone numbers provided by the carriers. In addition, investigators are not always certain that they are dealing with the actual owner or manager of the intended company, especially when the investigators meet with company representatives in restaurants and other nontraditional places.

New entrant carrier safety audits, as currently conducted, were described as having limitations. The inspectors and investigators indicated that the time between receiving DOT operating authority and the first contact with the FMCSA was too long. During safety audits of new entrants, inspectors and investigators have consistently found violations. Although passenger carriers sign a certification statement on their registration forms, the investigators stated that the carriers often did not know the relevant regulatory requirements or misunderstood them. Some inspectors and investigators suggested that new entrants should be audited before operations are permitted to commence, but other enforcement personnel thought that a new entrant carrier needed sufficient experience before a safety audit would be useful. Safety audits are not as comprehensive as compliance reviews and may last only 4 to 6 hours. In addition, some investigators questioned the value of safety audits in their current form, saying that they sometimes consist of group educational sessions.

Enforcement personnel expressed concern that a key form used to keep track of passenger carriers is often submitted late and with inaccurate information. State inspectors and federal investigators were concerned that passenger carriers were not submitting the MCS-150 form on time; it is required to be resubmitted every two years. Further, the investigators said that MCS-150 form data, including contact information, numbers of vehicles, and numbers of drivers, were often inaccurate.

Some investigators think that fines for serious violations are so low that some motorcoach carriers may treat them as a cost of doing business. Investigators expressed concern that $2,000 fines would not deter motorcoach carriers from violating safety rules. The investigators thought that $10,000 fines would get the attention of the carriers.

Motorcoach Driver Fatigue

Drivers in focus groups said that getting adequate rest was important, but reported difficulties getting sufficient sleep during off-duty time as well as sometimes working longer hours than those allowed by hours-of-service rules.

The following quotes from drivers illustrate their concerns about rest:

“Rest is the number one thing that drivers need. We’re fatigued all day.”

“But that’s the key thing with our job is how can we get more rest, better rest.”

One hindrance to getting rest cited by charter drivers was difficulty in locating legal bus parking, particularly in large cities. Bus parking is sometimes located far from the passenger drop-off location, and, in some cases, drivers said they had to navigate through dense traffic to get to these areas. Many of the legal parking locations have no indoor areas or nearby restaurants, so that drivers have to remain with their vehicles. Remaining in vehicles also poses challenges to rest because motorcoaches do not have sleeper berths. Furthermore, some cities do not permit drivers to idle the bus, which results in being in a motorcoach without air-conditioning or heat.

Another problem that was mentioned was having responsibilities while in an off-duty status. Several participants said they would be blamed if anything happened to their motorcoaches, so they logged off-duty while parked but felt unable to leave the vehicles.

Another contributor to fatigue described by drivers was holding multiple jobs to earn adequate income. The multiple jobs sometimes were said to lead to hours-of-service violations from driving after on-duty limits had been reached.

Both driver focus groups agreed that the minimum working day length when doing chartered service was 12 hours. Work days exceeding 12 hours were described as common. One company was described as making their drivers work 20 hours but compensating them only for 5 hours of driving. Some young drivers were described as routinely working 15- to 17-hour days.

Charter and tour bus operators also encounter problems with adhering to hours-of-service regulations because their passengers sometimes expect to be taken out after reaching their destinations. They said that their front offices should educate the customers about the regulations, but this discussion often did not happen. Drivers said they were particularly vulnerable to pressures from passengers because tips are a substantial part of driver compensation.

When asked about dozing behind the wheel, drivers said this happened to all drivers, especially early in their careers. Overnight driving presents additional challenges for staying awake. Participants said that training in how to drive and stay alert at night is important. In instances when an overnight operation is planned, relief drivers may be used. This method uses two drivers that operate in shifts, theoretically allowing one driver to rest while the other drives. Drivers explained that sitting upright does not result in high quality rest or the relief driver may unable to sleep because of ambient noise.

Drivers said that they sometimes do not get the full required eight hours off-duty if their company is busy. They pointed out that having eight hours off from the time they punched out until the time that they punched back in meant they received little sleep after accounting for commuting time and personal time, perhaps as little as four to five hours of sleep.

Drivers related instances of being given schedules that necessitated violating hours-of-service rules to complete their trips. Drivers spoke of concerns that turning down jobs due to fatigue or being over legal driving hour limits might negatively impact their work status. The drivers said they do not get fired for turning down driving jobs; rather, they may get less work to do. A driver also pointed out that those drivers who are willing to go over work hour limits may get rewarded with more jobs, including more desirable trips.

Federal safety investigators participating in focus groups confirmed that some motorcoach drivers have few opportunities to take breaks while transporting passengers. State inspectors and federal safety investigators expressed concern about the extended work hours permitted by current hours-of-service rules for motorcoach drivers, pointing out that these work hours can lead to fatigue. In addition, the enforcement personnel agreed with the drivers that eight hours of off-duty time does not provide motorcoach drivers with adequate opportunities to sleep.

State inspectors described drivers as being adept at masking violations of hours-of-service regulations in logbooks. Inspectors reported reviewing logbooks in which drivers had filled out their logs ahead of time or had waited to fill out their logs until after they reached their destination. The two main categories of logbook violations are falsified logbook violations and general log violations (including not having a log or not keeping the log updated). To verify driving hours, state inspectors use toll and fuel receipts. However, because of the widespread use of toll transponders, such as E-ZPass, inspectors do not have immediate access to toll receipts. Also, inspectors may not have access to fuel receipts if a large motorcoach operator has its own fuel pump or has contracted with a supplier that does not provide date- and time-stamped fuel receipts. State inspectors and federal safety investigators supported the use of electronic onboard recorders to determine driving hours. Drivers discussed instances of missing or falsified logbooks, but did not comment on electronic onboard recorders.

Speeding

State inspectors and FMCSA investigators in the focus groups also identified speeding as a safety problem in the passenger carrier industry. The number of motorcoach speeding tickets does not reflect the extent of the speeding problem. According to focus group participants, some police officers are reluctant to pull over motorcoaches when they are speeding because of safety concerns about having a large vehicle with passengers on the side of a road. In addition, federal safety investigators indicated that speeding tickets are often not entered into the FMCSA database. Police officers who are not affiliated with the Motor Carrier Safety Assistance Program have no mechanism for uploading a speeding ticket to the FMCSA database.

Drivers in focus groups were questioned about their attitudes toward speeding and safe driving, and most drivers indicated that the decision about whether to exceed the speed limit depended on the environmental conditions and the traffic density. Most drivers thought that it was acceptable to drive 72 to 74 mph on interstate highways if the traffic was light. One driver said that his carrier strictly enforced a 70-mph limit.

Other Safety Concerns

State requirements for motorcoach safety vary. The inspectors and investigators said that motorcoach operators could legally shop for state registrations. For example, one state requires two inspections each year and confirmation of insurance coverage, so some motorcoaches that operate in that state are registered in states with less stringent oversight. Also, the requirements for obtaining a commercial driver’s license are weaker in some states than in others, so drivers may gravitate toward those states.

Smaller and newer motorcoach carriers were described as more likely to violate rules. FMCSA investigators thought that small carriers, particularly those with only one or two motorcoaches, and new carriers were more likely to violate rules, including those for drug testing and hours of service. The investigators believed that large motorcoach carriers could not afford to operate illegally. Vehicle maintenance was another concern raised by state inspectors.

Drivers, inspectors, and investigators thought that motorcoach carriers providing predominantly curbside service posed a greater hazard to safety than other motorcoach carriers. Drivers described some instances of vehicle maintenance problems among motorcoaches operated by carriers providing mostly curbside service, in addition to instances in which logbooks were not maintained or drivers did not have proper licenses. Inspector and investigators also spoke of experiences in which they encountered unqualified drivers and vehicles in unsafe condition that were operating under the auspices of motorcoach carriers providing curbside service. In addition, curbside motorcoach carriers were described by enforcement personnel as engaging in practices that hamper oversight more often than motorcoach carriers using traditional terminals.

DISCUSSION

Inspectors and investigators reported a heavy workload that strains their staffing resources. FMCSA data supported this contention, indicating a relatively small number of qualified staff to oversee the more than 765,000 motor carriers and more than 4.8 million commercial motor vehicles falling under federal jurisdiction. The estimated ratio of state inspectors to commercial motor vehicles understates their workload because state inspectors also are responsible for overseeing commercial vehicles that are operated by intrastate motor carriers.

Safety enforcement personnel also described many practices that hamper safety oversight, including difficulties ascertaining ownership and management and motorcoach company owners holding multiple DOT numbers. Inspectors and investigators said that electronic onboard recorders would make it easier to detect and deter hours-of-service driving violations.

Motorcoach driver fatigue was highlighted as a problem by both enforcement personnel and by drivers. Drivers spoke of fears that turning down driving jobs due to fatigue or concerns about exceeding hours-of-service limits might result in their getting less work. Sleep deprivation was cited as likely when drivers had no more than the minimum eight hours off-duty. Charter drivers spoke of great difficulties of getting rest.

Speeding was considered to be a problem by inspectors and investigators. Speeding violations were said to be underreported both because enforcement is inconsistent and because some violations do not get submitted to the FMCSA data portals. Drivers thought that some degree of speeding was acceptable when traffic was light.

Qualitative research can help establish the existence of safety problems and can provide in-depth information about possible causes of these problems and potential solutions that are not available through quantitative data analyses [Thompson, 2006]. As reported in the Results, both enforcement personnel and drivers made specific suggestions for improvements that warrant attention.

The major limitation of focus groups is that they do not necessarily represent the populations of interest and cannot indicate how prevalent a behavior or an attitude is within the population. Focus groups are small, can be influenced by a facilitator, and may be very different from the group from which they are drawn because they all are volunteers.

Findings from the driver focus groups regarding driver fatigue are consistent with those of focus groups conducted with motorcoach drivers during 1999 [Office of Motor Carriers, 1999]. Drivers participating in focus groups in Biloxi, Mississippi, San Diego, California, and Atlantic City, New Jersey during 1999 spoke of needing to hold multiple jobs, fears of refusing trips, very long workdays, being subject to charter/tour group pressures due to reliance on tips for income, not having enough time to rest (eight hours was described as inadequate), problems with parking and resting on layovers, and difficulties in sleeping on buses during layovers. This is due to buses having no sleeper berths and drivers having no other rest facilities available during layovers. The consistent findings between the two time periods suggest that these obstacles to rest have not been adequately addressed and strengthen the credibility of the 2011 focus group findings. The credibility also is bolstered by the geographic diversity and larger numbers of participants of the 1999 focus groups.

The concerns about speeding motorcoaches voiced by inspectors and investigators are supported by data on speeding tickets among motorcoach carriers [NTSB, 2011(a)]. Over a 2-year period, moving violations, which mostly consisted of speeding citations, averaged 5.7 per 100 vehicles among non-scheduled (primarily charter) motorcoach carriers and exceeded 20 per 100 vehicles among scheduled carriers.

Data extracted from FMCSA databases also supported the concern expressed by investigators and inspectors regarding MCS-150 data, which often were submitted late and with outdated or missing information on mileage [NTSB, 2011(a)]. Analyses also observed increased crash and safety violation rates among motorcoach carriers with 10 or fewer motorcoaches, 10 or fewer years in business, or providing curbside service, which is consistent with what inspectors and investigators had said about such motorcoach carriers. Outdated and missing MCS-150 data impair the ability of the FMCSA to identify the passenger carriers posing high safety risks so the agency can intervene.

One potential limitation of the findings from the focus groups of state inspectors and federal investigators was that observations by supervisory personnel may have inhibited complaints about workload. However, concerns about future problems with staffing resources did surface and subsequent interviews with FMCSA investigators also provided details about difficulties in managing workloads.

Another consideration when interpreting findings is that the participating drivers largely worked for charter motorcoach carriers. Some of the safety concerns identified by drivers, such as obtaining legal parking so as to allow rest, likely applied more to charter operations than to scheduled service.

The FMCSA is aware of obstacles to effective oversight and finalized a rule, effective in 2014, to standardize the state requirements to obtain a commercial driver’s license. This rule will not apply retroactively to drivers already holding commercial licenses. In addition, the FMCSA is working with Congress on language that would permit en route inspections and require safety audits prior to beginning operations [Ferro, 2011(b)]. Based on focus group comments, state inspectors supported en route inspections and federal investigators supported them if proper facilities were available for passengers. In 2012, FMCSA published a final rule that defined both reincarnated carriers and carriers affiliated with entities that either had been shut down or had received legal consequences from violating safety rules [FMCSA, 2012]. This new rule targets carriers trying to evade legal consequences of safety violations by reincarnating as a new carrier or by transferring assets to affiliated carriers.

Further research is needed to quantify the prevalence of the safety concerns expressed by inspectors, investigators, and drivers, including the obstacles to oversight. Some of the safety challenges, such as inadequate rest, already have been abundantly documented, so that the next logical step is evaluation of the effectiveness of countermeasures that have been proposed, such as fatigue management systems. Such systems could include methods to protect drivers from adverse consequences of turning down work due to fatigue. Research methods should include a combination of surveys, observational data (such as the frequency of speeding by motorcoaches), and reviews of workloads and schedules. To obtain a representative sample of drivers, personal interviews likely would be needed. A combination of online questionnaires and telephone interviews could be used to survey safety oversight professionals.

CONCLUSION

Focus groups of state inspectors and federal investigators reported encountering multiple obstacles to performing effective oversight of safety in the motorcoach industry. The obstacles named by enforcement personnel included heavy workloads, which was confirmed by FMCSA staffing data, and practices by some companies in the motorcoach industry, including incorrect, missing, or out-of-date information on mandatory forms. Enforcement personnel also expressed concern about speeding motorcoaches. Both motorcoach drivers and enforcement personnel said that driver fatigue was a continuing problem, with drivers telling of difficulties obtaining sufficient rest and pressures that they had felt from at least some employers to drive while fatigued or to exceed hours-of-service limits. Additional research is needed to quantify the prevalence of these safety problems and to determine effective countermeasures. Given the relatively small numbers of federal and state professionals performing safety oversight for motor carriers, increasing their effectiveness is an important subject for research.