The Doctor is Out…Driving While Medically Unqualified

NOTE: This article is part of a series investigating the definition of “impaired driving” as it occurs in society, traffic safety and driver safety professional networks.

The Federal Motor Carrier Safety Administration (FMCSA), has enforced regulations to prevent drivers from operating Commercial Motor Vehicles while impaired in a number of ways.  One area that the organization has been working very hard to enhance is keeping medically unqualified drivers from behind the wheel.
Traditionally, this has been done (mainly) by requiring a biennial (once every two years) or more frequent (if a notable health/medical condition exists) visit to a certified medical doctor for a physical exam.  To provide an additional set of elements to the “safety net” there are substance abuse testing protocols completed by the employer, and roadside inspections to spot driver irregularities during the course of the year.
In theory, this system of checks and balances should capture the majority of exceptions and assure a consistent pool of qualified drivers.  However, a recent report published in November 2012 by the Government Accountability Office (GAO) “…found that these controls were vulnerable to abuse or manipulation.”  This report describes key controls designed to prevent medically unfit or impaired commercial drivers from operating commercial vehicles, and examples of commercial drivers with potentially disqualifying impairments related to epilepsy, drugs, or alcohol who managed to drive despite the existence of the key controls.
It also points out how some of the worst issues will be addressed by MAP-21 (link to summary here)
The study that led to the report was conducted in the following manner:
“To identify key controls, GAO reviewed FMCSA policies and regulations, and interviewed officials. Cases were identified on the basis of FMCSA roadside-inspection data, DOT’s Commercial Driver License Information System (CDLIS), a national database of all commercial drivers, and SSA disability insurance files. From this analysis, GAO identified commercial drivers who were driving with an epilepsy diagnosis. GAO also randomly selected 100 individuals to determine whether the driver was receiving SSA disability benefits when the state issued or renewed the driver’s CDL.” [underline added for emphasis]
Notable findings from GAO report summary:
“Matching CDL holders with Social Security Administration (SSA) disability files produced 204 commercial drivers who drove a commercial vehicle as recently as 2011 despite having epilepsy, a disqualifying medical condition characterized by sudden seizures and unconsciousness. Thirty-one of these drivers were involved in accidents, demonstrating the threat to public safety posed by medically impaired drivers. GAO also identified 23 cases where state licensing agencies issued or renewed CDLs for drivers after they were, according to SSA records, diagnosed with epilepsy or had drug or alcohol dependence noted, which could also disqualify them from driving under DOT regulations.  However, because DOT did not require state licensing agencies to maintain drivers’ medical certifications at the time of GAO’s review, it is unlikely that states knew of the drivers’ conditions. In fact, they were unable to provide medical certifications for any of the 23 individuals. States are now required to electronically store medical certificates for new and renewing CDL applicants and will be required to electronically maintain this information for all CDL holders by January 2014. Doing so could help prevent ineligible drivers from obtaining or renewing CDLs in the future.”

Here is a link to the full GAO Report – http://www.gao.gov/assets/660/650388.pdf

Bottom-line is that drivers with “serious medical conditions” can still meet FMCSA fitness requirements because “…medical determinations rely on subjective factors and patient self-reporting, [therefore] it is not possible to systematically determine whether these drivers had disqualifying medical conditions.”

This will require changes to how medical qualifications are completed and recorded.  The GAO report summarizes several key changes that are on the way or will be here very soon:

  • “As of January 30, 2012, individuals renewing or applying for a CDL must submit a copy of their current medical certificate to their state licensing agency, making state licensing agencies responsible for ensuring that drivers have current medical certificates on file.
  • “In April 2012, FMCSA published a final rule establishing a National Registry of Certified Medical Examiners.
  • “The 2012 final rule provides requirements for all healthcare professionals responsible for issuing medical certificates for interstate truck and bus drivers to complete a training course on the Federal physical qualifications rules and to pass an examination to assess the examiners ability to apply the rules, and advisory criteria in a consistent manner when making the determination whether a driver meets the qualification standards.
  • “FMCSA has announced its plans to initiate a new rulemaking that would enable the agency to require medical examiners on the National Registry to submit to the agency the medical certificate information on each individual who applies for a medical certificate. The agency would then have the ability to transmit to the state driver licensing agency the medical certificate. This process will significantly decrease the likelihood of drivers being able to falsify medical certificates.
  • “Specifically, the law [MAP-21] requires DOT to establish, operate, and maintain a national clearinghouse with records relating to the results of positive drug and alcohol tests of commercial drivers or instances of refused tests. Once the clearinghouse has been established, employers must request and review their CDL drivers’ records from the clearinghouse annually. The MAP-21 Act also requires DOT to develop a method to electronically notify an employer of each additional positive test result or other noncompliance.
  • “Specifically, the law requires DOT to establish, operate, and maintain a national clearinghouse with records relating to the results of positive drug and alcohol tests of commercial drivers or instances of refused tests. Once the clearinghouse has been established, employers must request and review their CDL drivers’ records from the clearinghouse annually. The MAP-21 Act also requires DOT to develop a method to electronically notify an employer of each additional positive test result or other noncompliance.

Summary

Drivers have a responsibility to be safe while behind the wheel.  Employers (motor carriers) have a responsibility to properly qualify and monitor the ongoing qualification status of those who drive for them.

Driver impairment, whether from drugs, alcohol, fatigue or medical conditions is foreseeable (through testing and qualification programs) and preventable so long as everyone does their part. 

To find out in hindsight that heavy vehicle crashes occurred where drivers were also receiving Social Security Administration disability benefits (and were not medically qualified to drive) is tragic if it were a mistake and a travesty if it occurred knowingly but was ignored.

SafetyFirst specializes in driver safety programs for both regulated and non-regulated fleets.  We have clients throughout the USA and Canada utilizing a wide range of proprietary database systems (for compliance with company or Federal policies affecting drivers, crash reporting, training documentation, qualification reminders, etc.), hotline coaching programs, and varied training/educational approaches.  We also consult with larger fleets and insurance carriers on developing strategies to assure effective implementation of telematics programs and other high capital projects where safety results depend on data analysis and translation to behavior safety outputs to realize and capture measurable gains.

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2013 Ten-Minute Training Topics Calendar

Driver education takes many forms in many companies.  A variety of methods used frequently helps assure that drivers receive the message that’s being sent by the management team. 

We recognize that there are many really wonderful driver “training” programs out on the market, but many approach the educational program by making the driver sit in a class or in front of a computer for more than an hour at a time.  This cuts into their productivity and may become “mind-numbing” after the first 12 to 15 minutes – especially if they’ve already been through this topic in the recent past.

We’ve built a “reminder” or “refresher” program to supplement our driver coaching program.  It’s designed to remind drivers of what they should already know and be practicing on a regular basis.  Also, it’s designed to do this in a very short time span — typically a ten minute tailgate talk or similar approach (i.e. self-study; coaching sessions, etc.)

Each year we publish a new calendar for our popular Ten-Minute Training Topic series.  These driver training packages are included in our very popular “driver safety hotline” program that some firms continue to call a “how’s my driving” program.

The monthly training package for drivers includes:

  1. A driver handout with statistics about the issue, a description of why they should care and tips to consider about their driving habits.
  2. A manager’s supplement report that includes current news stories about that month’s topic, links to web sites with additional resources and a discussion of how the month’s topic relates to company policies and procedures.
  3. A pair of power point presentations — one for easy copying/printing and one with full graphics and images to help drivers relate to the message at hand.

Occasionally we’ve tested other elements — word searches, handbooks and quizzes, or other training delivery formats.  All in all, our 4,000 clients have agreed that “keep it simple” has worked best and they really enjoy working with our materials.  It’s easier than dealing with bandwidth/kiosk issues for many clients, and yet we’re also wrapping up the testing of an online, interactive training program, too (featuring four-minute length reminder videos followed by a very short quiz).

The very first Ten-Minute Training Topic was published way back in May of 2003.  We’ve been publishing a new or re-written topic each month since then — building an archive of over 80+ topics at our customer website.

During 2013, we will be publishing several interesting topics based on client requests and feedback:

  • January – “Winter Season Driving“
  • February – “Clicking the Last 16%“
  • March – “Driving Too Fast for Conditions“
  • April – “Distracted Driving“ (April is National Distracted Driving Awareness Month)
  • May – “Aggressive Driving“
  • June – “Lane Change Collisions“
  • July – “Pedestrian Collisions“
  • August – “Sharing the Road with School Buses“
  • September – “Wildlife Collisons“
  • October – “Grade Crossing Collisions“
  • November – “Drowsy Driving“ (November is Drowsy Driving Awareness Month)
  • December – “Parking Lot Collsions“

In the past, we’ve published topics on many other pertinent and timely issues related to driver safety.  Current clients may substitute older issues for current issues by going to our site and downloading the older topics as they see fit.

In addition to providing these topics as a benefit of participating in the “driver safety hotline” program, some clients subscribe to the training topics as a stand alone program — separate from the hotline program. 

We base most of the topics on suggestions we receive from current clients and their insurance carrier support teams.  If you have a topic of interest, please let us know and we will see what we can do for you.

If you have an interest in receiving a courtesy copy of one of our monthly programs, let me know!  Additionally, if you’d like to see a preview of our supervisory training programs, or our interactive training programs, we can arrange a web cast.

“One for the road” – Alcohol Impairment

NOTE: This article is part of a series investigating the definition of “impaired driving” as it occurs in society, traffic safety and driver safety professional networks.

Of the most common ways a driver can impair their own ability to drive is to choose to consume alcohol before getting behind the wheel.  In fact, this is a world-wide phenomenon.  According to the Global Road Safety Partnership (Link),

“In high-income countries about 20% of fatally injured drivers have excess alcohol in their blood, while in some low- and middle-income countries these figures may be up to 69%.” (from “Drinking and Driving: an international good practice manual”)

Here in the USA, we have an annual fatality rate of roughly 32% from drinking and driving.  Granted this is much improved since the 1970’s when it was as high as 50% (and even 40% as recently as 2003 per National Highway Traffic Safety Administration – NHTSA) These reductions were due largely to:

  • Changes in laws
  • Aggressive enforcement
  • Community involvement
  • Public awareness
  • Educational programs targeting the youth of our country

Unfortunately, as a nation, we seem to have hit a plateau over the past decade where further declines have been halted.

It’s a sobering reality to contemplate that we continue to record an alcohol fueled traffic fatality every 51 minutes despite our best efforts to curb these behaviors.

Patterns of Deep Seated Behavior?

In reviewing recent research and statistics on alcohol and driving, we find that out of 1.5 million arrests of impaired drivers each year, about a full third are repeat offenders.  Additionally, the Insurance Information Institute issued an update in September showing that first-time offenders are very likely to have driven drunk before their first arrest.  Further, studies suggest that on average, one arrest is made for every 88 instances of driving over the legal limit; therefore we have to wonder if the average first-timer has driven drunk 80+ times before getting caught. (Link to source)

The Insurance Institute of Highway Safety (IIHS) reminds us that while alcohol related crashes happen at all hours, they peak at night and are more common on weekends than on weekdays.  This suggests a link between parties and crashing on the way home, but it’s not the whole picture.  Alcohol still plays a role at all other times on the calendar and clock.

When we combine the fact that most “drunk drivers” have a pattern of drinking and driving, and that while most crash on weekends, the choice to get behind the wheel while buzzed is primarily a judgment call, not one of convenience, conscience or mere location (i.e. the behavior of the weekend partier carries that judgment to the business vehicle during the week even if the alcohol is left behind).

Latest Trending – Binge Drinking

Centers for Disease Control (CDC) suggests that most alcohol-impaired drivers binge drink.  Binge drinking is a behavior where large quantities of alcohol are consumed in a short period of time with the purpose of becoming drunk as quickly as possible.

CDC further indicates that most people who binge drink are not alcohol dependent or alcoholics in general.  They may be ordinary people who want to escape their normal routine, “have fun” or simply “get blitzed.”  Consider the following statistics from a January 2012 report:

  • More than half of the alcohol adults drink is consumed while binge drinking.
  • Age group with most binge drinkers: 18-34 years
  • Age group that binge drinks most often: 65+ years
  • Income group with most binge drinkers: more than $75,000
  • Income group that binge drinks the most often and drinks most per binge: less than $25,000

Binge drinking may be a sign that:  the person is unable to cope with other stressors in their life, it could affect more than just driving (i.e. job performance, workers comp injuries, customer complaints, etc.).  All in all, this may also signal a need for the employee to take advantage of an Employee Assistance Program if one is available to them.

Wrong Way Crashes and Links to Alcohol Impairment

On December 11, 2012, an Associated Press article was released which stated:

“Hundreds of people are killed each a year when drivers turn the wrong-way into the face of oncoming traffic on high-speed highways, and a majority of the crashes involves drivers with blood alcohol levels more than twice the legal limit, a federal accident researcher said Tuesday.

“The board’s study analyzed data from 1,566 crashes from 2004 to 2009, as well as nine wrong way collisions NTSB directly investigated. In 59 percent of the accidents, wrong-way drivers had blood alcohol levels more than twice the legal limit, researchers said. In another 10 percent of the crashes, drivers had alcohol levels between .08 and .14. The limit in most instances is .08.”

“Often the chain of events begins with drivers entering an exit ramp in the wrong direction, making a U-turn on the mainline of a highway or using an emergency turnaround through a median, investigators said.”

“To address the problem, the board is considering recommending all states require convicted first-time drunken-driving offenders use ignition interlock devices that test their breath for alcohol concentration in order to drive. The devices, mounted on the vehicle’s dashboard, prevent the engine from starting if the driver’s alcohol concentration is too high. Seventeen states already have such a requirement.”

Legal “Profiling”

In California, driver abstracts (aka motor vehicle reports or driver violation histories) that get issued to insurers automatically include any Driving Under the Influence (DUI) violations from the past ten years.  This was done to ensure that a past recipient of a DUI conviction would not qualify for a “good driver discount.”  Even though other types of violations can “fall off” or be “grandfathered”, DUIs are a much more indelible mark on a driver’s record.

From an employer’s perspective, there is a risk in voluntarily handing keys to a driver who has previously been convicted because of “negligent supervision”, “negligent entrustment” and similar legal theories.  Of course, employers might provide keys to company equipment if required by court order, if an “interlock ignition” system is installed or if any license restrictions allow commuting to the worksite (and don’t require the transport of passengers or other riders).

Commercial Drivers and Alcohol

The Federal Motor Carrier Safety Administration (FMCSA) has published regulations affecting drivers who hold a Commercial Drivers License (CDL).  Initially, a substance abuse testing program was launched in 1989 to cover certain controlled substances, but expanded in 1994 to include alcohol testing requirements.

The testing, along with enforcement initiatives and educational factors have made an impact.  In 1990, 2.8% of all drivers of heavy trucks who died in crashes had a BAC of 0.08 or greater.  By 2010, that percentage had dropped to 1.8%.  This compares favorably to drivers of passenger cars:  1990 = 28.9% and 2010 = 23.2% (these percentages are also similar to drivers of light-duty trucks).  This information is from the “Large Truck and Bus Crash Facts 2010” (FMCSA-RRA-12-023, August 2012)

Here are some highlights from the FMCSA’s own website:  http://www.fmcsa.dot.gov/rules-regulations/topics/drug/engtesting.htm

  1. Who do these rules apply to (besides CDL holders, specifically)?
    1. Examples of drivers and employers that are subject to these rules are (the following does not represent a complete listing):
      1. Anyone who owns or leases commercial motor vehicles
      2. Anyone who assigns drivers to operate commercial motor vehicles
      3. Federal, State, and local governments
      4. For-Hire Motor Carriers
      5. Private Motor Carriers
      6. Civic Organizations (Disabled Veteran Transport, Boy/Girl Scouts, etc.)
      7. Churches
  2. WHAT ALCOHOL USE IS PROHIBITED?
    1. Alcohol is a legal substance; therefore, the rules define specific prohibited alcohol-related conduct. Performance of safety-sensitive functions is prohibited:
      1. While using alcohol.
      2. While having a breath alcohol concentration of 0.04 percent or greater as indicated by an alcohol breath test.
      3. Within four hours after using alcohol.
    2. In addition, refusing to submit to an alcohol test or using alcohol within eight hours after an accident or until tested (for drivers required to be tested) are prohibited.
  3. WHAT ALCOHOL TESTS ARE REQUIRED?
    1. The following alcohol tests are required:
      1. Post-accident – conducted after accidents on drivers whose performance could have contributed to the accident (as determined by a citation for a moving traffic violation) and for all fatal accidents even if the driver is not cited for a moving traffic violation.
      2. Reasonable suspicion – conducted when a trained supervisor or company official observes behavior or appearance that is characteristic of alcohol misuse.
      3. Random – conducted on a random unannounced basis just before, during, or just after performance of safety-sensitive functions.
      4. Return-to-duty and follow-up – conducted when an individual who has violated the prohibited alcohol conduct standards returns to performing safety-sensitive duties. Follow-up tests are unannounced. At least 6 tests must be conducted in the first 12 months after a driver returns to duty. Follow-up testing may be extended for up to 60 months following return to duty.

SUMMARY

The problem of drinking and driving is a significant contributor to road deaths despite improving results over the past four decades.  While we never make light of the emerging threat of electronic distractions, there remains a significant difference between these two conditions:

  • Distracted drivers can drive well, but choose to ignore their duty
  • Alcohol-impaired drivers can’t drive well because they’re physically or “medically” unfit for the duty, but choose to drive anyway

In reality, neither should get behind the wheel if they’re going to impair themselves, and yet both boldly choose to endanger themselves and other drivers despite the warnings and pleadings of safety professionals and the public at large.

As a nation, we’ve called for a complete ban on hand-held cell conversations and texting-while-driving, but it feels like we haven’t (recently or as loudly) called for true zero-tolerance of drinking and driving with the same fervor.  

As an employer, consider a timely review of your policies covering drinking and driving. Perhaps its time to remind your employees of your expectations — after all, you’re also expressing genuine concern for their wellness and safety by curbing the notion that buzzed driving is somehow OK — it isn’t.

Within your own family, talk with teens and seniors, moms and dads — everyone who drives should be reminded that the choices we make have direct and significant consequences.  Calling a cab (or mom and dad) for a ride is a far better choice than hoping for the best, or feeling lucky.

Join the conversation at our Linked In discussion site or our facebook page.

SafetyFirst provides automated MVR checking/ranking services, fleet policy consulting, access to tailored telematics that actually “fit” your company and it’s unique needs.  Validated best in class for reducing collision claims among insurance carriers and world-class safety organizations in every SIC division.
 

Severe Obesity as a form of Impaired Driving?

NOTE: This article is part of a series investigating the definition of “impaired driving” as it occurs in society, traffic safety and driver safety professional networks.

A recent study searched for links between a driver’s Body Mass Index (BMI – a key measure to determine clinical obesity in people) and their crash rate.  The findings were preliminarily published in “ScienceNOW” (Link) on October 26th of this year.

The study focused on commercial drivers who typically deal with long hours, a sedentary lifestyle punctuated with brief intervals of physical activity and a lot of stressful situations over scheduling and traffic.  Also linked to these drivers are very irregular sleep patterns and typically a deficient amount of quality sleep.

Due to the amount of miles driven, commercial operators are predisposed to crashes and many of these are already linked to fatigue, drowsiness and medical issues.

Two years ago, the research team focused on driver height and weight as factors in crash occurrence.  The height and weight can be used to derive BMI:  BMI greater than 25 is considered “overweight”; greater than 30 is considered “obese”; and greater than 35 has been labeled “severely obese” by the study.

During their first 2 years on the road, drivers in the study group with a BMI higher than 35 (“severely obese”) were 43% to 55% more likely to crash than were drivers with a normal BMI, the team reports in the November issue of Accident Analysis & Prevention (Link).

The specific causal reasons have not been clearly documented and speculation is focused on obstructive sleep apnea (OSA), limited agility and fatigue associated with other medical factors other than OSA.

There are a range of medical issues that can cause a driver to become disqualified as a “Commercial Motor Vehicle Operator” under the Federal Motor Carrier Safety Regulations (FMCSRs).   Presently, a person with severe obesity might be at elevated risk of developing some of the conditions that could lead to disqualification, but the simple weight or BMI of a person has no direct connection to qualification as expressed in Part 391.41. 

Additionally, the link between crashes and supposed causes (in this case BMI over 35) does not constitute grounds for disqualification; however, it may be a warning sign that drivers, their employers, health providers and EAP program administrators should be working in concert to manage a BMI greater than 35 downward to a lower number where feasible (if not for crash reductions, then for the many well documented health benefits of maintaining a lower BMI). 

Driving a commercial vehicle for a living presents special challenges, but comes with added responsibilities, too.  It’s a difficult challenge for many drivers to get the help and relief they need to make consistent lifestyle changes.  If they could, they’d benefit directly and if the study mentioned above is representative of all drivers, then we’d see potentially lower crash rates, too.

Stay tuned for more articles examining the issue of “impaired driving” in its many forms.

SafetyFirst provides a range of driver safety programs to more than 3,800 active fleet clients and through a network of more than 75 insurance providers. 

Our programs range from MVRs to hotline reports — all designed to identify specific drivers with specific habits that should be “brought to the front of the line” to get help from their supervisors immediately.  This compassionate intervention in a timely fashion has been documented to reduce crash rates by 20 to 30% without expensive telematics devices that cost 100 times more per vehicle per month than our proprietary program.

However, we also embrace technology and have helped our clients better leverage their telematics investments.  In one case, we worked with a client to design and implement an enhanced coaching program that reduced the actual behavior that triggers telematic speed alertsThey dropped the alerts by 600% in the first year.

Impaired Driving in its many forms…

Until very recently, “Impaired Driving” was often interpreted as “Drunk Driving” or “driving under the influence of alcohol”.  I think it means a lot more than that and the National Institutes of Health (NIH) agrees. According to their website, they state:

“Impaired driving is dangerous and is the cause of more than half of all car crashes. It means operating a motor vehicle while: affected by alcohol; affected by illegal or legal drugs; too sleepy; distracted, such as using a cell phone or texting; having a medical condition which affects your driving.”

Where I disagree is their inclusion of “distracted driving.”  I think they chose to include it since the driver could be suffering from “inattention blindness” where their mind is so hopelessly preoccupied that they don’t recognize traffic signals and conditions properly.

I feel that there is a fundamental difference between distracted driving and impaired driving:

  • Distracted drivers are fully capable of driving well, but choose to ignore their duty to drive properly
  • Truly impaired drivers incapable of driving well because they’re tired, drugged, drunk or ill, but choose to drive anyway

In reality, neither should get behind the wheel, and both choose to endanger themselves and other drivers. 

Driving presents a unique challenge each time we get behind the wheel.  To be ready to handle the dynamic situations we’ll encounter when driving, we ought to be in top condition. 

Our bodies and minds can be affected by a wide range of factors: being tired; being physically ill; suffering from allergies; coping with chronic physical conditions; taking over the counter medications; drinking alcohol; smoking marijuana; taking prescription medications or abusing illicit drugs.

These factors most commonly contribute to collisions by impairing the driver’s judgment and/or reaction times. 

The universal precaution for impaired driving is to avoid becoming impaired in the first place.  This may translate into getting enough sleep and eating a proper diet to avoid fatigue, getting a flu shot annually to lessen the impact of symptoms, avoiding the intake of alcohol or other “recreational” drugs such as marijuana, or asking extra questions of the doctor and pharmacist when dealing with prescribed medications for illnesses or chronic conditions. 

For regulated drivers (i.e. those subject to FMCSRs), physical or medical qualification is an important aspect of becoming and remaining qualified to drive.  For most regulated drivers, this translates to visiting the doctor for a physical once every two years (or more frequently depending on your condition and the doctor’s findings).  In some cases, a failure to meet the minimum requirements (or any discovered fraud surrounding these issues) could lead to disqualification.  On November 30, 2012, the FMCSA issued a press release (Link) stating that it had ordered a driver to cease driving “due to his failure to exercise an appropriate duty of care to the motoring public regarding his medical conditions.”

The FMCSA placed the driver out of service “…after agency investigators found serious safety concerns surrounding his medical condition and qualifications under his commercial driver’s license (CDL) issued by the State of Georgia.” 

Specifically, “…Investigators discovered that Felton failed to disclose to a medical examiner his disqualifying medical conditions, including his medications prescribed in treating those conditions.”

The news release concludes with this message;

“This case sends a clear message that we will use every tool at our disposal to identify and remove from our roads unsafe operators,” said FMCSA Administrator Anne S. Ferro. “Our agency is committed to raising the bar for commercial vehicle and driver safety.”

This month’s Ten-Minute Training Topic is on Impaired Driving and includes a driver handout, manager’s supplemental report, and a pair of slideshows to facilitate educational opportunities with drivers.  This is distributed to all of the supervisors who receive monthly summary reporting through our Safety Hotline program — in place at more than 3,800 active clients and covering about a quarter million commercial vehicles.

We’ll also be looking at individual forms of impairment more closely through our blog site over the next several weeks.