(Mostly) Everything Relates to Fatigue

By Margaret Edwards, Manager of Government Affairs, Commercial Vehicle Safety Alliance
Originally published in the 2025 Third Quarter Guardian, page 51

• Surface transportation reauthorization may sound legislative — but its real impact is operational.
• From personal conveyance limits to ELD exemptions and CMV parking shortages, fatigue is the common denominator shaping risk exposure.
• This article connects congressional policy debates directly to crash prevention, enforcement strategy and carrier liability.
• Because in Washington’s regulatory decisions today lies the fatigue risk your operation will manage tomorrow.

Estimated Reading Ttime: 4–5 minutes

The U.S. Congress holds committee hearings to explore topics and hear from stakeholders as part of its work to prepare for upcoming surface transportation reauthorization legislation. So far this year, the House Transportation and Infrastructure Committee has held 13 hearings, and two covered topics such as roadway safety and trucking. The U.S. Senate’s Committee on Commerce, Science and Transportation has held two hearings focused on commercial motor vehicles (CMVs), with one addressing cargo theft and the other looking at issues facing the truck and bus industries. And CVSA uses each hearing as an opportunity to educate members of the U.S. Senate and House of Representatives on the Alliance’s priorities for surface transportation reauthorization.

One opportunity to educate members of Congress about the Alliance’s priorities comes in the form of submitting statements for the record. The statements for the record submitted by CVSA must connect the topics discussed at the hearing to the priorities important to roadside inspectors.

For example, when the House Transportation and Infrastructure Committee held a hearing on trucking in April, CVSA submitted comments that addressed the topics discussed in the hearing, such as solutions to challenges facing the industry, while also using the opportunity to share information about the Alliance’s reauthorization priorities.

While connecting the Alliance’s reauthorization priorities to the hearing topics, one thought that came to mind when drafting the comments was to connect multiple reauthorization priorities back to the issues surrounding fatigued driving and solutions to mitigate fatigue, which were covered in that hearing. 

Fatigued driving is near the front of my mind because CVSA added a policy statement on fatigued driving to the CVSA Standing Policy Guide in September 2024. The policy statement supports a requirement that motor carriers implement a fatigue management program, and the discussion focused on how driver fatigue is a significant contributor to CMV crashes and poses a risk to road safety. The policy position and discussion highlighted the Alliance’s focus on mitigating fatigue-related driving to enhance safety on our roadways.

Mitigation strategies for fatigue are woven throughout CVSA’s reauthorization priorities. One such strategy relates to personal conveyance. CVSA supports capping the time drivers can use personal conveyance. Currently, drivers can misuse and abuse personal conveyance to drive for an unlimited amount of time. Using personal conveyance to extend driving time increases the risk of fatigue and can endanger other road users. Placing a limit on the time a driver can use personal conveyance is a strategy to mitigate fatigued driving that should be implemented.

Another reauthorization issue related to fatigue is CVSA’s opposition to legislative exemptions. Exemptions granted by legislation do not always include safety considerations and are difficult to revoke once established. Because industry can pursue exemptions through an administrative process, CVSA opposes the inclusion of exemptions from federal safety regulations in legislation. The connection between legislative exemptions and fatigue arises because they often exempt drivers from the hours-of-service (HOS) rules. The HOS rules exist to prevent and manage driver fatigue by establishing a framework that, if followed, allows drivers to get the rest necessary to operate their vehicles safely.

Additionally, Congress may also grant legislative exemptions from the electronic logging device (ELD) mandate. For example, livestock and insect haulers are permanently exempted from the ELD mandate. CVSA opposes any effort to exempt a portion of the motor carrier industry from the requirements. ELDs assist in the effective enforcement of HOS regulations. ELDs are a valuable tool for enforcing hours-of-service regulations, making it easier for inspectors to identify violations and remove unsafe, noncompliant carriers and drivers from roadways, while saving time for both enforcement and industry.

A final reauthorization priority that aims to address the issue of driver fatigue is promoting investments that address the nation’s CMV parking shortage. The availability of adequate parking facilities, strategically placed throughout the U.S., is a critical CMV safety issue. Without adequate parking facilities, drivers are faced with driving fatigued and/or over the allowable time in the HOS rules. Increasing parking availability for CMV drivers would ensure they have safe places to rest, as required by safety regulations. By supporting investments in expanding CMV parking, these critical situations caused by fatigue can be alleviated 

In the upcoming surface transportation reauthorization legislation, Congress and the administration have the opportunity to prioritize solutions that mitigate fatigued driving. CVSA will continue to include these solutions that address fatigued driving and improve safety as part of its advocacy on the Alliance’s priorities ahead of the upcoming surface transportation reauthorization priorities.