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Safety Recommendation Details

Safety Recommendation H-12-029
Details
Synopsis: On Tuesday, May 31, 2011, approximately 4:55 a.m. eastern daylight time, a 2000 Setra 59-passenger motorcoach operated by Sky Express, Inc., occupied by a driver and 58 passengers, was traveling north on Interstate 95 in the right lane of the three northbound lanes near Doswell, Virginia. The motorcoach drifted from the highway to the right, struck a cable barrier, rotated counterclockwise around its vertical axis, overturned to the right, and rolled onto its roof. As a result of the accident, 4 of the 58 passengers were killed, 14 received serious injuries, and 35 received minor injuries. The driver sustained minor injuries and refused medical treatment. The National Transportation Safety Board (NTSB) determines that the probable cause of this accident was the failure of the motorcoach driver to maintain control of the vehicle due to his falling asleep while driving because of fatigue resulting from acute sleep loss, poor sleep quality, and circadian disruption and the failure of Sky Express, Inc., management to follow adequate safety practices and to exercise safety oversight of the driver. Contributing to the accident was the Federal Motor Carrier Safety Administration's lack of adequate oversight of Sky Express, Inc., which allowed the company to continue operations despite known safety issues. Contributing to the fatalities and the severity of the injuries was the lack of a comprehensive occupant protection system, including systems for providing passenger restraint and for ensuring sufficient roof strength.
Recommendation: TO THE FEDERAL MOTOR CARRIER SAFETY ADMINISTRATION: Establish an ongoing program to monitor, evaluate, report on, and continuously improve fatigue management programs implemented by motor carriers to identify, mitigate, and continuously reduce fatigue-related risks for drivers. (This safety recommendation supersedes Safety Recommendation H-08-14)
Original recommendation transmittal letter: PDF
Overall Status: Closed - Unacceptable Action
Mode: Highway
Location: Doswell, VA, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: HWY11MH010
Accident Reports: Motorcoach Roadway Departure and Overturn on Interstate 95
Report #: HAR-12-02
Accident Date: 5/31/2011
Issue Date: 8/16/2012
Date Closed: 6/3/2019
Addressee(s) and Addressee Status: FMCSA (Closed - Unacceptable Action)
Keyword(s):

Safety Recommendation History
From: NTSB
To: FMCSA
Date: 6/3/2019
Response: We note that you have continued to promote voluntary motor carrier adoption of the North American Fatigue Management Program and fatigue-related research; however, the intent of this recommendation was for you to develop a program at the motor-carrier level to monitor, evaluate, report on, and continuously improve any fatigue management programs motor carriers implement for their drivers in the absence of a federal mandate for such programs. As we noted in our response (copy enclosed) to your February 6, 2019, “Notice of application for exemption; request for comments,” your lack of a mechanism to evaluate and track fatigue risk management systems proposed by carriers makes you unable to oversee the use of such systems as an alternative means of compliance. This type of oversight has already been implemented in the aviation mode and should be within reach for motor carrier regulators. We are disappointed that you decided not to develop a program that would allow you to measure the effectiveness of the fatigue management programs you encourage motor carriers to have. Because you intend to take no further action to establish the recommended program, Safety Recommendation H-12-29 is classified CLOSED--UNACCEPTABLE ACTION.

From: NTSB
To: FMCSA
Date: 3/6/2019
Response: The National Transportation Safety Board (NTSB) has reviewed the Federal Motor Carrier Safety Administration (FMCSA) “Notice of application for exemption; request for comments,” which was published in 84 Federal Register 2304, on February 6, 2019. The request was made by several associations on behalf of drivers who transport livestock, insects, and aquatic animals. The groups have requested an exemption from certain provisions in the hours-of-service (HOS) rules to allow their drivers, after 10 consecutive hours off duty to: (1) drive through the 16th consecutive hour after coming on duty; and (2) drive a total of 15 hours during that 16-hour period. For the reasons outlined below, the NTSB believes that the FMCSA should deny this requested exemption, and any similar exemptions, to the HOS rules. In 2012, the NTSB reiterated Safety Recommendation H-10-9 in two reports in which the probable cause was attributed to driver fatigue: (1) the March 2011 motorcoach run-off-the-road and collision with a vertical highway signpost in New York City, New York, and (2) the May 2011 motorcoach roadway departure and overturn in Doswell, Virginia.5 In the Doswell report, the NTSB stated that, “Although some carriers will adopt fatigue management programs to improve the safety of their operations, many will not. In fact, those carriers with the weakest safety management—that is, the operations that most need a fatigue management program—are the least likely to implement one.” Also, in light of the initial progress the FMCSA had made on developing the NAFMP and assessing its utility, the NTSB reclassified Safety Recommendation H-08-14 “Closed—Acceptable Action/Superseded” and recommended that the FMCSA, “Establish an ongoing program to monitor, evaluate, report on, and continuously improve fatigue management programs implemented by motor carriers to identify, mitigate, and continuously reduce fatigue-related risks for drivers” (Safety Recommendation H-12-29). In the years since Safety Recommendation H-12-29 was issued, the FMCSA has continued to promote the NAFMP as a voluntary approach to fatigue management. However, the agency has repeatedly refused either to mandate fatigue management programs or to establish a method of evaluating and improving such programs adopted by motor carriers. In a May 2014 letter to the FMCSA, the NTSB stated, “We are concerned that a voluntary adoption policy with no monitoring of such a policy’s results will fail to adequately address the problem of fatigued drivers, and will continue to result in catastrophic crashes,” and classified Safety Recommendation H-12-29 “Open—Unacceptable Response.” The FMCSA stated in January 18, 2019, correspondence to the NTSB concerning Safety Recommendation H-12-29 that it had no plans to implement a program to monitor, evaluate, report on, and continuously improve fatigue management programs at the motor carrier level. It requested that the NTSB close the recommendation. By including “Reduce Fatigue-Related Accidents” in its 2019–2020 Most Wanted List of Transportation Safety Improvements, the NTSB reaffirmed its commitment to this vital safety issue. Safety Recommendation H-12-29 is one of the recommendations in this safety area. The NTSB continues to believe that, as stated in Safety Recommendation H-12-29, the FMCSA should establish a program to monitor, evaluate, report on, and continuously improve FRMSs implemented by motor carriers. In their application for exemption from HOS requirements, the requestors proposed implementing an FRMS to provide an adequate level of safety in lieu of the requirements. In the current environment, the system they have proposed cannot be fulfilled because the FMCSA does not have a means to track, evaluate, or validate the effectiveness of FRMSs. The NTSB believes that, until it adopts a program to track FRMS performance, the FMCSA should deny the requested exemption, and any similar exemption, to the HOS rules. We urge the FMCSA to establish a program as described in Safety Recommendation H-12-29, so that it can evaluate and monitor the success of FRMS programs in general, but more particularly, so that it can ensure the safe operation of motor carriers that are granted regulatory exemptions.

From: FMCSA
To: NTSB
Date: 1/18/2019
Response: -From Michael Jordan, Strategic Planning and Program Evaluation Division, Federal Motor Carrier Safety Administration: On August 8, 2018, and December 4, 2018, representatives from the Federal Motor Carrier Safety Administration (FMCSA) and National Transportation Safety Board (NTSB) met to discuss the status of 13 safety recommendations. This memorandum communicates the status updates discussed at those meetings. Source: Highway Accident Report (NTSB/HAR-12/02); Doswell, Virginia (2011-05-31) Current Classification: Open - Unacceptable Response Requested Classification: Closed Status Update: • FMCSA acknowledges that NTSB issued safety recommendation H-12-029 to encourage the development of an Agency program (at the motor carrier level) that monitors, evaluates, reports on, and continuously improves any fatigue management programs that motor carriers implement in the absence of a Federal mandate for motor carriers to implement such a program. • FMCSA plans no action to establish the program “at the motor carrier level” as recommended by NTSB. • Fatigue management information continues to be accessed via the NAFMP web site. Google Analytics data for the NAFMP web site indicate that 7,600 user sessions were logged in both 2016 and 2017, with 7,200 user sessions logged in 2018. o Google Analytics uses the term “sessions” to count the number of hits. A user session is a group of user interactions with a web site that takes place within a given time frame. For example, a single session can contain multiple page views, events, social interactions, downloads, and e-commerce transactions. o FMCSA does not know who the individuals were that accessed the NAFMP web site more than 22,000 times during the last three years. However, the Agency does know, anecdotally from staffs’ engagement at conferences and other engagements with safety managers, that individuals in positions to influence motor carriers’ safety cultures are incorporating guidance from the NAFMP into their management practices. o The NAFMP web site remains active and guidance concerning fatigue management continues to be accessed and used by motor carriers. • FMCSA will continue to support both fatigue-related research and the NAFMP, which includes the maintenance, improvement, and promotion of the NAFMP to encourage the voluntary implementation of fatigue management practices by motor carriers. • FMCSA requests NTSB close safety recommendation H-12-029.

From: NTSB
To: FMCSA
Date: 12/6/2017
Response: We are encouraged by your efforts to evaluate the causes of driver fatigue through multiple studies and programs; however, the intent of this recommendation was for you to develop a program at the motor carrier level to monitor, evaluate, report on, and continuously improve any fatigue management programs motor carriers implement for their drivers in the absence of a federal mandate for such programs, as recommended in Safety Recommendation H-10-9. Pending your development of the recommended program, Safety Recommendation H-12-29 is classified OPEN--UNACCEPTABLE RESPONSE.

From: FMCSA
To: NTSB
Date: 6/20/2017
Response: -From Michael J. Jordan, USDOT/FMCSA MC-PRS, Strategic Planning and Program Evaluation: • FMCSA continues to work with Transport Canada and other entities to improve fatigue management programs, including the North American Fatigue Management Program (NAFMP). o The NAFMP Web site has been implemented since July 2013. o Support for the NAFMP rotates on an 18-month cycle where FMCSA will take the lead for 18 months and then hand off the lead role to another entity for the next rotation. • FMCSA funded a study by the National Academies of Sciences, Engineering, and Medicine (NASEM) to assess the state of knowledge about the relationship of factors (e.g., hours of driving, hours on duty, and periods of rest) to the fatigue experienced by truck and bus drivers while driving and the implications for the safe operation of their vehicles. Additionally, NIOSH was tasked with assessing the relationship of these factors to drivers’ health over the longer term and identify improvements in data and research methods that can lead to better understanding in both areas. o The NASEM report is available online at https://www.ncbi.nlm.nih.gov/books/NBK384966/pdf/Bookshelf_NBK384966.pdf • FMCSA partially funded a study/survey of long-haul truck drivers conducted by the National Institute for Occupational Safety and Health (NIOSH) o The NIOSH report is available online at https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4631642/. • FMCSA’s National Training Center (NTC) is examining NAFMP materials to determine whether a refresh of materials is necessary. • FMCSA funded a Small Business Innovative Research (SBIR) project for a smart phone application designed to incorporate fatigue modeling into driver schedules, routing when booking a load, and allow the CMV driver to stay in the range of a higher state of alertness. • FMCSA proposed a pilot program on June 6, 2017, to allow temporary regulatory relief from the sleeper berth regulation for commercial driver’s license holders who regularly use a sleeper berth to accumulate their required 10 hours of non-duty work status. During the pilot program, participating drivers would have the option to split their sleeper berth time within parameters specified by FMCSA. Driver metrics would be collected for the duration of the study, and participants' safety performance and fatigue levels would be analyzed. This pilot program seeks to produce statistically reliable evidence on the question whether split sleeper berth time affects driver safety performance and fatigue levels. • FMCSA requests NTSB close safety recommendation H-12-029.

From: NTSB
To: FMCSA
Date: 5/13/2014
Response: We are pleased you have undertaken a multi-year collaborative effort with your Canadian partners to complete implementation of the NAFMP. We understand that the instructional program, which can be used online or in a traditional classroom setting, includes 10 modules that address various aspects of fatigue management, including safety culture, driver and driver family education, shipper and receiver best practices, scheduling tools for drivers and motor carriers, sleep disorder management, and fatigue monitoring technologies. We note that these materials are accessible through the NAFMP website and are available free of charge. We also note that the NAFMP training modules consist of PowerPoint presentations, videos, and interactive courses that include current fatigue management practices and countermeasures; that you have revised your “Driver Fatigue Video” to include all commercial vehicle drivers; and that you plan to update the modules regularly as new research findings, technology, and best practices become available. Including the recommended information in these modules constitutes an acceptable alternate means of satisfying Safety Recommendations H 09-32 and H 10-8. Accordingly, these recommendations are classified “Closed?Acceptable Alternate Action.” Although the NAFMP is a comprehensive program containing a range of information to help drivers and motor carriers effectively manage commercial driver fatigue, we are disappointed that you have not required its adoption by all motor carriers nor implemented a program to evaluate or improve fatigue management programs adopted by motor carriers. We are concerned that a voluntary adoption policy with no monitoring of such a policy’s results will fail to adequately address the problem of fatigued drivers, and will continue to result in catastrophic crashes. We urge you to reconsider your position and explore all possible means to mandate the use of the NAFMP by the more than 525,000 currently active interstate motor carriers and to develop a way to provide continuous improvement of the NAFMP based on real-world data from the carriers. Pending your reconsideration of your current position, Safety Recommendations H 10-9 and H 12-29 are classified OPEN—UNACCEPTABLE RESPONSE.

From: FMCSA
To: NTSB
Date: 2/3/2014
Response: From Anne S. Ferro, Administrator: FMCSA worked collaboratively with Transport Canada, the Alberta Ministry of Transportation, the Alberta Ministry of Employment and Immigration, the Commission de la sante et de la securite du travail du Quebec, and the Societe de 1 'assurance automobile du Quebec to develop NAFMP and will continue to encourage the voluntary use of this interactive web-based educational and training program. Operational and other support was provided by the motor carrier industry through the participation of the Canadian Council of Motor Transport Administrators (CCMT A), Alberta Motor Transport Association, the American Transportation Research Institute (ATRI), and Canadian and U.S. volunteer motor carriers. The multi-year collaborative research to develop, test and evaluate components of a fatigue management program (FMP) for commercial vehicle operators has resulted in a thorough understanding of the issues, opportunities, and challenges inherent in managing operator fatigue in a 24/7 commercial trucking environment. The NAFMP was developed through the following four distinct research, development, and testing phases: • Phase 1 -Involved the identification of fatigue management requirements and developed a comprehensive approach designed specifically for drivers, dispatchers, and company managers. • Phase 2 - Involved the development of education and training materials and procedures for assessment of field testing the FMP. • Phase 3 -Involved the conducting of field operational tests in two stages: protocol development and field testing of the effectiveness of the comprehensive FMP compared to current industry practices. • Phase 4 - Involved the development and advancement of recommended practice guidelines, manuals, and other training materials, which were made available to all commercial motor carriers to implement a comprehensive and effective FMP. The overall NAFMP instructional program is organized into a series often modules, each covering required topics directed toward specific audiences, and is available both online and through traditional classroom settings. The curriculum for the training program is listed below. The estimated duration for each module includes time for slide presentation/narration, trainee probe questions, self-tests, and trainee evaluation (at end of each module). Module 1: FMP Introduction and Overview (45 minutes) Module 2: Safety Culture and Management Practices (1.5 hours) Module 3: Driver Education (3 hours) Module 4: Driver Family Education (45 minutes) Module 5: Train-the-Trainer for Driver Education and Family Forum (3.5 hours) Module 6: Shippers and Receivers (30 minutes) Module 7: Motor Carrier Sleep Disorders Management (1.5 hour) Module 8: Driver Sleep Disorders Management ( 1.25 hour) Module 9: Driver Scheduling and Tools (1 hour) Module 10: Fatigue Monitoring and Management Technologies (1 hour) For each module, instructional methods and materials include instructor-led PowerPoint presentations, web-based non-interactive course, and web-based interactive course. FMCSA recognizes the growth of the world-wide web and the possibilities it affords in providing alternative training and educational opportunities. As a result, the Agency proposes using the web-based modules in place of a separate video to offer experiential learning opportunities that will specifically address commercial driver fatigue. On July 10, 2013, the NAFMP website was officially launched and can be viewed at http://nafmp.org. Information is currently offered in English and French. The website provides a comprehensive approach to commercial driver fatigue management including the following: • Online fatigue management training for drivers, drivers' families, carrier executives and managers, dispatchers, and shippers/receivers. • Information on how to develop a corporate culture that facilitates reduced driver fatigue. • Information on sleep disorders screening and treatment. • Driver and trip scheduling information. • Information on Fatigue Management Technologies. The website's NAFMP Implementation Manual provides guidance for carriers that choose to deploy the NAFMP and help with designing and implementing a FMP for their company. The website includes all materials and guidance free of charge to any individual or organization and will be continually updated to include any new research findings, technology, or best practices. The website also offers carriers a cost-benefit (Return-on-Investment) calculator to estimate the monetary benefits of implementing NAFMP, either in its entirety or select components in a customized program (e.g., fatigue management training, sleep disorder screening and treatment, technology deployment, and scheduling tool s). The user guide explains the various data input requirements and results generated by the calculator, and provides the sources used to generate the default values for several data elements. The NAFMP fatigue management tool does not replace or override the FMCSA or Transport Canada's regulations on hours-of-service (HOS). The Agency's and Transport Canada's regulated commercial motor carriers and drivers continue to have a duty to know and comply with the respective FMCSA or Transport Canada HOS regulations. FMCSA acknowledges NTSB's concerns regarding the need for carriers to adopt FMPs; however, the Agency still believes that non-regulatory alternatives should be explored fully prior to any effort to mandate such programs. The Agency will continue to work with stakeholder groups and the motor carrier industry to promote the voluntary implementation of FMPs based on the NAFMP. The NAFMP Steering Committee is planning a meeting with industry and government representatives to obtain guidance and recommendations for the NAFMP. This meeting is tentatively scheduled for February 2014 and will include a focused discussion on the use of NAFMP. Based on the information provided, FMCSA plans no further action and believes that it has fully addressed safety recommendations H-09-32; H-1 0-08; H-1 0-09; and H-12-29 and respectfully requests that NTSB reclassify these safety recommendations as "Closed-Acceptable Alternate."

From: NTSB
To: FMCSA
Date: 3/28/2013
Response: We support the FMCSA’s continued efforts to develop the North American Fatigue Management Program (NAFMP), and we encourage you to include elements in the program to address this recommendation. We look forward to participating in a preview of the completed NAFMP. Until your work on the program is complete, Safety Recommendation H-12-29 is classified OPEN—ACCEPTABLE RESPONSE.

From: FMCSA
To: NTSB
Date: 2/21/2013
Response: -From Anne S. Ferro, Administrator: I am pleased to provide the Federal Motor Carrier Safety Administration's (FMCSA) response to the National Transportation Safety Board's (NTSB) letter regarding Safety Recommendations H-12-29 through H-12-31. The Agency acknowledges the NTSB's thorough investigation into the May 31, 2011, motorcoach crash near Doswell, Virginia. The FMCSA shares your concern and commitment to transportation safety, especially pertaining to passenger carrier safety. Safety is FMCSA's number one priority and clearly shapes the Agency's agenda to ensure the safe operation of commercial motor vehicles (CMV) and to hold unsafe companies accountable for achieving safety compliance. The FMCSA does this through a mix of programs, rules, and enforcement tools framed on three guiding principles: to raise the safety bar to enter the industry; to require high safety standards to remain in the industry, and to remove high-risk carriers, drivers and service providers from operation. Everything the Agency does can be tied back to one or more of these principles. . Following the Doswell, Virginia, and other fatal motorcoach bus crashes along the Interstate 95 corridor, FMCSA launched an unprecedented investigation into bus companies operating in flagrant violation ofthe Agency's safety regulations. This investigation culminated into nine separate enforcement actions against three passenger carrier networks based on extensive information collected by FMCSA safety investigators and inspection data collected by State law enforcement partners during multiple bus safety strike forces and investigations. The Agency's investigations and data analysis found multiple patterns of serious safety violations by three networks of bus companies that deliberately structured their operations to evade Federal laws and regulations. The companies, which carried almost 2,000 passengers a day, showed flagrant disregard for the public's safety by using: • Drivers without valid commercial driver's licenses or medial qualification certificates; • Drivers who had not been properly drug tested; • Drivers who had exceeded the hours-of-service limits; and • Vehicles that were mechanically unsafe and in disrepair. The Agency continues to investigate companies operating under this type of management structure and will continue to take appropriate action against any of these companies as warranted. Another way FMC SA is working to achieve higher safety standards and remove unsafe drivers and carriers is through focused safety strike forces at the busiest travel destinations across the country and areas of non-traditional, curbside service. In Fiscal Year (FY) 2011 alone, the Agency and its State law enforcement partners conducted more than 114,000 inspections and 1,500 compliance reviews and issued 12 imminent hazard orders and 110 unsatisfactory/unfit determinations or failure to pay out-of-service (OOS) orders to passenger carriers. These were drastic actions taken against carriers that would not come into compliance with Agency regulations and had to be removed from service. 2 In 2012, FMC SA continued its strike force initiatives and conducted safety inspections of motorcoaches, tour buses, school buses, and other commercial passenger buses in 13 states and the District of Columbia, including (Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, Virginia, and West Virginia). In FY 2012, FMCSA conducted 124,153 inspections, 1,891 compliance reviews, issued 30 imminent hazard orders, and 108 unsatisfactory/unfit determinations or failure to pay OOS orders to passenger carriers. The FMCSA will continue to partner with State and local law enforcement to take part in the nationwide passenger carrier strike forces to strengthen commercial bus and driver safety. In September 2011, the u.S. Department of Transportation (DOT) hosted a National Motorcoach Safety Summit in Washington, DC, to increase awareness of the importance of motorcoach safety and to energize and empower stakeholders, partners, and the public to take action in making motorcoach transportation safer. To compliment this effort, FMC SA unveiled its "SaferBus Mobile App," a first-of-its-kind, multilingual smartphone and tablet application that gives bus riders a quick and free way to review a bus company's safety record before buying a ticket or booking group travel. The FMCSA also continues to encourage consumers to review its "Think Safety: Every Trip, Every Time" pre-trip safety checklist available online at the Agency's website. Consumers are also encouraged to report any unsafe bus company, vehicle, or driver to FMCSA through a toll-free hotline at 1-888-DOT-SAFT (1-888-368-7238) or through its online National Consumer Complaint Database. Likewise, FMCSA has actively been implementing the Department's Motorcoach Safety Action Plan (MSAP), first released in November 2009. The MSAP took a fresh look at motorcoach safety issues and identified actions to address outstanding safety problems with schedules for implementation. To date, more than 60 percent of the original FMCSA actions have been completed. On December 12, 2012, the Department released an updated MSAP. The updated plan highlights the Department's accomplishments from previous years and provides information on safety measures and new initiatives to improve the safety of motorcoach passengers. It reflects the integrated activities of the Department's safety agencies and incorporates the feedback of numerous motorcoach safety stakeholders during the 2011 Motorcoach Safety Summit. It expands on the initial 2009 version by focusing on driver fatigue, driver behavior, vehicle maintenance, operator oversight, crash avoidance measures, and occupant protection. It also includes new requirements and mandates under the "Moving Ahead for Progress in the 21st Century Act" (MAP-21) reauthorization legislation. The MAP-21 legislation requires various new motorcoach rulemakings and research projects, as well as requirements for improved oversight of motorcoach service providers. Specific to NTSB Safety Recommendations, H-12-29 through H-12-31, the Agency believes the initiatives outlined below address each of the respective recommendations. The FMCSA acknowledges NTSB's views on this issue, but does not believe establishing a program to monitor, evaluate, and report on fatigue management programs (FMP) would provide meaningful information to the Agency or advance the cause of roadway safety. The FMCSA believes that the soon-to-be complete North American Fatigue Management Program (NAFMP) will be sufficient for this purpose and that establishing additional reporting and monitoring requirements is unnecessary. Since 1999, FMC SA has been involved in NAFMP, an initiative which aims to develop, implement, evaluate, and deliver a comprehensive, integrated FMP for the commercial motor carrier industry, operating under various regulatory jurisdictions. There are four phases to the project, three of which have been completed as follows: • Phase 1 - Involved the identification of FMP technical requirements and developed a comprehensive approach designed specifically for drivers, dispatchers, and company managers. • Phase 2 - Involved the development of education and training materials and procedures for assessing the effectiveness of an FMP. • Phase 3 - Involved conducting field operational tests in two stages: protocol development and field testing of the effectiveness of the comprehensive FMP compared to current industry practices. The project is currently in Phase 4, which involves the development and advancement of recommended guidelines, manuals, and other training materials that will be made available to all commercial motor carriers to implement a comprehensive and effective FMP. Presently, the NAFMP modules and implementation manuals have been completed in English and are being translated into French. The NAFMP website which contains the Learning Management System, PowerPoint presentations, interactive exercises, images and videos, and lesson quizzes is still under development. The Agency anticipates the website and NAFMP to be completed by spring 2013. Upon completion, FMCSA will invite NTSB to a formal preview and briefing on the NAFMP initiative. Additionally, FMCSA has recently published the following three research reports related to motorcoach driver performance and fatigue: • Motorcoach Driver Fatigue Study • Investigation of the Effects of Split Sleep Schedules on Commercial Vehicle Driver Safety and Health • The-Safety-Performance-of-Passenger-Carrier-Drivers In the meantime, FMCSA will continue to work with our stakeholders to encourage and promote the safety benefits of incorporating an FMP in a motor carrier safety environment. Based on the reasons cited above in Safety Recommendation H-12-29, FMCSA respectfully requests that NTSB classify Safety Recommendation H-12-29 as "Open-Acceptable Response."