First Name | Lee |
---|---|
Last Name | Brown |
Email Address | leebrown@calcontrk.org |
Affiliation | CCTA |
Subject | Truck Rule - PM2.5 Not Killing Truckers |
Comment | Mortality Study on Owner-Ops Disproves Claims of Risk From Exposure to PM2.5 As readers of California Transportation News are aware, the California Construction Trucking Association (CCTA) is at the forefront of challenging the environmental regulation of the trucking industry based on questionable claims that exposure to diesel PM somehow represents a significant health risk – to anyone. While many in our industry have grown weary of the fight and have either chosen to comply with onerous and expensive regulations, or decided to leave the industry altogether, the fact that epidemiological studies used as the basis to regulate our industry are flawed must still be pursued – especially since the proverbial “goal posts” are in the process of being moved in regards to unsupported health effects from increasingly cleaner diesel emissions. Staff for the CCTA attends many various meetings of environmental agencies and we can report that academic researchers (such as John Froines at the Southern California Particle Center) are already soliciting additional research funds from those agencies to study “diesel vapor” and its “unknown health risks.” Obviously, researchers think their work thus far has shown conclusive linkage between exposures to diesel PM and adverse health consequences. Even with the 2010 EPA compliant engines producing nearly zero emissions, opponents of diesel need to create a new boogeyman in order to keep the hundreds of millions in research dollars flowing. We hear “autism” is next on the list. Truckers, the Big Canaries Without going into a long dissertation on all the statistical and methodological problems with virtually every study of diesel PM, consider this; when it comes to diesel exhaust exposure, who are the proverbial “canary’s in the coalmine” when it comes to real world ambient exposure to diesel exhaust? If diesel exhaust actually leads to all the deleterious health affects claimed by environmentalist and their lackeys inside public agencies and conflicted academia, who would be most affected and show a direct linear relationship between exposure and adverse health risk? Truckers of course, they are “ground zero” when it comes to diesel exhaust exposure and a study exists that shows truckers are not dying at the same rate from the same causes as the population as a whole. A number of years ago as a member of the Board of Directors of a trucking trade association we were presented a pretty convincing theory that truckers were inherently at risk of an early demise – it was an occupational hazard we were told. We were also told that the average age of death for a member was 55 years of age and that the average age of death for a retired Teamster driver was just past 61. These unsubstantiated statistics actually worked their way into public discussion of driver health risks and were often cited as facts. It was believed that if a study were performed by the National Institutes of Occupational Safety and Health (NIOSH) confirming the grim reality it would be immeasurably useful in advancing certain legislative priorities of the association. The organic statute creating the Federal Motor Carrier Safety Administration (FMCSA) requires that the agency ensure that operating a commercial motor vehicle would “not create an adverse impact on driver health,” so being able to cite to a definitive government study that confirmed the hypothesis would have been worth its weight in gold. The Bell That Didn’t Ring Researchers for NIOSH eventually did an analysis culled from a cohort of 156,241 owner-operators (truck drivers) located throughout the U.S. and compared that list with death certificates on file with the National Death Index (NDI). Researchers were able to pull and identify the cause of death for 4,368 individuals and statically compare the cause of death rate against 26 major disease classifications for the entirety of our national population. If truckers were dying sooner or more frequently from diseases commonly associated with diesel exhaust exposure it should have easily shown up – it didn’t. With the exception of one category – accidental deaths from transportation accidents – truckers are not dying at the same rate as the general population from a wide range of diseases. Simply stated, for those exposed to diesel exhaust at higher concentrations and for durations extending into decades, an analysis of death certificates does not show them dying at statistically relevant elevated levels compared to the general population. It almost seemed this finding was unexpected by the researchers and in order to explain the surprising results they attributed their findings to the Healthy Worker Effect (HWE). Basically, researchers assumed that because truckers (CDL holders) must be medically re-qualified every other year and because certain medical/physical conditions can prohibit someone from driving a truck, as a group truckers are healthier than the general public. That assumption is dead wrong. Everyone in trucking knows the medical qualification process is and has been a joke for decades. It has never been a problem simply paying to get a medical card where the doctor asked “how do you feel?” and simply signed off on the whole process. Because of this and outright fraud identified post-crash by the National Transportation Safety Board, the entire medical qualification process is undergoing significant regulatory revamp to tighten up the process, ensure that drivers are actually medically qualified and place significant oversight on medical providers. Those changes have not actually had an impact as yet, since they will be implemented over the next couple of years. Hence, reliance on the HWE to explain the unexplainable is scientific misdirection. Besides the obvious implications related to diesel exhaust exposure, the study is also useful for our industry to push back against further regulation of our industry based on unsupported claims that the task of driving a truck inherently compromises driver health. CTN is republishing the abstract of the study that was published in a 2010 journal of the American Association of Occupational Health Nurse (AAOHN) – See centerfold pullou in CTN Magazine November issue Editor’s note: CCTA recently submitted comments to the U.S. EPA regarding CARB’s off-road diesel engine regulations. To support our opinion that CARB cannot meet an extraordinary and compelling need to regulate as required under the Clean Air Act, we attached the same study abstract to our comments. The U.S. EPA has embargoed that portion of our comments from public display claiming it is copyrighted material in spite of the fact we have paid AAOHN to republish it. Additionally, our use was within the copyright acceptable use policy as published by AAOHN. We have been in contact with the periodicals editor and she cannot understand the EPA’s refusal to fully publish our comments. Truth suppression anyone? |
Attachment | www.arb.ca.gov/lists/com-attach/253-truckbus14-BmdXMFM9BD8FbQNp.pdf |
Original File Name | AAOHNJ Mortality Among Truck Driver Assoc Members Birdsey 1110 (3).pdf |
Date and Time Comment Was Submitted | 2014-04-21 17:03:53 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.