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Comment 227 for Truck and Bus Regulation (truckbus14) - 45 Day.

First NameLee
Last NameBrown
Email Addressleebrown@calcontrk.org
AffiliationCCTA
SubjectTruck 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 NameAAOHNJ Mortality Among Truck Driver Assoc Members Birdsey 1110 (3).pdf
Date and Time Comment Was Submitted 2014-04-21 17:03:53

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