Working hours regulations and fatigue in transportation: A comparative analysis

Fatigue is recognised as one of the most important safety issues in transportation. The current paper identifies and compares the laws and regulations of four English speaking nations that limit working hours for safety purposes, and evaluates them against eight fatigue-related criteria. In addition, International and European Union law are considered where relevant. Two different styles of regulation were utilized by the countries surveyed: a prescriptive “Hours of Service” approach, and a non-prescriptive “outcomes” approach. The advantages and disadvantages of these two models are discussed. None of the rules were assessed as addressing all eight criteria. A proposal for a hybrid approach between the prescriptive and non-prescriptive systems is presented.