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Applying a voluntary compliance model to a proposed transportation safety regulation


David E. Cantor
College of Business, Iowa State University, Ames, Iowa, USA, and

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Received December 2009 Revised June 2010 Accepted July 2010

Marianick Terle
Enval, France
Abstract
Purpose The objective of this paper is the development of a voluntary compliance model that is applied to the current and substantive governmental regulatory electronic on-board recorder (EOBR) proposal in the workplace. Design/methodology/approach This study is designed to qualitatively evaluate the responses of commercial drivers to the federal governments proposed EOBR safety technology. Results are based on the analysis of published comments made by commercial drivers to a US government online database, the Federal Docket Management System. Findings Four major thematic categories emerged from the commercial driver comments are analyzed, including government control over workplace behavior; nancial impact; technology readiness; and attribution issues , e.g. misplaced responsibility for safety problems (generally on other drivers or outside parties). This paper links these concerns to a procedural justice model and discusses how procedural justice concerns can contribute to voluntary compliance and employment turnover intentions. Important commercial driver, motor carrier, and public policy implications are thus revealed. Originality/value This study represents the rst development of a voluntary compliance model that is applied to the proposed EOBR mandate. The deployment of this voluntary compliance model may lead to greater compliance rates. Keywords Transportation, Road safety, Communication technologies, Employee turnover Paper type Research paper

International Journal of Physical Distribution & Logistics Management Vol. 40 No. 10, 2010 pp. 822-846 q Emerald Group Publishing Limited 0960-0035 DOI 10.1108/09600031011093223

1. Introduction Compliance with safety practices is a critical workplace issue in the USA. In 2007, an astounding 5,488 employees in the USA died from work-related injuries, and another 3.9 million sustained injuries causing the loss of at least one day of work. The National Safety Council (2010) estimates the total annual economic cost of serious work-related injuries and fatalities at $183 billion on an annual basis. To put this cost in perspective, each and every worker must produce $1,250 worth of goods and services annually to offset the cost of work injuries (National Safety Council, 2010). Unfortunately, serious work-related accidents have both nancial and human consequences, and it is important that social scientists develop voluntary compliance strategies to reduce employee exposure to the consequences of an error-prone work environment (Tyler et al., 2008; Hoffman and Mark, 2006; Hoffmann and Stetzer, 1998). Research suggests that one possible cause of workplace accidents is excessive work demands. In the US motor carrier industry, the setting of this study, commercial motor vehicle (CMV) drivers are motivated to work long hours in order to earn

a reasonable living, as they are generally paid on a per-mile basis. Commercial drivers routinely violate rules governing maximum allowable work hours, thus are highly susceptible to highway collisions and near misses (Saltzman and Belzer, 2002). Indeed, driver fatigue is repeatedly cited as a major contributor to motor carrier crashes (Crum and Morrow, 2002; Hartley et al., 1996; Smiley, 1996; Wylie et al., 1996; Knipling and Wang, 1994). Electronic on-board recorders (EOBRs) the safety tool studied here have received signicant attention as a potential tool to mitigate the frequency and magnitude of truck crashes, because they address driver fatigue and logbook falsication problems (Cantor et al., 2009, 2010). To address these issues, in May 2000, the federal government issued a notice of intent to require the adoption of EOBRs to record a drivers daily hours (US Department of Transportation, 2001). Unsurprisingly, the federal governments proposed use of information technology for this purpose has raised a multitude of concerns across the industry, as the rule provides a powerful means for government ofcials and management to monitor the daily activities of drivers in real time. The Owner-Operator Independent Drivers Association (OOIDA) expressed its opposition to the EOBR rule, protesting that there is no rational basis for the economic burden and the unreasonable imposition on personal privacy proposed by this rule (OOIDA, 2007, p. 4). Additionally, the teamsters are concerned that data used in any electronic tracking system could be used as grounds for disciplinary action against its members (Fleet Owner, 2007). Among the harshest critics is public-advocacy group Public Citizen, which asserts that the criteria imposed on carriers potentially subjected to the EOBR rule represents a very weak standard (Fleet Owner, 2007). However, an Arkansas Trucking Association (2009) report suggests that EOBRs have proved to be efcient and should reduce or eliminate large dollar awards resulting from litigation. Tyler et al. (2008) offer initial evidence that eliciting voluntary compliance with rules and regulations is more effective in promoting compliance than the command-and-control approach, because individuals are more likely to comply with rules when they are not monitored. In voluntary compliance it is crucial that group members adopt the value of compliance with rules and regulations as their own. Trevino et al. (1999) provide empirical support to demonstrate that employees who voluntarily comply with rules achieve greater compliance rates. Yet the potential role of voluntary compliance in successful adoption of the EOBR regulation has scarcely been examined. The objective of this paper is the development and application of a voluntary compliance model to a forthcoming governmental regulatory EOBR proposal. The voluntary compliance model is enhanced by insights gleaned from procedural justice literature and commercial driver responses to an upcoming federal policy based on a unique data set of published comments made by commercial drivers to a US government online database, the Federal Docket Management System (FDMS). The contribution of our research is to build upon previous motor carrier safety and procedural justice research by developing a voluntary compliance model on a public policy in which drivers will be required to use the EOBR technology as a part of a federal government safety initiative (Cantor et al., 2009, 2010; Masterson et al., 2000; Moorman, 1991). Section 2 provides brief background information on the current and substantive EOBR public policy problem and introduces a new voluntary compliance model. Section 3 describes the qualitative approach used in the analysis of the EOBR adoption problem.

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Major themes expressed by CMV drivers about the proposed EOBR policy are identied in Section 4. Findings are explored and interpreted in Section 5. Section 6 contains nal conclusions, implications of the research, and directions for future research. 2. A voluntary compliance model for the EOBR safety technology As highlighted in the introduction, there is widespread speculation that commercial motor carrier drivers (and other constituencies) are largely opposed to the US Department of Transportations electronic EOBR rule (York, 2004). Historically, motor carrier drivers have been attracted to the industry because of the autonomy and independence associated with long haul trucking responsibilities. Not surprisingly, over the past several years, many new rules have met with the resistance of motor carrier drivers, because any new government mandate has been perceived as an intrusion into the daily lives of the truck driver (Cantor, 2008). Motor carrier drivers have been increasingly attentive to the EOBR rule because they widely agree that the rule will provide a powerful means for the government and management to monitor the daily activities of the driver in real time, thus will invade their privacy. Government authorities are charged with improving safety performance by issuing public policy directives that govern safety practices. Because voluntary compliance with initiatives may more effectively encourage adherence to rules and regulations as compared to a command-and-control approach, a voluntary compliance model that is informed by the literature on procedural justice, technology readiness, and attribution theory is in order (Tyler et al., 2008). The basic premise of this model is that greater compliance with government regulations on workplace safety practices can be achieved by addressing a groups procedural justice concerns (Tyler et al., 1996; Tyler, 1989). Procedural justice refers to the impact of the perceived fairness of decision-making procedures on the attitudes and behavior of those affected by authoritative organizational or legal decisions (Moorman et al., 1998; Korsgaard et al., 1995; Moorman, 1991; Lind and Tyler, 1988; Thibaut and Walker, 1975). Consistent with Tyler et al. (2008), this premise is rooted in the belief that decision-making procedures should be neutral, unbiased, transparent, and fact based. Operating under such a premise, a group authority can successfully gain a groups compliance with future organizational or government decisions, such as new safety rules that govern the group member behavior in the workplace. An illustration of the model is shown in Figure 1. Control over workplace behavior and procedural justice The rst determinant in the voluntary compliance model is control over workplace behavior. Greater attempts by the government to control workplace behavior will likely lead to lower procedural justice evaluations among commercial drivers. Because use of the EOBR device will enable government ofcials to directly monitor commercial drivers, it is expected that commercial drivers will develop the impression that it is professionally and socially unfair to intrude on the drivers privacy rights. Direct monitoring of workplace behavior by organizational or government ofcials may diminish commercial drivers positive attitudes about their social status, job, employer, and other constituencies (Niehoff and Moorman, 1993). In fact, several studies have found that monitored workers report decreased social interaction with coworkers and supervisors (Irving et al., 1986) and emotional reactions such as boredom, tension, anxiety, depression, anger, and fatigue (Smith et al., 1992). Electronic surveillance

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Control over workplace behavior Intrusion of privacy Excessive government rules Hours of service rule Financial impact Cost of EOBR device Impact on industry and supply chain Technology readiness Not able to monitor everything (innovativeness) Current monitoring works No proof safety improves (insecurity) Attribution issues Only a few break the rules Others cause crashes

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Procedural justice evaluations based on group value model Neutrality of decision-making procedures Trust in decision-making authority Evidence about social standing

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Voluntary compliance Government regulation Commitment to organization and industry Organizational turnover Industry Exit

Figure 1. Voluntary compliance with EOBR regulation model

in the workplace can diminish a workers sense of dignity and social status (Lund, 1992). Use of the EOBR device or related electronic surveillance technology by an employer or the federal government to frequently monitor and control employee performance is expected to result in lower procedural justice perceptions of trust, social standing, and neutrality of regulatory authorities (Niehoff and Moorman, 1993). Financial impact and procedural justice The second determinant in the voluntary compliance model is nancial impact. Greater attempts by the government to impose additional nancial burdens on the commercial driver group will lead to lower procedural justice evaluations. To promote a positive social exchange among the driver community and government ofcials, commercial drivers must be rewarded for their good safety behavior, not nancially penalized (or punished) for the unsafe actions of only a few members in the industry (Konovsky and Pugh, 1994). Commercial drivers will develop unfavorable attitudes if they believe the government will place a nancial burden upon the driver to acquire and maintain the safety technology. Indeed, Tyler et al. (2008) point out that an employee is more likely to follow rules in environments that reward ethical behavior as compared to an environment that primarily punishes unethical behavior. The EOBR technology could be viewed as a penalty because of the perceived high cost. To alleviate nancial concerns among drivers, federal authorities should consider ways to collect driver input. Thibault and Walker (1975) point out that participation in the organizational change process is an important way to build perceptions of procedural fairness. It is logical to conclude that drivers must be allowed to assert their voices on the nancial aspect of the EOBR rule. If drivers are forced to absorb the cost of the technology

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without at least having their voices heard it will almost certainly result in lower driver evaluations of procedural justice neutrality among government authorities. Technology readiness and procedural justice The third determinant that contributes to procedural justice evaluations is a drivers technology readiness surrounding the EOBR device. Technology readiness describes the propensity of a user to embrace and use new technologies for accomplishing goals (Parasuraman, 2000). Commercial drivers may be more willing to accept technologies that are an appropriate t with a drivers job roles and responsibilities (Netemeyer et al., 1997). Advocates of the EOBR technology must explain how the EOBR technology will improve the lives of drivers, including how it will contribute to their effectiveness on the job (Parasuraman, 2000). Drivers are more likely to perceive that the proposed EOBR technology will be procedurally fair if drivers are shown the innovative potential of the technology. Government and organizational authorities can share with group members drivers how the technology will give them more control over their daily lives, enable drivers to be more efcient in their occupation, and allow them to accomplish more on the job than was previously possible. For example, EOBR or similar technologies can be used to monitor those events in the surrounding environment that contribute to driver fatigue, including warehouse facility delays, over which commercial drivers have no control. The EOBR technology could be used to monitor and measure other reasons drivers may have to work more than the legally required hours. Commercial drivers will develop favorable procedural justice evaluations of authorities when they derive positive beliefs about how the technology will benet them. Attribution issues and procedural justice The fourth determinant that contributes to procedural justice evaluations is the attribution issues category. Attribution theory examines the causality of the focal problem (Weiner, 1979). Consistent with attribution theory, causality of safety problems is perceived to be external rather than internal to the commercial driver (Weiner, 1979). Undoubtedly, the actions of myriad entities could contribute to safety problems in this industry, including shippers, receivers, a few bad commercial drivers, and the general driving public. In this regard drivers blame shippers and receivers for delaying the driver at warehouse facilities, thus reducing the available driving hours. Drivers have expressed their desire for new public policies that would penalize shippers and receivers for these delays. In fact, some drivers think that regulatory enforcement actions are needed for those shippers and receivers that delay drivers at warehouse facilities. Following this logic, drivers will have lower procedural justice neutrality views of government authorities unless the ofcials take action on other parties who may be contributing to safety problems in the industry. The safety technology mandate cannot be reasonably solved by controlling and monitoring the safety behavior among all drivers in the industry. Implementing a safety technology that is only relevant to a few group members in the industry appears to be consistent with the assumptions of distributive justice (Moorman, 1991)[1]. Drivers could perceive great inequity if the EOBR device is required for all drivers, as drivers may attribute the safety problem to only a few drivers in the industry. While this is a regular problem in the industry, drivers indicate that there are several alternative courses of action. One suggestion is to require only the bad apples to use the

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EOBR device. Another option is to regulate shippers and receivers for delaying drivers at warehouses. Procedural justice affects voluntary compliance To encourage voluntary compliance to the EOBR rule, research shows that the federal government should focus on creating favorable perceptions of procedural justice. Historically, government authorities predominantly create laws from a reactionary perspective, meaning that it seeks to solve problems articulated by voters. This research illustrates the need for government to act proactively and consider driver feedback from a neutral, transparent, and fact-based perspective (Tyler et al., 2008). Commercial drivers are more likely to comply with the governments proposed rule if the driver community is presumed to have been treated fairly (Folger and Cropanzano, 1998; Greenberg, 1993; Tyler, 1990). To develop trust among the parties involved, government authorities should provide credible evidence that they are considering the interest of commercial drivers. Anecdotal evidence suggest, that the government is attempting to create better working conditions for the group members but the driver community perceives lack of evidence that this is occurring. Therefore, voluntary compliance with the new regulation hinges on the level of trust among group members and group authorities. While it is important to provide a credible process to the commercial drivers, this does not mean that the commercial drivers should get everything they want (Tyler et al., 2008). Even though commercial drivers will not be pleased that the EOBR requirement most likely will move forward, commercial drivers will hopefully have a positive view of the federal government because drivers perceive that the process was fair. Past research has shown in many settings that procedural fairness is more important than actual outcome fairness in promoting employee compliance (Tylor et al., 2008). Voluntary compliance and drivers future commitment to the organization and industry Group members who voluntarily comply with the decision-making authority are more likely committed to the organization and industry. Compliance with the authority reects the individuals belief that the rules are morally right. Compliance also signals that the group member now believes that he or she is being treated with courtesy, dignity, and respect. The group member is valued, satised with quality of interactions with the group authority, and hence motivated to obey the rules (Tyler et al., 2008; Tyler and Bies, 1990; Bies, 1987; Bies and Shapiro, 1987; Bies and Moag, 1986). Indeed, quality of interpersonal treatment is important to group members because they want to know that their needs, concerns, and well-being are being addressed in a fair and trustworthy manner (Tyler et al., 2008). When this expectation has been met, the group members develop a sense of obligation to reciprocate with greater commitment to the group (Masterson et al., 2000). The group member will care about group-oriented issues and devote greater effort to helping the organization achieve its goals (Setton et al., 1996). Group members will also become more committed to group authorities because the group wants to maintain a long-standing relationship. Group members want to reciprocate and become involved in a social exchange relationship with the group authority (Masterson et al., 2000). Each party wants to offer something that is seen as valuable, equitable, and fair. In this case, the group members expect that the group authority will create rules that enable the group members to earn a respectable living while acting in safe manner in the workplace. In return, the group members will engage

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in positive organizational citizenship behaviors, including acting in a safe manner while still maintaining a commitment to working in the organization and industry for a long career (Setton et al., 1996). So long as this type of environment provides a satisfactory working environment for both parties, group members will not want to exhibit adverse behaviors such as withdrawal, absenteeism, intentions to quit, and actual turnover (Masterson et al., 2000; Hom et al., 1992; Steel and Ovalle, 1984). 3. Methods 3.1 Research strategy This study is designed to evaluate the reactions of commercial drivers to the federal governments proposed EOBR safety technology. Published commercial driver comments were selected from a US government online database, the FDMS. An interpretive methodology was utilized to conduct the research (Isabella, 1990; Gephart, 1993). 3.2 Sample Because use of and experience with the EOBR technology is not yet common, this study required a sample of respondents who perceive that they would be impacted by the proposed federal rule. The study also required respondents to draw on at least one attitudinal belief and describe it in sufcient detail. To avoid any geographic bias in the sample, respondents from across the nation are included in the study. Following these considerations, a sample of unique commercial motor carrier driver comments, submitted between August 2005 and September 2007, were obtained from the FDMS. Hence, we used a purposive sampling technique (Pitsis et al., 2003; Cooper and Schindler, 1998). The FDMS system is a publically accessible, web-based electronic rulemaking repository where federal departments and agencies publish rulemaking and non-rulemaking documents (for example, Federal Register notices, supporting analyses, and comments). In total, 581 sets of statements were obtained with complete contact information. All were submitted to the FDMS web site in response to the Federal Motor Carrier Safety Administration (FMCSA) request for comments on potential amendments to its regulations concerning electronic logbooks (EOBRs), which are used to document compliance with the federal hours-of-service rules[2]. The US Department of Transportation notied participants in the US motor carrier industry of the proposed federal rule and the subsequent request for comments in The Federal Register[3]. Because the FDMS did not ask for demographic information from respondents, in the fall of 2008, a short follow-up questionnaire was developed based on Dillmans recommended approach (2000) to solicit the missing demographic information. The questionnaire was distributed by mail to the addresses provided by the 581 original respondents; of that total, 48 were undeliverable. A total of 293 respondents returned the questionnaires for a total response rate of 50.40 percent (293/581). The sample of 293 comments is composed of signicantly more men (91 percent) than women. The largest group of respondents is between the ages of 51 and 60 (42 percent); however, the range in ages was between 21 and over 60. More than 80 percent of respondents have worked in the industry at least 11 years. About 67 percent of the respondents reported that they drive their vehicle between 100,001 and 150,000 miles annually. The average length of haul reported by most of the respondents (60 percent)

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is more than 1,000 miles. The sample is approximately equally split between those who own and operate their vehicles (51 percent) and those who are employed as company eet drivers (49 percent). More than 93 percent report that they have an average or better understanding of the EOBR issue. Overall, the characteristics of the respondents in this convenience sample are representative of drivers throughout the motor carrier industry[4]. 3.3 Content analysis technique The content analysis technique, an exploratory qualitative technique in which researchers gather and analyze archival documents, was used to investigate commercial driver reactions to an upcoming policy on the proposed EOBR rule in the US motor carrier industry. This technique is particularly well suited to develop greater knowledge of a phenomenon of which relatively little has been documented in elds such as political science, journalism, education, social psychology, and marketing (Bitner et al., 1990). The primary advantage of this research method is its capacity to provide accurate and consistent interpretations of peoples accounts and events without depriving these accounts of their power or eloquence (Viney, 1983, p. 550). Another advantage is that content analysis can incorporate both qualitative and quantitative examination of communications. Critics of content analysis have focused on the reliability and validity of the categories that emerge in the analysis. They note that reliability and validity problems may arise as a result of the ambiguity of the word meanings, category labels, and coding rules in the study (Weber, 1985). However, computerized content analysis programs can diminish reliability problems (Gephart, 1993). To this end, as will be described below, a formalized approach was developed and the Atlas Ti qualitative computer software was utilized to address reliability issues. Content across many texts was compared and a coding system was used to capture the beliefs, attitudes, and values expressed in the texts by the participants in this research. Prior research indicates that people are adept at describing their beliefs on a particular topic, issue, problem, or incident (Bitner et al., 1990). For this study, the textual data are the reactions of commercial motor carrier drivers to the FMCSAs proposed rule. The patterns or themes that emerge from textual analysis are not meant to be generalizeable to issues other than that specically under investigation, but rather to provide insight into the nature of the phenomenon in question (Neuman, 2006). Most of the studies that use this textual analysis method focus exclusively on the categories that emerge and the characteristics of those categories. Consistent with Gephart (1993), an iterative process of moving between text and theory guided comment analysis. In particular, a comparison and contrast between the comments of respondents revealed patterns of similarity and differences in perspective across the sample (Rynes and Gephart, 2004). 3.4 Category development and reliability After collecting the qualitative data, a set of formal and controlled procedures were used to analyze content and classify the data thematically. To this end, a coding template was developed which summarized and provided an organization of the themes identied by a team of judges as important (King, 1998, 2004; Gephart, 1993; Gephart and Wolfe, 1989). The template was initially formed by sorting the data into logical groups and categories.

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Judges A and B, graduate students who are familiar with the topic of EOBRs, read a random sub-sample of submissions and independently identied similarities across comments. These two judges then sorted, combined, and re-sorted the sample of comments until an initial set of categories emerged. The judges resolved all disagreements through discussions. In this process they developed denitions of each category and used them to inform an additional set of judges. Subsequently, Judges C, D, and E independently analyzed the content of the entire sample of comments using the Atlas Ti qualitative software program and category denitions provided by the original judges. The interjudge reliability among Judges C, D, and E was calculated using the percentage agreement statistic. Interjudge reliability was 81 percent across the classication categories. Following Perreault and Leigh (1989), an additional index of reliability (Ir) was also calculated. In contrast to the percent agreement statistic, Ir is based on a model of the level of agreement that might be found given a true population level of reliability (Perreault and Leigh, 1989). Ir was calculated as 0.767. 4. Major themes expressed by commercial drivers about the proposed EOBR policy As shown in Figure 1 in Section 2, data from this research reveal that interpretations among commercial drivers concerning the upcoming federal technology policy occur across four major thematic categories, including: (1) government control over workplace behavior; (2) nancial impact; (3) technology readiness; and (4) attribution issues. In each case the logic and presuppositions of the interpretations differ. Following are descriptions of some of the comments expressed by the commercial drivers within each of the major thematic categories. It should be noted that more than 70 percent of the comments express opposition to the EOBR issue; the remainder are positive comments. 4.1 Government control over workplace behavior Table I indicates each driver concern about government command and control over workplace behavior. Of drivers who commented in this category, the average driver was 49 years of age, and more than 85 percent of drivers are employed by a for-hire carrier. About 89 percent of these drivers are male; 60 percent of drivers were owner-operators. Owner-operators made more statistically signicant comments in this category than eet drivers ( p , 0.05). Also, there are more statistically signicant negative comments than positive comments within this category ( p , 0.01). Turning to the specic comments, many drivers worried that when EOBR technology enables government ofcials to monitor drivers daily lives, it can be used by an employer or the federal government to unfairly monitor and control driver behavior in the workplace. Fear of privacy invasion and violation of personal privacy rights is a signicant concern among motor carrier drivers. Some drivers perceive that governmental authorities are following a command-and-control approach to implement

Thematic category Intrusion of privacy

Driver concern

Sample of driver comments negative view on thematic category

Sample of driver comments positive view on thematic category

Government control over workplace behavior

Regulatory environment

1. It is an invasion of peoples privacy and 1. I am in agreement that on-board it is none of the governments business recorders should be required. Not only what we do on the road should they be required, they should be fully monitored. All records, including log books, fuel and toll receipts, kept by drivers and motor carriers should also correspond with these recorders 2. Recording devices should be required on 2. The obvious and glaring questions raising constitutional issues regarding an all CMVs used beyond 100-mile radius or individuals right to privacy (as afrmed when drivers are required to complete by the US Supreme Court in other cases) records of duty status will expose the government to cost burdens defending the use of such EOBR devices and ordinary citizens to legal costs to oppose this regulation, if passed, which seems to raise such an obvious constitutional issue to any citizen 3. This EOBR would be invading my privacy 1. Truck drivers are probably the most 1. More education to drivers of four regulated workers in the country wheeled vehicles, more enforcement of current laws upon all drivers not just truckers 2. To add one more tool for law 2. Enforcement of the current rules is the answer and education of the motoring enforcement to use for the purpose for public nding blame to be placed on the CMV operator is unacceptable 3. I do not agree with more government control (continued)

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Table I. Government control over workplace behavior comments

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Thematic category 4. The thought that somebody is interested in my safety is touching, but when the enforcement agencies start touching my wallet, I start to think even they are not really interested in my safety Support for workplace 1. The 11-14- hour day thing is stupid you rules should have give us the restart and left the log books along for now I work harder and longer without the rest

Table I. Driver concern Sample of driver comments negative view on thematic category Sample of driver comments positive view on thematic category 1. The hours of service were designed to ensure driver and public safety, which everyone has seemed to have forgotten. The on-board recorder would, if enforced, make the trucking industry more productive, safer, and, perhaps, healthier and attract career professions 2. The hours of service (HOS) rules now in 2. I commend the agency (US DOT) for place are not feasible for real world taking a stand against HOS violations by non-compliant carriers. Not only does nonconditions, i.e. no breaks allowed during compliance have a negative impact on the 14-hour workday clock once a driver has started his/her on-duty status for the safety, but I think there is a cause and effect between non-compliance, day substandard freight rates and excessive delays in loading and unloading 3. I do not think we should have on-board 3. I believe that FMCSA has got the EOBR recorders until we or you address the rule making right. The bad carriers are the shipping and receiving problems with the ones needing to get their act together and should be watched 14-hour work rule

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the EOBR device, which will lead to unnecessary levels of performance monitoring and control over driver behavior, manifested in the hours that the driver is legally allowed to work (Tyler et al., 2008). Some drivers believe that government authorities are biased in their view, hence they suspect ofcials may use the technology to further intrude on drivers privacy rights. 4.2 Financial impact A number of respondents expressed concerns about both the initial and ongoing nancial impact associated with the deployment and maintenance of EOBR technology (Table II). Drivers who commented in this category were on average 50 years of age, and 92 percent are male. Approximately, 57 percent of comments are made by owner-operators. There are more statistically signicant negative comments than positive comments within this category ( p , 0.01). Some drivers who provided comments speculated that mandated EOBR adoption will not be cost effective and will result in an increase in transportation prices. Many drivers believe that the EOBRs are too expensive and that the cost represents another procedural justice violation among some drivers in the industry. This attitude is emphasized because, as mentioned earlier, part of the procedural justice concern is based upon the lack of an opportunity for drivers to assert their voices on this nancial matter. Indeed, in this case, drivers are not sufciently informed about the actual cost of this technology. Perceptions of government ofcials are in part due to miscommunications regarding the nancial aspects of this decision. Independent motor carrier operators (owner-operators) in particular believe that the proposed technology mandate could be very expensive, especially since they would not benet from signicant economies of scale. The primary interpretation of these comments is that commercial drivers do not have sufcient information about how much the technology will initially cost to implement and maintain, because the US Department of Transportation has provided only a sample of cost estimates to date (US Department of Transportation, 2007). Because EOBR technology is not yet widely used, and because drivers have not been legally required to bear the nancial burden of the technology, drivers have a limited understanding of how they will be able to pass along part of the cost to their customers or otherwise relieve their ensuing nancial burden. As previously alluded, these nancial concerns could contribute to perceptions of procedural injustice and unfairness associated with any future EOBR mandate. These negative impressions may lead to feelings of distrust of government ofcials and a subsequent impression among drivers that they are not valued citizens within the industry. These drivers are less likely to voluntarily comply with the forthcoming regulation. 4.3 Technology readiness Table III identies the concerns of drivers about their technological readiness to use EOBRs in the workplace. Within this category, more than 58 percent of driver comments are those of owner-operators and 91 percent are males. On average, each driver is 50 years of age. There are more statistically signicant negative comments than positive comments within this category ( p , 0.01). As dened earlier, technological readiness refers to a persons propensity to embrace and use new technologies for accomplishing goals at work (Parasuraman, 2000). In the

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Thematic category

Financial impact

Table II. Financial impact comments Sample of driver comments negative view on thematic category Sample of driver comments positive view on thematic category 1. I believe (it is) a very simple, and therefore inexpensive remedy to the enforcement of HOS rules is to install a black box in the truck 2. The cost of investigating a crash will be reduced and more facts will be known about the crash 1. I think that on-board recorders would be benecial to the trucking industry. Too many truck right now go to fast, the saving in diesel fuel would greatly help the countrys energy crunch 2. This would be much less expensive for all 3. It can be a good thing for both companies and law enforcement 4. It will simplify and standardize bookkeeping by making everyones entries legible and easy to read 1. We are going to be forced to put in an expensive piece of equipment. Being a small company this could break us nancially 2. Drivers and enforcement personnel will need to be trained at a cost to trucking companies and taxpayers 3. It will very expensive to install on all trucks 4. I personally cannot afford to purchase an on-board electronic recorder (OBER) 1. The American Trucking Industry is going to be lled with a few million drivers with little or no experience as many driver with 15 or more years of experience and excellent driving records quit the industry as a result of this ruling 2. I cannot make a living spending ve of six hours a day at the docks 3. If EOBRs are mandated in the industry I will sell my truck and seek other employment opportunities 4. You people are going to keep on until no one wants to drive a truck. How do you plan on getting your food, toilet paper, and gasoline then?

Driver concern

Cost

Impact on industry and supply chain

Thematic category

Driver concern

Sample of driver comments negative view on thematic category

Sample of driver comments positive view on thematic category 1. If the purpose of the recorder is for accident prevention and investigation it should be coupled with continuous digital video recording at least in front and the sides (of the truck) 2. I do think that it should also show ground speed, as in my personal experience i have noticed most of drivers that agrantly falsify logs also tend to be more aggressive in there driving habits

Technology readiness

Not able to monitor everything

1. What would happen if I was on my mandated 10-hour break and needed to move my truck to allow work to be done in my parking spot or for safety reasons. As I understand this proposal that would violate my 10-hour break and cause me to have to restart the break? 2. The machines are unable to determine what activity is being done at any given moment, whether a driver is on-duty, driving, or off duty or if his off-duty time is used to ensure he will be adequately rested to continue driving when he restarts work. This inability to determine what is actually being done by the driver (or co-driver) will be of absolutely no help in determining whether a driver is in compliance with any HOS regulations that may affect him 3. The black box is still not going to prevent a driver being held hostage at a shipper or receivers mercy from driving after being forced to load or unload freight or wait hours or days with no compensation 4. You have no idea what that person is doing. You do not have any idea if that person is in the sleeper birth, in a near by building watching TV, loading or unloading his truck, washing his truck or any of a number of other scenarios

(continued)

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Table III. Technology readiness comments

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Thematic category 1. The qualcom unit on all trucks already provides the necessary information needed

Table III. Sample of driver comments negative view on thematic category Sample of driver comments positive view on thematic category 1. I think you should also look at the shippers and receivers to see how long they hold us up and put regulations on the too 2. There are already ways for dispatchers to know 2. If you are truly interested in highway safety, what is going on with the truck. Many companies then EOB(R]s must be installed in every truck on have installed computers that can message a the road. Other wise, the abuse will continue. If driver, know where they are and the mileage they drivers that have committed themselves to run have already gone. So why should the black legal and safe are to survive, then we need boxes be installed? protection from those that those that would see to it we are run out of the business or do us harm 3. The engine control module system s can tell you just about anything that an OBERs can 1. You put black boxes on planes and they still 1. I am all for the automatic recording devices! As crash. It is just a factor of life accidents happen a professional driver for the past 28 years I have seen way too many alleged professional drivers cheating in their log books and then bragging about it. I think that the way the program has been proposed (targeting problem companies) is a fair way of dealing with the issue 2. These boxes are supposed to be in the interest 2. From a drivers point of view, my job is somewhat less complicated. The unit is there to of safety. A driver having to drive that long because he is being recorded by this device is view, and my status in regard to the 11, 14, and 70 unsafe hours rules are updated by the minute. It automatically updates the hours available [. . .] leaving me with condence that I remain legal at all times, and will not make any errors in those calculations (continued)

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Driver concern

Current monitoring works

No proof that technology will improve safety

Thematic category

Driver concern

Sample of driver comments negative view on thematic category

Sample of driver comments positive view on thematic category

3. EOBRs will do little or nothing to improve 3. I strongly support this petition. Unsafe driving safety as they are not addressing the problem reects on our entire industry, not just on those who are unsafe. 4. The proposed rule to put EOBRs in commercial 4. This would go a long way in improving safety, vehicles will have little impact on overall and would not require a lengthy rule making highway safety. Electronic technology will not process deter anyone from entering false information and or bypassing the recording data. All the data will show is when the truck is moving, how fast it is moving and when it is idle

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Table III.

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case at hand, it encompasses attitudes toward the technology readiness dimensions described in Parasuraman (2000). This includes the potential of the technology to monitor everything to improve safety (i.e. the innovative potential of the technology); current monitoring technology already manages safety adequately (i.e. drivers are uncomfortable with using technology to replace existing processes); and disbelief that the EOBR technology will lead to improvements in safety (i.e. drivers are insecure about how and when the technology can be used to improve safety). Some drivers do not believe in the innovative potential of the EOBR technology. Rather, they believe that the EOBR device will be used to monitor driver behavior unfairly. In particular, some drivers are pessimistic that the technology will be able to monitor and reduce driver fatigue because current performance standards associated with the proposed rule do not include any biometric requirements. Drivers are also concerned that it is procedurally unfair for the EOBR technology to be in use when the driver is operating their truck for personal purposes as the technology will record all driving time as on-duty time. These comments inform the understanding that some drivers doubt that the benets of the electronic technology outweigh the economic and social costs associated with its use. The interpretation here is that these procedural justice concerns exist because public policy ofcials have not created a neutral environment to resolve questions about the technological capabilities and intended use of the EOBR device. Government ofcials have not provided to drivers scientic evidence that EOBR adoption contributes to improvements in safety performance. Rather, driver comments indicate the belief that the government may have predetermined that the EOBR device will improve safety without utilizing scientic data, which violates a core principle of procedural justice (Tyler, 1989). 4.4 Attribution issues Respondents attitudes about driving accidents illustrate the fundamental attribution error: only a few commercial drivers violate driving rules, hence it is others who cause crashes (Table IV). Drivers in this category were 48 years of age, on average. More than 56 percent of drivers, comments made were from eet drivers, and more than 95 percent of drivers, comments were from operators for carriers on a for-hire basis. There is not any statistically signicant difference in comments from owner-operators and eet drivers. There are more statistically signicant negative comments than positive comments within this category ( p , 0.05). Some drivers asserted that they abide by the current rules and should not be penalized due to the poor judgment of a few underperforming individuals such as passenger vehicle drivers. Not surprisingly, respondents in the present category believe any EOBR mandate on all commercial drivers is unwarranted and hence a violation of distributive justice. 5. Discussion A model of voluntary compliance to the governments proposed EOBR regulation has been developed. Based on a review of the literature and through a qualitative examination of commercial drivers reactions to the proposed government rule, four main themes that contribute to procedural justice judgments have emerged. The model was then extended to examine how these procedural justice judgments can impact

Thematic category Attribution issues

Driver concern Only a few break the rules

Sample of driver comments

Transportation safety regulation

1. We keep the log books required and although there is a very small percentage that is dishonest, most make every effort to comply 2. If you take care of the bad apples in the barrel so to speak and make examples of them; such as to thwart others from being caught up in the same dilemma, you would see a drastic decrease in (hours of service) HOS violations 3. I think the EOBR should be required only for agrant violators of HOS 4. For those carriers that are already operating in a safe manner the requiring of additional expenditures to prove compliance is unjustied Others cause crashes 1. If you looked at the actual statics of trucking (not CMV drivers) accidents and auto accidents. There are more auto accidents then CMV accidents every year and the accidents that are involved with a CMV more then 50 percent are caused by an automobile that is doing some of the following: (1) talking on the phone; (2) cutting in front of a CMV or tale gating; (3) just in general careless driving; and (4) falling asleep at the wheel 2. It has been proven time and again that most accidents are caused by the everyday motorist not the professional driver 3. American automobile association did a study and found that most truck/car accidents were ten out of 12 times the auto drivers fault 4. If we want to cut down on accidents, crackdown on aggressive drivers in cars and trucks

839

Table IV. Attribution issues comments

voluntary compliance intentions to the rule. The model also increases our understanding of how compliance can have important consequences regarding organizational and industry turnover concerns. The ndings are important, given the US Department of Transportation initiative that would require motor carrier drivers to adopt EOBRs in lieu of civil penalties (US Department of Transportation, 2007). Therefore, this voluntary compliance model is informed by relevant theory and has real-world signicance. An important contribution of this research is the development of the voluntary compliance model in a public policy context. In doing so, this paper demonstrates how management and organization theory can elucidate the understanding of sensitive societal issues in this case regulatory safety concerns. Informed with insights on factors that contribute to procedural justice evaluations to an upcoming federal policy, this research can offer federal agencies strategies to increase regulatory compliance. These ndings demonstrate that control over workplace behavior is an important contributing factor to procedural justice judgments. The primary nding within this thematic category is that the proposed rule raises procedural justice concerns because the requirement to use the technology will diminish the perceived control that the group has over the way that they conduct their daily lives. Government ofcials and carriers can ameliorate the concerns of commercial drivers by providing group members a forum

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to voice their opinions about how and when the EOBR device should be used. Involving drivers in the proposed EOBR adoption process is an important way for public policy ofcials and carriers to allay some of the concerns and fears expressed by the commercial driver community. Driver involvement in this process is also an important way to prevent loss of job satisfaction, which can lead to greater levels of employment turnover. A stronger social exchange between public policy ofcials, carriers, and drivers is also needed so that a clearer understanding of the challenges that exist with this proposed technology adoption policy can be addressed. Through future research, one could empirically evaluate the potential ramications associated with the EOBR device, including diminished job satisfaction and lower commitment to the organization and industry, which result in higher turnover rates. Financial concerns about a government regulation also contribute to procedural justice judgments. It has been estimated that electronic logbook devices cost between $1,000 and $3,000 per unit (US Department of Transportation, 2007). Group members who could be required to bear the cost of the proposed rule will judge the governments regulatory actions as cost prohibitive and might leave the industry. To address these procedural and distributive justice concerns, drivers recommend requiring only the most unsafe drivers to use the EOBR technology. Further, it is vital for public policy ofcials to clearly provide drivers with information about the cost of the technology as a way to develop organizational support and voluntary compliance to the rule (Masterson et al., 2000). In doing so, the federal government can directly address any equity concerns associated with mandating the technology. Technology readiness is an important factor that contributes procedural justice judgments. Currently, some group members do not believe that the EOBR device will make their lives easier because they are not comfortable with the innovative potential of the technology. While there are some drivers who believe that there are benets to using the EOBR technology, government ofcials should continue to incorporate feedback from drivers on how the technology will make their daily workplace activities easier. Government ofcials should also substantiate the benets provided by the EOBR device with scientic evidence that the technology can lead to improvements in safety. By addressing these concerns, government ofcials should be able to gain the long-term commitment of drivers. These interpretive ndings also highlight how attribution issues contribute to procedural justice judgments. For example, some drivers commented that a minority of unsafe commercial drivers and unsafe passenger car drivers should receive harsher penalties. An important implication of this nding is that, in order to address equity concerns, government ofcials should clarify the reasons that some group members will be required to use the safety technology. In order to institute a new rule, it is important for public policy ofcials and carriers to incorporate this feedback and convey to the overall industry that they recognize that a minority of drivers are primarily responsible for the problems, and they will target any proposed solution to this particular part of the industry. In this way, the government could address distributive justice concerns of drivers. While many drivers attribute the problem to others, all drivers need to nd a way to help control this issue. Employee turnover is a common concern when an organization implements a new policy or management practice (Cantor et al., 2009, 2010). Historically, in the truckload segment of the motor carrier industry, employee turnover rates have reached over

100 percent on an annual basis[5]. Combined with the arduous work environment, the proposed EOBR rule, and the tremendous resources needed to enforce safety policies, it is critically important for government and organizational authorities to work toward creating a voluntary compliance environment to alleviate the reasons group members consider leaving the industry. This model offers strategies for group authorities to assuage potential turnover concerns. 6. Conclusion, implications, and future research A voluntary compliance model applied to a proposed government safety technology regulation has been developed, and a qualitative examination of commercial driver reactions to the proposed government rule has been conducted. Drawing upon procedural justice, technology readiness, and attribution theory, four main themes that contribute to procedural justice judgments emerge. The impact of these procedural justice judgments on voluntary compliance with the proposed rule has also been examined, the results of which reveal important components of organizational and industry turnover concerns. This research has a several important implications to commercial drivers, motor carriers, and public policy makers. This research represents an initial means for commercial driver opinions to be formulated and concerns presented to policy makers so that their interests can be considered in the development of a nal EOBR rule. In doing so, drivers are more likely to develop favorable impressions that the EOBR rule has addressed their concerns, which will improve driver retention rates within the industry. Public policy makers may also nd this model of value. Given the vast size and complexity of the industry in terms of both employees and carriers, public policy makers face signicant resource challenges associated with enforcing safety regulations. As described in the introduction, voluntary compliance models can be more effective in promoting compliance than the command-and-control approach because individuals are more likely to comply with rules when they are not monitored (Tyler et al., 2008). Policy makers could consider how this model can achieve greater compliance rates. This model is also informative to motor carriers. Some motor carriers are rapidly adopting advanced vehicle management technologies that enable company ofcials to: . regulate commercial driver speed; . monitor and analyze braking behavior; and . track truck driver driving practices. Undoubtedly, these advanced technology and safety practices may raise driver privacy and technology concerns, and this voluntary compliance model may offer insight as to how to ameliorate driver apprehension. While this study represents the rst development of a voluntary compliance model applied to a proposed government safety technology mandate, there are several future research opportunities. As proposed in this study, there are several links between the procedural justice concerns of commercial drivers and this procedural justice model. Future research should explore in more detail the empirical relationship of these links using survey data. In particular, further research could glean important insights on how extensively each of these factors contributes to perceptions of procedural justice in terms of neutrality, trust, and social standing. It is also important to empirically test

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the linkages among the procedural justice, voluntary compliance, and turnover intention constructs. Scholars should examine these empirical relationships initially within the motor carrier industry regarding the EOBR rule. Future research could also uncover procedural justice differences by empirically testing this model in regulatory settings outside of the motor carrier industry, including in the US airline industry and US retail industry[6]. It is also important to expand this model to operations management settings where adhering to safety standards and policies is also valued. Future research could test this model in a manufacturing setting whereby it is important for line workers to comply with organizational safety practices.
Notes 1. Moorman (1991) explains that distributive justice reects that one expects to be allocated a fair reward (output) for the inputs that he or she provides to an organization or society. 2. As pointed out by one reviewer, logbook data is used for enforcement by motor carrier regulators whether it is electronic or manual. 3. The Federal Register is published by the Ofce of The Federal Register, National Archives and Records Administration. It is the ofcial daily publication for rules, proposed rules, and notices of federal agencies and organizations. 4. The Global Insight (2005) reports that in 2004 the US motor carrier industry was composed of 95 percent male drivers. The Global Insight (2005) study also described that 44.5 percent of commercial drivers are between the ages of 45 and 64. The American Trucking Associations (ATA, 2010) reports that most individual long-haul drivers average from 100,000 to 110,000 miles driving per year. The ATA (2010) study also reported that the average length of haul for an over-the-road driver is nearly 500 miles. The Owner-Operator Independent Drivers Association (OOIDA) association estimates that owner-operators comprise about one-third of the total USA for-hire carrier eet. 5. As pointed out by a reviewer, when there is a good economic climate drivers are lost to construction projects; in poor times, the movement is back to the carriers. For over 15 years the larger national carriers have experienced driver shortages; consequently, rms such as JB Hunt and Schneider National have sought to put long-distance hauls on railcars as container on at car or trailer on at car moves. This enables them to retain drivers for shorter hauls where there is a better quality of life. 6. One reviewer points out that there is a close parallel between the EOBR issue and commercial drivers, and pilots in the US aviation industry. Specically, pilots at more progressive airlines have been given laptop-based preight checklists in order to both relieve them of the manual task, but to also improve the accuracy of checklist completion. Admittedly, these were not government mandated, but going through the preight checklist is.

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Further reading Cantor, D.E., Corsi, T.M. and Grimm, C.M. (2008), Determinants of motor carrier safety technology adoption, Transportation Research Part E: Logistics and Transportation Review, Vol. 44E No. 5, pp. 932-47. Corsi, T.M. and Fanara, P. (1988), Driver management policies and motor carrier safety, Logistics and Transportation Review, Vol. 24 No. 2, pp. 153-64. Dillman, D.A. (2000), Mail and Internet Surveys: The Tailored Design Method, 2nd ed., Wiley, New York, NY. Haffenden, C. and Yeomans, K. (2007), Technology boosts carriers performance, Occupational Health and Safety, available at: www.ohsonline.com/articles/50657/ (accessed 20 October 2007). McElroy, J.C., Rodriguez, J.M., Grifn, G.C., Morrow, P.C. and Wilson, M.G. (1993), Career stage time spent on the road, and truckload driver attitudes, Transportation Journal, Vol. 33 No. 1, pp. 5-15. Russell, D. (1982), The causal dimension scale: a measure of how individuals perceive causes, Journal of Personality and Social Psychology, Vol. 42 No. 6, pp. 1137-45. Suzuki, Y., Crum, M.R. and Pautsch, G.R. (2009), Predicting truck driver turnover, Transportation Research. Part E: Logistics and Transportation Review, Vol. 45 No. 4, p. 538. US Department of Transportation (2005), Hours of service; nal rules: 49 CFR Parts 385, 390, and 395, Federal Register, Vol. 70 No. 164, pp. 1-97. About the authors David E. Cantor is an Assistant Professor of Logistics and Supply Chain Management at the College of Business, Iowa State University. He received his PhD in Supply Chain Management from the University of Maryland. David E. Cantor serves on the Editorial Review Board of the Journal of Supply Chain Management. David E. Cantors primary research interest is in supply chain management and information systems. His secondary area of research interest is in human decision making in the supply chain. His research has been published in the Journal of Business Logistics, Journal of Operations Management, Transportation Journal, Transportation Research Part E: Logistics and Transportation Review, and International Journal of Logistics Management. David E. Cantor is the corresponding author and can be contacted at: dcantor@iastate.edu Marianick Terle is a Marketing Assistant for a consulting company in Lyon, France. She graduated from a Masters Program in Aix-en-Provence, France. She also earned an MBA from the Coggin College of Business at the University of North Florida. Marianick Terle worked as a Research Assistant for David E. Cantor while completing her MBA degree. Her primary interest is in the eld of marketing. She specializes in e-marketing consulting. Marianick Terle is also interested in new e-commerce technologies.

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