3. TIM Tactical Program Elements

3.1 Introduction

The impact of traffic incidents on highway operations and safety is well documented as noted in the following citations:

• According to the Texas Transportation Institute (TTI), in 2007, congestion in the top 85 U.S. urban areas caused 4.2 billion hours of travel delay and 2.9 billions gallons of wasted fuel, for a total cost of $78 billion.[42]
• The National Traffic Incident Management Coalition (NTIMC) estimates that one-quarter of the traffic congestion in the United States is caused by non-recurring traffic incidents.[43] For every minute that an Interstate lane is blocked during peak congestion, 4 minutes of travel delay result.[44]
• The Bureau of Labor Statistics of the U.S. Department of Labor reported that between 2007-2008, 345 workers were killed in struck-by vehicle incidents,[45] and an indication of the dangers emergency responders face in managing traffic incidents.

At the center of every Traffic Incident Management (TIM) Program is the operational activities that occur at the incident scene to quickly, safely, and efficiently clear the incident and restore traffic flow. Strategic program elements (chapter 2) provide the multi-agency planning, programming, and evaluation necessary to support efficient and collaborative on-scene operations. Supporting technical elements (chapter 4) provide the tools and technologies for traffic management and inter-agency communications for on-scene operations.

Regardless of the level of program advancement in Strategic and Technical functions, Tactical operations practices, procedures, and protocols must be followed to expedite scene response and clearance to promote safety of incident responders and motorists. As described in chapter 2 (section 2.2.3), the NTIMC has described goals and strategies for responder safety: safe, quick clearance of incident scenes, and interoperable communications through the National Unified Goal (NUG).

Significant investments made at all levels of government work to improve incident management and responder safety. This chapter discusses new developments in tactical operations, including:

• Response and clearance policies and procedures.
• Responder and motorist safety.

3.2 Response and Clearance Policies and Procedures

Since the very first traffic incident, there has been traffic incident response. Over time, policies and procedures have been defined and refined to clarify and coordinate responder roles and responsibilities, expedite scene clearance, and maximize traffic flow around the incident scene. As these adjustments occurred, responders came to realize that working through a formalized structure, i.e., TIM programs, would accelerate the process. TIM program evolution has led to changes in the following areas, described in more detail within this chapter:

• Responder Roles and Responsibilities.
• Incident Command System/Unified Command.
• Resource Typing and Identification.
• Fatal Incidents.
• Safe, Quick Clearance Laws and Policies.
• Full-Function Service Patrols for Incident Response.

3.2.1 Responder Roles and Responsibilities

Chapter 1 identifies and separates TIM stakeholders into four discrete categories: traditional responders; special/extreme circumstance responders; incident information providers; and transportation system providers and users. Table 12 lists the stakeholders identified in each of the four categories. While all the stakeholders cited are involved in TIM, this chapter focuses on the roles and responsibilities of the traditional and special/extreme circumstance responders listed in Table 12.

Table 12. TIM Stakeholder Roles and Descriptions

Traditional Responders	Special/Extreme Circumstance Responders	Incident Information Providers	Transportation System Providers and Users
Public Safety Communications	Hazardous Materials Contractors	Traveler Information Services	Traveling Public
Law Enforcement	Hazardous Materials Contractors	Traveler Information Services	Traveling Public
Fire and Rescue	Coroners and Medical Examiners	Traffic Media	Trucking Industry
Emergency Medical Services (EMS)	Coroners and Medical Examiners		Insurance Industry
Towing and Recovery	Emergency Management Agencies	Transportation Agencies	Public Transportation Providers
Transportation Agencies	Environmental/Natural Resources/Departments of Health (DPH)	Transportation Agencies	Motorist Organizations

Since each incident is different, the sequence of individual responder actions depends upon a variety of factors, such as who arrives first on scene, the severity of the incident, and the surrounding traffic conditions, among others. Additionally, incident responders' actions are heavily interrelated, and generally are not limited to one specific responder group. There are a number of guidance documents and training courses available that can provide more detailed definitions and instruction on traffic incident responder activities (see "Want to Know More?" at the end of this chapter).

Traditional Responders

The following information describes the on-scene actions conducted by the traditional responders:

• Emergency 911 (E911) Dispatchers: E911 personnel are normally the first responders to have knowledge that an incident has occurred. The mission of dispatchers is to quickly, accurately, and completely convey the necessary information to the proper agencies and field personnel to get the right personnel and equipment to the scene as quickly as possible. E911 personnel normally begin the data collection on an incident by recording information in a Computer-Aided Dispatch (CAD) system.
• Law Enforcement: In many cases, law enforcement is the first to arrive at the incident scene. Upon arrival, the first officer on scene assesses the situation and calls for additional resources (fire, EMS, and towing and recovery, among others) as needed. The officer secures the scene for responder and motorist safety, and conducts traffic control as necessary. Law enforcement also conducts scene investigation and/or evidence collection as dictated by the incident scene and severity.
• Fire and Rescue: In some cases, fire and rescue personnel may be the first responders to arrive at the incident scene. Upon arrival, fire and rescue personnel secure the scene to protect responders and motorists. Upon securing the scene, these personnel assess injured parties, and if warranted, request EMS support. Fire and rescue personnel provide first aid until EMS personnel to arrive (if requested). Fire and rescue personnel address any fire or potential fire hazards and assist in scene recovery. In most locations, they also assess the scene for hazardous materials (HM) and notify remediation or clean-up contractors, as needed.
• Emergency Medical Services: The primary responsibility for EMS is to assess injuries, administer triage on-scene as needed, and remove injured parties quickly to medical facilities for additional care. In those areas of the country where EMS is a fire-based function, the fire and rescue personnel provide EMS functions.
• Towing and Recovery: The towing and recovery personnel primarily remove disabled vehicles, clear incident debris, and clean up spilled cargo.
• Transportation Agencies: Within transportation agencies, it is the operational sections—Traffic Management Centers, maintenance field staff, and Service Patrols—that play a critical role in TIM. TMCs serve as the hub for the collection and dissemination of incident information and play a critical role with incident detection and verification. At the incident scene, transportation agency responders focus on temporary traffic control, expedite scene clearance, and restore traffic flow. Transportation agency responders include maintenance personnel and specialized traffic incident responders, such as maintenance and service patrol personnel (see section 3.2.6).

Special/Extreme Circumstance Responders

The following specialized responders are required when the incident scene is more severe; when it involves fatalities, spilled cargo, or the release of hazardous materials; and/or when the incident is part of a larger manmade or natural disaster:

• Hazardous Materials Contractors: When the incident scene involves HM that require response and cleanup beyond the capabilities provided by fire and rescue resources, specialized HM contractors are dispatched to the incident scene. Their primary responsibility is to remove the HM and mitigate additional risk from the continuous release of material into the environment.
• Coroners/Medical Examiners: When incidents involve fatalities, coroners/medical examiners are called to the incident scene. A number of jurisdictions have enacted policies that allow the removal of the deceased by designated personnel to other locations before the coroner/medical examiner arrives at the scene to facilitate incident clearance and preserve the body from loss or destruction, or for prospective organ donation (see section 3.2.4).
• Emergency Management Agencies: When the scope and severity of an incident dictates, State and local emergency management agencies may be called upon to direct and/or participate in incident response as part of the overall response to major emergencies. These types of responses are precipitated by man-made or natural disasters, such as weather events, fire, earthquakes, floods, and so forth.
• Environmental/Natural Resources Agencies: State and local environmental and natural resources agencies are deployed to provide technical assistance, assess impacts, and recommend mitigation strategies for both hazardous and non-hazardous related cargo releases.
• Departments of Health: When an incident involves medical waste, the DPH is called to the scene to identify whether or not medical waste is infectious. DPH is also called to the scene to identify medical radiological materials and respond to incidents involving food, drugs, or cosmetics to decide if the material should be destroyed or if it can be recovered by the owner. DPH can assist with proper disposal options for any of the above-cited materials.

3.2.2 Incident Command System/Unified Command

How responders execute their respective roles and responsibilities at the incident scene is a major factor that contributes to the successful, safe, and quick clearance of the scene. As defined in the National Incident Management System (NIMS), the Incident Command System (ICS) provides a framework for responding to all emergencies, and must be used and understood by all parties at the scene of an emergency. Incident Command System The ICS is a well-established, standardized on-scene process for managing incident response activities. The ICS was developed in the 1970s to manage rapidly moving wildfires where response activities were adversely impacted by:

• Too many individuals reporting to one response commander.
• Lack of interoperable communications and lack of reliable information.
• Different organizational structures between emergency response agencies.
• Lack of structure for coordinating response activities and lack of authority over response activities.
• Lack of a common terminology between agencies.
• Differing and/or unclear incident response objectives.

In 2003, the President of the United States charged the U.S. Department of Homeland Security (DHS) with developing and administering NIMS. Designed to improve incident response in a post-September 11th environment, NIMS builds upon and helps to integrate existing Federal, State, and local incident and emergency response systems to advance a nationwide framework for responding to incidents at all levels. Rather than circumvent the existing incident and emergency response processes and protocols, NIMS promotes a common language and uses a systems approach to integrate existing best practices into a unified, national framework.

As a key component of NIMS, ICS is used as the key strategic incident command structure. The rationale is that ICS provides a flexible, yet standardized approach for incident command, and that "ICS defines the operating characteristics, interactive management components, and structure of incident management and emergency response organizations engaged throughout the life cycle of an incident."[46]

NIMS defines five major functions for the ICS, as shown in Figure 3[47] and summarized below:

• Command: In an incident command organization, the Command Staff consists of the Incident Command (IC) and various special staff positions:
  • Incident Command: Responsible for management and control authority over an incident, including setting incident objectives and ensuring that all responding entities meet these objectives.
  • Public Information Officer (PIO): Interfaces with the public and media and/or with other agencies with incident-related information requirements, and monitors public information.
  • Safety Officer (SO): Responsible to the IC for the set of systems and procedures necessary to ensure emergency responder safety, as well as the general safety of Incident Operations. The SO has emergency authority to stop and/or prevent unsafe acts during incident operations. In a UC structure, a single SO should be designated and assigned responsibility across all participating agencies.
  • Liaison Officer: Point of contact for representatives of other governmental agencies, nongovernmental organizations, and/or private entities.
• Operations: Responsible for all tactical operations.
• Planning: Assists with the development of the Incident Action Plan (IAP), maintains resource use and situation status, and provides technical resources needed to particular aspects of incident response activities.
• Logistics: Provides personnel, facilities, and materials support to the entire incident response effort.
• Finance and Administration: Tracks costs and accounts for reimbursements.[48]

Figure 3. Incident Command Structure.

Incident Command

IC represents a function, not a person, and is responsible for all aspects of incident response including management of public affairs, health and safety, and liaison activities within the incident command structure. Command determines the size and structure of the ICS organization needed to respond to an incident and makes all decisions with respect to the need to implement all aspects of the ICS. As noted in the Simplified Guide to the Incident Command System for Transportation Professionals,[49] Command considers the following three priorities when identifying assisting agencies and structuring the ICS organization:

• Life Safety: Protects emergency responders, any incident victim, and the general public.
• Incident Stability: Minimizes an incident's impact on the surrounding area, maximizes response efforts, and ensures efficiencies in using resources.
• Property Conservation: Minimizes damage to property while still achieving established incident objectives.

Typically, the ranking first responder will assume IC function with overall incident management responsibility. The first responder may well be a Department of Transportation (DOT) unit member if that unit arrives on scene first, even if that person is not fully qualified to command emergency units.[50] In general, the IC function is assumed by law enforcement and/or fire personnel once those units arrive on scene. Some States have statutory mandates identifying which agencies may assume IC, or for liability reasons, prohibit DOT personnel from assuming command.

The NIMS notes that a single IC structure should be used when an incident occurs within a single jurisdiction, and there is no jurisdictional or functional agency overlap. This function is frequently handled by the Incident Commander.

Under the IC function, the Incident Commander:

• Has the authority to assume command.
• Knows agency policy.
• Ensures incident safety and establishing response priorities.
• Establishes an incident command post.
• Initiates and controls communications, and approves information released through the PIO.
• Determines incident objectives and strategies to be followed and approves, implements, and evaluates the IAP.
• Coordinates traffic management and control operations.
• Approves resource requests.
• Oversees incident demobilization and reporting.[51]

Unified Command

When multiple jurisdictions or agencies are involved, Unified Command (UC) is one method of conducting the IC function within the ICS organization structure for incident management. As stated in the Simplified Guide to the Incident Command System for Transportation Professionals,[52] UC is recommended as the command structure when an incident response activity:

• Involves two or more responding agencies within a jurisdiction that each has a functional responsibility for a major tactical activity related to incident response (e.g., traffic control, medical attention, or crash investigation).
• Impacts more than one political or legal jurisdiction (for example, a municipality and a county, or a municipality and a State), and requires response by multiple agencies from the same discipline (for example, county and/or municipal fire department, or State and/or local police).

UC differs from the sole incident command structure in that the IC function is handled by multiple participating agencies, and not a single Incident Commander. UC has the same Command function responsibilities as does a single IC, but uses a different organizational structure to implement these responsibilities.

Each responder agency designates an official responsible for specific disciplines to serve as the agency's representative to the UC, and the UC, as a whole, establishes common objectives and strategies for incident response. DHS, in NIMS, describes the UC structure as:

…one where the individuals designated by their jurisdictional authorities (or by departments within a single jurisdiction) jointly determine objectives, strategies, plans, and priorities and work together to execute the integrated incident operations.[53]

UC differs from a single command structure, where the IC establishes incident management objectives and strategies, and is directly responsible for ensuring that all functional area tasks are conducted to meet the objectives and strategies.

The UC should strive to set its mitigation goals and Incident Action Plan through consensus. However, statutory requirements as established by State General Laws may warrant an agency having the overriding lead authority within Unified Command. The responsibilities outside of the Fire Departments normal purview such as highway site safety and traffic control shall continue to be the responsibility of the State Police. Issues and decisions related to lane closures and site safety shall be made jointly by the appropriate agencies throughout the UC. However, the final decisions as they relate to traffic management are the responsibility of the UC.

The initial responder to the incident establishes the command post for the IC. The other responding agencies accomplish their jurisdictional responsibilities based on the goals set by Unified Command (Figure 4). Depending on the size of the incident or event, the IC may assign a command staff to provide services for the entire organization. The proper "mix" of responding agencies within a Unified Command structure depends on the location and nature of the incident.

While the UC generally makes decisions based on a consensus of the agencies included in the UC, the lead agency can make a final decision on any issue that the UC is not able to resolve on a consensus basis. This "lead agency" status may change as particular activities take priority during the course of incident response and as the IAP is executed.

The UC is intended to function as a flexible and adaptable structure that is adjusted based on incident response needs and offers a number of advantages for managing transportation incidents:

• UC provides a common organizational structure that enables agencies to understand joint priorities and restrictions and the specific functional responsibilities of each agency. Each agency also is able to understand the legal authority of other responder agencies, thus avoiding compromise or neglect of each authority.
• By jointly developing the IAP, UC enables agencies to develop a single set of objectives and strategies for responding to an incident, to avoid duplication of effort, and to coordinate the efforts and resource deployments across all responder agencies.
• Agencies are able to establish a single command post for the UC, which helps support the unified planning process, as well as the flow and coordination of information between agencies and jurisdictions involved in the response.

Relationship between UC and ICS

The National Response Team's (NRT) ICS/UC Technical Assistance Document summarizes the relationship between UC and ICS as:

…the UC replaces the Incident Commander function and becomes an essential component of an ICS. In this way, the UC provides the organizational management tool to facilitate and coordinate the effective involvement of the various agencies; it creates the link between the organizations responding to the incident and provides a forum for these agencies to make decisions with which all responders can agree.[54]

Figure 4 presents the relationship between a UC and the ICS.[55] The Command function is comprised of the multiple responder agencies—Federal, State, local—that meet the criteria of having a functional responsibility for a major tactical activity. Otherwise, the organizational structure is the same and the command staff and sections have the same duties and responsibilities as under the ICS. The Simplified Guide to the ICS for Transportation Officials[56] states that the Operations Section Chief designation must be a unanimous decision by the UC, and further notes that an On-Scene Coordinator (OSC) is drawn from an agency designated as the lead agency.

Figure 4. Unified Command Organization Structure.

IC and UC Preparation and Implementation

Advance planning and ongoing practice and training are critical to the successful implementation of the IC and UC. Each agency needs to know and understand in advance the roles and responsibilities of the other responder agencies. The NRT identifies four key issues that must be addressed to have an IC structure through UC:

• All responder agencies should learn ICS and the roles IC and UC have in ICS.
• Responder agencies should conduct the necessary advance planning to define the roles and responsibilities of each responder agency, and to include guidance on when and how to implement IC and UC:
  • The structure must be agreed to by all responder agencies, and ICS functions and responsibilities should be well defined.
  • Individuals should be designated for each function, with a reporting mechanism put in place.
  • Contingency plans should be in place.
• All responder agencies should understand the criteria and conditions necessary to implement UC as early as possible in the incident response process to avoid unnecessary delay and confusion.

A Unified Command Example

The following hypothetical example captures components of incidents that actually have occurred on the highway systems throughout the United States:

Two passenger vehicles are involved in a collision. One driver is not injured and is able to get out of the damaged vehicle. The other driver is severely injured and needs to be extricated from the vehicle. Responders to the incident include a fire department and an EMS responder, law enforcement, a DOT Service Patrol and the local news media.

Law enforcement is the first to arrive at the incident and immediately implement the procedures for UC: The incident involves multiple responders that have a functional responsibility for a major aspect of the incident, a criterion for implementing a UC:

• Law Enforcement: Secures incident scene; first responder; crash investigation; traffic control.
• Fire Departments: Rescues/extricates victims; contains/mitigates a HM release; protects incident scene.
• EMS: Provides medical treatment to injured parties at the scene; transports victims for additional medical treatment; determines destination and transportation requirements for injured victims.
• DOTs: Protects incident scene; provides traffic information; develops and operates alternate routes; implements traffic control strategies.

The UC for this incident[57] includes representatives from law enforcement; the fire department and EMS; and the transportation agency. As noted, each agency has functional responsibility, and is able to provide assistance (resources, personnel) to support incident response operations. Each agency also is responsible for a major component of the command or coordination efforts involved the incident response activities.

A contracted tower who arrives on scene to remove the damaged vehicles is not included in the UC. This is because the tactical activities are directed by agencies already represented in the UC. The contracted tower's input into response activities is provided to the respective UC representatives, and the tower's role in the response activities are defined as "technical specialist".

Initially, law enforcement is designated as the "lead agency" within the UC, since it meets the requirement of primary mission. However, as the IAP is implemented and incident response activities change, the "lead agency" designation moves to other agencies as different tactical activities take priority during the response process.

3.2.3 Resource Typing and Identification

ICS and UC provide the structure and framework for incident responders to execute their respective roles and responsibilities. As described in chapter 2, another key NIMS component is Resource Management, in which the necessary resources are identified for incident response (Strategic) and their deployment as appropriate to the incident (Tactical).

NIMS specifies 120 resource typing definitions, which are described as "the categorization and description of response resources that are commonly exchanged in disasters through mutual aid agreements."[58] The standard resource typing definitions help incident responders "speak the same language" when requesting or deploying the resources needed by using common terminology. Formally documented definitions for response terminology help agencies identify, locate, request, order, and track response resources located outside the individual agency's jurisdiction. Knowing and using the common terminology helps responders to move resources quickly and effectively to the jurisdiction that needs them.

More specific to traffic incidents, standard resource typing definitions include:

• Identifying towing and recovery resources with operator capabilities and equipment availability.
• Identifying HM response contractors with operator capabilities and equipment availability.

It is essential to identify and correctly deploy towing and recovery resources according to operator capabilities and available equipment when responding to incidents involving commercial vehicles. Since not all towing and recovery operators invest in the equipment necessary to upright or remove large commercial vehicles, precious response and clearance time is wasted when the wrong resources are sent to these incidents.

To address this issue, the Towing and Recovery Association of America (TRAA) produced and disseminates a Vehicle Identification Guide. The Guide provides law enforcement and other first responders with necessary information for a towing and recovery operator (disabled vehicle type, size, number of axles, how vehicle is positioned, and so forth) to determine the correct equipment to dispatch for the tow.[59]

3.2.4 Fatal Incidents

When an incident involves one or more fatalities, protocol dictates that additional steps are taken to protect and preserve the incident scene for criminal investigation, and to respect the rights of the deceased and their families.

National Cooperative Highway Research Program (NCHRP) Synthesis 318 found that "…73% of jurisdictions require that medical examiners or coroners respond to the site of a fatal crash before the deceased can be removed."[60] The notification and response time for a coroner or medical examiner may be lengthy if that person is attending to other duties at some distance from the incident scene. The increased time creates additional congestion and safety hazards for incident responders and motorists. The longer an incident scene is in place, the greater the likelihood for secondary crashes.

Therefore, many States are implementing laws, policies, and procedures that take into account all activities that must be done for crime scene investigation, including dealing with the deceased, as well as expediting scene clearance. These combine quick clearance and hold harmless provisions that address the removal of a fatality from an incident scene where the location obstructs or presents a hazard to the normal flow of adjacent traffic.[61]

Texas is an example of a State that has legislatively addressed the movement of a body in a fatal accident. The statutory language, found in the Texas Code of Criminal Procedure, chapter 49, section 25, part 8, states that:

When any death under circumstances set out in Section 6 shall have occurred, the body shall not be disturbed or removed from the position in which it is found by any person without authorization from the medical examiner or authorized deputy, except for the purpose of preserving such body from loss or destruction or maintaining the flow of traffic on a highway, railroad or airport.[62]

The Washington State Patrol (WSP) and the Washington State Department of Transportation (WSDOT) have executed a series of memoranda with County Coroner's Offices, titled, Guidelines for Off-Site Removal of Deceased Persons at Collisions, which establish the procedures under which a body may be moved after a fatal accident. One example is found in the agreement reached among the WSP, WSDOT, and Skagit County:

During these investigations, it is important to balance the need to conduct thorough investigations with the need to respect the dignity and privacy of the deceased and the deceased's family. It also is important to prevent on-lookers from viewing the deceased whenever possible and to restore the flow of traffic as soon as possible.[63]

The State of Georgia Open Roads Policy contains similar language:

Once the police investigator has completed taking photos of the deceased person(s) and the incident scene, the Office of Medical Examiner agrees to the movement of deceased person(s) from the travel lanes. The movement of deceased persons may include ejected deceased persons and vehicles containing deceased persons to the shoulder of the roadway, to off ramps, accident investigation sites, or other safe areas off the travel lanes for completion of investigation to reduce the delays and secondary crashes associated with motorists slowing to view the incident scene.[64]

3.2.5 Safe, Quick Clearance Laws and Policies

Safe, quick clearance (SQC)[65] is defined as "…the practice of rapidly and safely removing temporary obstructions from the roadway,"[66] and should be a key feature of all responder actions. A number of States, regions, and localities have implemented SQC laws to assist traffic incident responders. Three core laws, in particular, provide a necessary foundation for facilitating the safe and expedited removal of traffic incidents:

• Driver Removal or "Move It": These laws require motorists involved in minor crashes, where the vehicle is drivable and there are no serious injuries, to move their vehicles out of the travel lanes to the shoulder or other safe area before initiating the exchange of insurance information, or while awaiting the arrival of law enforcement and/or a tow truck.
• Authority Removal: These laws provide authority (and generally immunity from liability) for designated public agencies to remove vehicles and spilled cargo from the roadway to restore traffic flow.
• "Move Over": Designed to protect incident responders and stranded motorists alike, Move Over laws require motorists approaching incident responders and vehicles to slow down and move over to an adjacent lane, when possible, to provide an increased safety buffer. (As Move Over laws are a key feature of responder safety, they are discussed in more detail in section 3.3 Responder and Motorist Safety).

Driver Removal or "Move It" Laws

A number of States have enacted laws that require motorists involved in a crash to move their vehicles out of a lane and off the road to avoid blocking traffic when:

• The crash has not resulted in any apparent injuries or fatalities.
• There appears to be only property damage.
• One or more lanes are blocked by the vehicles involved in the crash.

A number of States have made the Move It law applicable only when a crash occurs on a limited access highway, expressway, or multiple lane highway. Several States' laws include statutory language, which states that moving the vehicle does not affect the question of fault in the cause of the accident, nor is it to be considered evidence of leaving the scene of an accident. For example, following is the language of a Move It law contained in the Connecticut Statutes, Title 14, Section 14-262(d) and (e):

(d) Each person operating a motor vehicle who is knowingly involved in a crash on a limited access highway which causes damage to property only shall immediately move or cause his motor vehicle to be moved from the traveled portion of the highway to an untraveled area which is adjacent to the crash site if it is possible to move the motor vehicle without risk of further damage to property or injury to any person.[67]

(e) No person who acts in accordance with the provisions of subsection (d) of this section may be considered to have violated subsection (b [referring to the duty to 'at once stop']) of this section.

The Connecticut Statutes language captures the key components of State Move It laws:

• Law addresses crashes with property damage only.
• Law requires that the motor vehicle be moved from a traveled to an untraveled area adjacent to the crash site.
• Law includes the caveat that the move should be done if "it is possible to move the motor vehicle without risk of further damage to property or injury to any person".[68]
• Attaches no blame for the cause of the crash to the driver for moving the vehicle.

The Missouri Revised Statutes (chapter 304, section 151) requires that a driver of a vehicle involved in a crash make every reasonable effort to move the vehicle or have it moved as not to block the regular flow of traffic, except in the case of a crash resulting in the injury or death of any person. The law further provides that any person who fails to comply with the requirements may be subject to a fine.[69]

The Missouri Move It law captures the same key components as does the Connecticut law, and adds two additional provisions:

• The law requires that a motorist, if not able to move a vehicle, must make a reasonable effort to have the vehicle moved by a third party.
• The law also establishes a penalty for failure to comply—if convicted, a motorist is assessed a fine between $10 and $50.

Authority Removal

Authority Removal laws provide statutory authority for incident responders to move vehicles or other roadway obstructions out of lanes of traffic or from the shoulder when the vehicle is creating a hazard. The intent is the same as with SQC policies—the safe and fast removal of incapacitated vehicles, cargo, or other obstructions resulting from a crash to remove lane blockages, increase responder safety, and reduce the potential for a secondary incident.

NCHRP Synthesis 318 "Safe and Quick Clearance of Traffic Incidents" defines Authority Removal Laws as follows:

An authority removal law provides authorization to a predesignated set of public agencies to remove (1) driver attended disabled or wrecked vehicles and (2) spilled cargo or other personal property blocking a travel lane(s) or otherwise creating a hazard to the flow of adjacent traffic. For definition purposes, an "authority" represents a public agency authorized to remove or cause removal of vehicles under an authority removal law. Such agencies generally include State, county, and local law enforcement, in addition to State DOTs.[70]

A key provision of these laws is to provide responders with immunity from liability for any damage that results from moving a vehicle, vehicles, or cargo from a roadway. An example of this is shown in the State of Montana Statute establishing authority removal. The Statute includes a "good faith immunity" clause that holds a responder harmless from liability unless any damages are caused by gross negligence:

61-8-909. Good faith immunity. A person who renders assistance in an emergency that is life-threatening to the occupant of a wrecked, disabled, or abandoned vehicle or that is creating an immediate hazard on a public roadway or who renders emergency assistance as directed by a law enforcement officer or other emergency responder at the scene of a motor vehicle crash is immune from damages arising from acts or omissions related to the rendering of assistance unless the damages are occasioned by the gross negligence or by the willful or wanton acts or omissions of the person rendering the assistance.[71]

Many State Laws specifically indemnify responders and agents acting in good faith in the performance of their duties. Agents acting in good faith may include towing operators operating under the direction of a peace officer and/or under contractual obligation with a State to provide authority removal services. An example of this indemnification is also contained in chapter 6 of Title 49 of the Idaho Statutes (49-662), which states in part:

Neither the peace officer nor transportation department employee, nor anyone acting under the direction of the officer is liable for damage to the motor vehicle, cargo or debris caused by reasonable efforts of removal.

Authority removal laws also include provisions that address:

• The type and severity of an incident that is subject to authority removal laws.
• The type of highway facility that is subject to authority removal laws.
• The type of obstruction blocking lanes (i.e., vehicles or cargo), where responders have the authority to move the obstruction.
• A listing of the agencies granted authority to remove or direct removal of incident.
• Requirements on where to move vehicles and/or cargo that are obstructing traffic.
• Guidance on vehicle and/or cargo handling after removal from the roadway.
• Guidance on handling incidents involving commercial vehicles.

An example of a State statute that includes these provisions is found in the Tennessee Code Annotated, Title 54 – Highways, Bridges and Ferries:

Removal of vehicles, cargo, and other spilled property. The law provides that a vehicle, cargo, or personal property that is creating an obstruction or hazard to traffic may be immediately removed unless the crash involves injury or fatality.[72]

SQC Law Implementation Status

According to Move Over America, an advocacy group for this law, Maryland, Hawaii, and Washington DC are the only jurisdictions without a Move Over law. Approximately 60 percent of States have Move It laws in effect, while approximately 97 percent have enacted the Move Over laws. However, each of these laws covers a different aspect of assuring open roadways after an incident.

To advance safety and mobility on a national level, States should enact all three SQC laws. Additionally, outreach to incident responders and the motoring public is necessary to ensure that the laws are understood and demonstrated by compliance.

To successfully implement SQC laws, they must be incorporated into agency TIM programs, and the agencies involved with TIM have to establish policies and procedures guiding how SQC laws will be enforced. This may require the enactment of supporting regulations or inter-agency agreements governing incident response activities in support of SQC. States also may need to develop procedures and policies on how the laws will be enforced, and provide education and training to all responders so that they understand SQC laws.

The WSDOT and the Washington State Patrol (WSP) developed the "Joint Operations Policy Statement"[73] (JOPS) to govern all aspects of incident management. JOPS, which was first enacted in 2002, and revised in 2005, 2006, and updated in 2008, defines the roles and responsibilities of each agency for incident response teams, hazardous materials handling, service patrols, and tow truck handling. The JOPS also establishes specific performance targets for clearing incidents—90 minutes—and the process by which performance is measured.

By establishing the target of clearing highway incidents within 90 minutes and identifying the agencies involved in response activities, the JOPS accomplishes two key goals. First, the JOPS recognizes the inter-dependencies between all of the agencies involved in response activities and the multi-disciplinary nature of incident response activities. Second, the JOPS establishes the 90-minute target against which actual performance is measured. The JOPS requires that the agencies report on average incident response times and conduct report on incidents that were not cleared within 90 minutes.

The JOPS states that Incident Response (IR) on Washington State Highways has always been a partnership of WSP, WSDOT, local fire/EMS (Fire), the tow industry, the media, auto/truck/ insurance associations and the public. Washington's IR partners are working more closely together than ever before. Following is an excerpt with respect to the collaborative goal of within the partnership of regarding JOPS policy:

The WSP, Washington State Association of Fire Chiefs (WSAFC), and WSDOT will collaborate to safely clear highway incidents within our mutual goal of 90 minutes. This policy manage resources responding to, mitigating, investigating, and clearing highway lanes and ferry routes in order to minimize traffic disruption. means WSP, WSAFC, and WSDOT will effectively and efficiently.[74]

By identifying the participating agencies and setting a clearance target, JOPS has accomplished a means to establish accountability. Agencies are responsible to report on their performance and assess the effectiveness of SQC. The agencies also have the opportunity to identify necessary operational performance changes and institutional issues that need to be resolved. This is an excellent example of how a State has established communications practices and procedures to coordinate the roles and responsibilities of on-scene, multi-disciplinary responder personnel.

Implementing SQC Laws: The Need for Education and Outreach

The effectiveness of SQC laws, even where they have been enacted, is frequently adversely impacted by a number of issues such as:

• Concern for the political or legal viability of these laws by legislators.
• A lack of widespread awareness among implementers including the general public and insurance companies of these laws.
• A lack of understanding of the relationships between these laws by implementers sometimes due to ambiguity in the legislation or inconsistent enforcement.
• Potential conflicts between agency missions—the enforcement community may need to conduct a crash investigation and moving vehicles, cargo, and/or obstructions out of a lane or off the road may adversely impact an investigation.
• Highly entrenched traditional reactions by many drivers who have previously been advised to not move vehicles involved in an incident before law enforcement arrives and an investigation is conducted.

In the case of authority removal laws, there is concern and uncertainty over liability among implementing agencies. The concern of being held liable by a vehicle or cargo owner because of damage causes responders to refrain from using their ability to move vehicles and cargo expeditiously, even in localities with these laws in effect. USDOT support for safe and quick clearance is driven by the need to keep traffic moving, reduce the possibility of secondary incidents, and enhance responder safety. However, there may be times when these objectives conflict with the objectives of other representatives of the responder community.

Additional research has shown that the traveling public is not aware of and does not understand SQC laws. Founded in 2007 to promote national awareness and enactment of Move Over laws, the "Move Over America" campaign reports that at the time there were only seven States that did not have Move Over laws in place. However, even in States with these laws, 71 percent of people surveyed have not heard of them.[75] The Traffic Incident Management Self-Assessment (TIMSA) 2007 National Report states that:

… a number of assessments acknowledge that while a quick clearance policy exists, its utilization is minimal. The reasons cited are either a lack of well-defined procedures and policies for executing quick clearance or a lack of public understanding of Move It and Move Over, Slow Down laws (which is in fact a responder safety tool and not a quick clearance policy). The confusion over what constitutes a quick clearance policy continues to hinder any real analysis on progress in this area. Until more clarity on quick clearance exists among incident responders, with whom responsibility resides for execution of the policies, it is unlikely that the motoring public will achieve any greater understanding of their responsibilities in quick clearance (steer it, clear it, etc.).[76]

To further SQC across the country, a number of TIM stakeholder organizations have published guides, provided training, and deployed public outreach campaigns in promoting safe, quick clearance information, as identified in Table 13.

Table 13. TIM Stakeholder Organizations Promoting SQC Nationwide

Sponsor	Constituency	Approach	Description
National Traffic Incident Management Coalition (NTIMC): http://timcoalition.org/?siteid=41	Multidisciplinary professionals at all levels, which represent the Emergency Medical Services, Fire, Law Enforcement, Public Safety Communications, Towing and Recovery, and Transportation communities.	National Unified Goal (NUG) for Traffic Incident Management.	The 18 NUG strategies provide the framework for achieving the overall NUG goals of: 1) responder safety; 2) safe, quick clearance; and 3) prompt, reliable incident communications. The strategies provide for the development of multi-disciplinary recommended and accepted practices, policies, procedures and training.
I-95 Corridor Coalition: http://www.i95coalition.org/	Transportation professionals at all levels.	Quick Clearance (QC) Toolkit and Workshops.	Documents sample QC laws, policies, procedures, and best practices. The workshops are designed to present QC implementation best practices.
Nonprofit organizations, such as "Move Over America": http://www.moveoveramerica.com/	Motoring public, elected officials, and emergency responders.	"Move Over" video and Web site.	Provides downloadable video and information via Web site, including testimonial about a fallen officer killed by a vehicle while responding to an incident.
American Automobile Association (AAA)	Motoring public; elected officials.	Slow Down/ "Move Over America" campaign.	Public information and legislative campaign designed to reduce injuries and death among roadside workers and stranded motorists through enactment of and public outreach on Move Over laws.
State and local governments	Motoring public.	Many States have instituted their own outreach efforts, such as "Steer It or Clear It" in Houston, Texas.	Provides downloadable video, press releases, and other outreach materials to raise awareness of existing SQC laws.
International Association of Chiefs of Police (IACP): http://www.theiacp.org/	Law Enforcement	Law Enforcement Stops & Safety Subcommittee (LESS)	The 2006 Staff Report[77] contains four chapters of original evaluation research by LESS members: Move Over laws. Officer Visibility. Vehicle Emergency Warning Systems. Vehicle Positioning and Officer Approach.

Safe, Quick Clearance and the Trucking Industry

Consensual towing refers to the ability of a consumer to negotiate and establish the terms and conditions, including pricing, for a tow service. Non-consensual towing indicates that the consumer has not enjoyed these same privileges. The need to quickly remove damaged vehicles from the roadway necessitates that it is the governmental agencies that will enter into service agreements with towing and recovery based on capabilities, geography, and regulated pricing. The vast majority of incident scene towing is non-consensual.

TIM administrators should be cognizant of the fact that the trucking industry has expressed concern with the scope of authority removal laws.

Obtaining industry involvement is recommended with developing authority removal laws is best done by involving the trucking industry, through the State trucking association or other industry groups, in the development of authority removal policies and regulations. These discussions should include Towing and Recovery capabilities to guarantee that only the most qualified companies are used to remove damaged commercial vehicles and cargo quickly and efficiently from the roadway. The importance collaborative efforts is recognized by the trucking industry as documented in a white paper prepared for the ATA Litigation Center's 2008 Forum for Motor Carrier General Counsels:

It is imperative for the trucking industry to monitor the non-consensual towing area and to seek to assist governmental agencies with implementation of non-consensual tow programs. There have been important and ground-breaking initiatives in this regard where State motor carrier associations have worked with State Departments of Transportation to develop non-consensual tow programs that are fair and efficient. When these types of programs (where the State motor carrier association has worked with the State DOT to develop a fair and efficient program) are implemented, many of the problems currently found in non-consensual tow can be minimized or eliminated altogether.[78]

A number of States have implemented programs that address the concerns of the trucking industry, while at the same time ensuring safe, quick clearance. The Colorado Department of Transportation (CDOT) and the Colorado Motor Carrier Association developed the CDOT Heavy Tow Program along the I-70 corridor between Denver and Vail. Under the program, heavy tow units are staged at strategic locations along the I-70 corridor during high traffic flow conditions, or when storms are anticipated. When a Class 8 or commercial vehicle becomes disabled, the heavy tow unit in the area quickly responds and removes the vehicle to a safe haven at no cost to the trucking fleet (at this point, the fleet is then responsible to move the vehicle). The success in the first season of this program is documented in the data as lane clearance times were cut in half from previous seasons to an average of 27 minutes. The economic benefit is reported by CDOT at over a 20:1 return on investment on a program that cost the State approximately $500,000 to fund per year.[79]

Other jurisdictions have implemented incentive-based towing programs designed to award tow companies a cash award for expedited clearings. Examples include the Florida Turnpike Rapid Incident Scene Clearance Program[80] and the Georgia DOT's Towing and Recovery Incentive Program.[81] All programs require training/certified operators, timed response, and performance metrics.

The programs are similar in that the qualifying tow companies are awarded zones and there are designated quality standards for service. The target clearing time to open all travel lanes is 90 minutes from the time a tow company gets the notice to begin recovery. If this time allotment is met, a monetary bonus is paid to the tow company. An additional resource on innovative towing programs is the I-95 Corridor Coalition's Scanning Tour of Innovative Towing Programs.[82]

3.2.6 Full Function Service Patrols for Incident Response

Traditionally, Service Patrol programs have offered only motorist assistance[83]—in itself an important service to the public that frees police and other emergency response personnel to perform the activities associated with their primary missions. Over time, service patrol programs have matured from basic motorist assistance into more fully functional programs that are actively involved in incident response and management. As a result, Full Function Service Patrols (FFSP) have become a new generation of first responders, providing valuable public safety and protection services. In this new role, Service Patrol programs help keep incident scenes safe, clear incidents more quickly, and assist other emergency responders at incident scenes.

An FFSP's mission is an extension of the transportation agency's mission to maintain the safe and efficient flow of traffic on the roadways. To accomplish this mission, agencies devote large budgets and resources, which include the operation of FFSP programs.

The basic functions of an FFSP include a multitude of responsibilities. To help maintain traffic flow and safety, FFSPs aid in the prompt detection of incidents or disruptions to traffic; minimize incident duration; clear obstructions; improve scene safety; and prevent secondary incidents. As defined in FHWA's Service Patrol Handbook,[84] an FFSP will:

• Provide Incident response services, clearance resources, and free motorist assistance services 24 hours, 7 days-a-week.
• Provide operators that are highly skilled and specially trained in the following:
  • NIMS/ICS: IS-100, IS-200, and IS-700.
  • ATSSA – Traffic Control Technician.
  • Red Cross – First Aid and CPR.
  • Wreckmaster – Towing and Recovery Operations Specialists.
• Provide emergency temporary traffic control (TTC) at incident scenes.
• Design and equip FFSP vehicles to fully relocate a stalled or abandoned automobile or light truck from a highway to a safe location.
• Provide a frequency of highway coverage to support statewide incident clearance goals.
• Be fully integrated with regional TMC operations.
• Participate in incident debriefs or after-action reviews.
• Include typical services provided in many service patrol programs today:
  • Provide minor repairs and motorist assistance.
  • Remove debris.
  • Provide fuel.
  • Provide first aid.
  • Relocate vehicles out of travel lanes.
  • Assist emergency services at vehicle crash scenes
  • Reduce traffic congestion, improve travel time reliability, and improve safety on freeway and arterial systems.
• Include the following equipment:
  • Traffic control items.
  • First-aid items.
  • Vehicle-mounted dynamic message signs (DMS)
  • Gasoline.
  • Air compressors.
  • Communications equipment.
  • Basic tools.
• Consider including advanced optional equipment such as:
  • Defibrillators and medical supplies;
  • Fire, animal, and HM containment supplies.
  • Public address system with an external speaker.
  • Automatic vehicle location (AVL).

FFSP vehicles are equipped with incident response equipment such as cones, signs, and message boards for traffic control; and radios, cell phones, and computers for communication. The FFSPs typically carry other equipment to assist in containing and removing an incident and cleaning up after a crash or spill. Their primary duty at incident scenes should be to set up and maintain traffic control to protect incident responders and to provide safer flow of traffic past the incident scene. They also should be the extra set of eyes and ears on the scene for transportation management centers (TMCs).

FHWA encourages FFSP deployment in all major metropolitan areas in the United States, and recommends that FFSPs perform as 24/7 operations to provide ongoing incident management and response assistance, as well as traditional motorist assistance activities.

In some jurisdictions, service patrols known as "motorist assist" or "courtesy" patrols often are subject to budget cuts. These titles belie their vital operational and safety functions in incident response. Therefore, it is important to establish methods for quantifying costs and benefits, including customer feedback and operational information such as clearance times (integrated with other first responders) to document the true role of service patrols at incidents. However, most cost-benefit analyses do not take into account the cost savings to other governmental agencies that service patrols provide.

In its 2008 SMART SunGuide Annual Report, Florida District Four described the adverse effects in the Intelligent Transportation Systems (ITS) Program concerning its performance measurement of program effectiveness. The 4 percent drop from 2007 is based, in part, on a reduction of the District's service patrol (Road Ranger fleet) hours. Specifically, when the Road Rangers' service hours in Palm Beach and Broward Counties were reduced from 24/7 service to weekdays, 6 a.m. to 7 p.m. (13 hours) in September and October, respectively, the report's benefit-cost ratio analysis revealed the following statistics:[85]

• The response activity of the Florida Highway Patrol (FHP) increased 59 percent.
• Towing response from wreckers dispatched (in lieu of Road Rangers) increased 48 percent.
• During Road Ranger "off periods" in the fourth quarter of 2008 during which 3,863 incidents occurred, the average duration increased by 1 hour per incident. This equated to $47,370,230 in unrealized benefit to the motorists, as well as a 3 percent decrease to the FHP's annual clearance time measures.

As another example of quantifying cost savings to other State agencies, the California Freeway Service Patrol (FSP) is operated jointly by the California Highway Patrol (CHP), the California Department of Transportation (Caltrans), and the local transportation agency.[86] The FSP is a congestion management tool that removes disabling events quickly, thereby maintaining maximum traffic flow. There is a direct benefit to the CHP. Prior to the implementation of the FSP program when an officer was conducting a crash investigation or performing other law enforcement related activities, additional CHP resources had to be dispatched or redeployed to provide the services now being accomplished by the FSP. Both Florida and California provide examples of using "capable but not overly qualified" resources that allows another State resource to conduct tasks that they are uniquely qualified to conduct.

In some jurisdictions, there are service patrols that provide more than basic services, but less than the services provided by the FFSPs. The Georgia DOT's Highway Emergency Response Operators (HEROS) is a good example of a hybrid service patrol program that provides many of the services identified for an FFSP. The HEROS units patrol the Atlanta-area freeways 7 days a week, Monday through Friday, 5:30 a.m. to 9:30 p.m., and Saturday and Sunday, 9:30 a.m. to 9:30 p.m. The HEROS units also are on call to respond to incidents that occur outside of working hours, as necessary. HEROS personnel wear uniforms that identify them as Georgia DOT Incident Management Technicians and carry required identification that is provided to motorists as needed.

The HEROS respond to between 55,000 and 60,000 incidents and calls annually. The Georgia DOT TMC is responsible for dispatching HEROS units to traffic-related incidents. The HEROS are primarily responsible for reducing traffic congestion and delays, and provide support to law enforcement, first responders, and other emergency agencies during incident response activities. The HEROS also aid motorists by clearing stalled vehicles from travel lanes, and help resolve minor mechanical problems when they:

• Change flat tires.
• Jump-start batteries.
• Provide fuel, coolant, etc.
• Provide road and travel information.
• Provide transportation to safer areas.
• Provide courtesy use of a telephone.[87]

Figure 5 shows a mobile HEROS unit supplied with advance warning arrow panels to warn oncoming traffic about a disabled car on the right shoulder.[88]

Figure 5. Georgia DOT HEROS Unit.

The Service Patrol Handbook recommends that to be most effective, FFSPs:

1. Be part of an integrated TIM program that includes Memoranda of Understanding (MOU) between responder agencies, which outline roles, responsibilities, and incident response functions. FFSPs significantly expand DOT response capabilities, which may require revisions to incident response procedures. Any such changes need to be documented and included in inter-agency agreements.
2. Have a dedicated source of funding. This should include both capital funding for procurement of equipment and vehicle funding for operations. The Handbook does identify several States that have contracted for all or part of FFSP services or have engaged in public-private partnerships to spread costs.
3. Need well-trained staff. Providing the resources to train staff properly in incident response and emergency management techniques and procedures is critical to ensuring that FFSPs provide the anticipated benefit.
4. Need to be supported by management and elected officials. While the benefits offered by deploying FFSPs are substantial, the cost of 24/7 services and the associated staff, equipment, and vehicles need to be understood and accepted by all decision makers—agency and elected. Documenting, and if possible, quantifying benefits realized from the deployment of FFSPs is critical for obtaining this support.

3.3 Responder and Motorist Safety

The impacts of traffic incidents on responder and motorist safety are well documented as shown in the following citations:

• Data collected by the National Institute for Occupational Safety and Health (NIOSH) shows an upward trend in numbers of all types of workers killed as a result of being struck by vehicles. In 2005, NIOSH reported 390 workers killed in struck-by incidents, up from 278 in 2004, and up from an annual average of 365 over the 2000-2004 period. In 2005, struck-by incidents accounted for 7 percent of the total number of fatal occupational injuries.[89]
• The U.S. Fire Administration (USFA) reports that over the last decade for which complete figures were available (1996 to 2006), vehicle collisions claimed 227 firefighter lives, and another 52 firefighters were involved in struck-by incidents. Between 1996 and 2006, vehicle collisions/struck-by incidents accounted for 20 percent of all fatalities. In 2003, this figure jumped dramatically to 35 percent of all fatalities, with 34 firefighters killed in vehicle collisions and 5 struck-by vehicles. This trend continued in 2005, with 24 percent (25) of the 115 fatalities resulting from vehicle collisions, and 2006, with 21 percent (22) of fatalities resulting from vehicle collisions.[90]
• Information presented at the National Conference on Traffic Incident Management indicated that secondary crashes account for more than 20 percent of all crashes. The U.S. Department of Transportation (USDOT) estimates that 18 percent of the fatalities occurring on Interstates are due to secondary crashes.[91] Overall findings show that improvement in all aspects of TIM, especially in incident duration and responder roadside exposure, reduces the probability of secondary crashes. An additional finding states that TIM improvements promote a significant safety benefit as well.

This section discusses new developments in tactical operations designed to improve responder and motorist safety.

3.3.1 Move Over Laws

Move Over laws are one of three key safe, quick clearance laws (see section 3.2.5 Safe, Quick Clearance). Move Over laws protect incident responders by providing specific requirements for motorists' reactions when approaching an incident scene. These laws provide for an additional "buffer zone" between the emergency vehicle and traffic. When approaching a stationary emergency vehicle displaying emergency lights or amber lights In general, Move Over laws require that motorists must:[92]

• Change lanes into an available lane that is not adjacent to the stationary emergency vehicle, but only if a lane change can be made safely.
• Slow down and be prepared to stop if a lane change is not possible.

The laws specify that these actions be taken when no other traffic direction is being given by an enforcement officer.

Some State statutes include specific speed reductions. For example, Florida requires that motorists slow down by 20 miles per hour (mph) on roadways where the posted speed limit is 25 mph or greater, or slow down to 5 mph when the posted speed limit is below 25 mph, unless otherwise directed by a law enforcement officer. Most State statutes, however, specify that motorists simply slow down to a speed that is safe for the road, weather, and traffic conditions in and around the stationary emergency vehicle.

In general, State statutes establish the presence of an "authorized emergency vehicle" with flashing emergency lights as the threshold for when a vehicle is required to move over. Authorized emergency vehicles, whether defined in the prevailing statutes or another companion statute, include police, fire, and EMS vehicles. A number of States expanded the definition of emergency vehicles to include towing and recovery vehicles. Some States also include service patrols, highway maintenance vehicles, and even animal control vehicles within the definition of an "authorized emergency vehicle".

The Tennessee Code provides an example of a State statute that specifically defines highway maintenance and service patrol vehicles as emergency vehicles included in a Move Over law as found in Title 55, chapter 8, section 132:[93]

55-8-132. Operation of vehicles and streetcars on approach of authorized emergency vehicles.

(c) Upon approaching a stationary recovery vehicle or a highway maintenance vehicle, when the vehicle is giving a signal by use of authorized flashing lights, a person who drives an approaching vehicle shall:

(1) Proceeding with due caution, yield the right-of-way by making a lane change into a lane not adjacent to the stationary recovery vehicle or the highway maintenance vehicle, if possible with due regard to safety and traffic conditions, if on a highway having at least four (4) lanes with not less than two (2) lanes proceeding in the same direction as the approaching vehicle; or

(2) Proceeding with due caution, reduce the speed of the vehicle, maintaining a safe speed for road conditions, if changing lanes would be impossible or unsafe.

For further information on Move Over and related quick clearance laws, see the FHWA publication, Traffic Incident Management Quick Clearance Laws: A National Review of Best Practices.[94]

3.3.2 Protective Apparel

The use of high-visibility safety apparel by incident responders is a key element of enhancing responder safety at roadside.[95] Based on the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU) Section 1402 requirements, on November 24, 2006, the FHWA adopted regulations that require all "workers" within the rights-of-way of Federal-aid highways to use high-visibility safety apparel.[96] On November 21, 2008, the FHWA issued an Interim Final Rule modifying the 2006 rule to address concerns of firefighters working at incident scenes requiring other special protective equipment. The rulemaking, codified in Title 23 of the Code of Federal Regulations (CFR), Part 634, became effective November 24, 2008, which states:

§ 634.2 Definitions.
"Workers" means people on foot whose duties place them within the right-of-way of a Federal-aid highway, such as highway construction and maintenance forces; survey crews; utility crews; responders to incidents within the highway right-of-way; firefighters and other emergency responders when they are not directly exposed to flame, fire, heat, and/or hazardous materials; and law enforcement personnel when directing traffic, investigating crashes, and handling lane closures, obstructed roadways, and disasters within the right-of-way of a Federal-aid highway.

§ 634.3 Rule.
All workers within the right-of-way of a Federal-aid highway who are exposed either to traffic (vehicles using the highway for purposes of travel) or to construction equipment within the work area shall wear high-visibility safety apparel. Firefighters or other emergency responders working within the right-of-way of a Federal-aid highway and engaged in emergency operations that directly expose them to flame, fire, heat, and/or hazardous materials may wear retroreflective turn-out gear that is specified and regulated by other organizations, such as the National Fire Protection Association. Firefighters or other emergency responders working within the right-of-way of a Federal-aid highway and engaged in any other types of operations shall wear high-visibility safety apparel.

The use of high-visibility safety apparel is governed by the requirements of the International Safety Equipment Association's (ISEA) "American National Standard for High-Visibility Apparel" and the American National Standards Institute (ANSI) Standard 107-1999. The Manual on Uniform Traffic Control Devices (MUTCD) standard for high-visibility safety apparel[97] is based on these requirements, and much of the equipment in use is designed to the ISEA requirements and ANSI standard. The standard defines high-visibility safety apparel requirements for retroreflectivity, type of material, colors, and fluorescence. Figure 6 presents two samples of ANSI/ISEA-compliant Class II (sleeveless vest) and Class III (vest with sleeves) high-visibility apparel in appropriate colors with retroreflectivity and florescence properties.[98]

Figure 6. ANSI/ISEA Standard 107-Compliant Vests.
Source: Photo courtesy of Mr. Ronald Moore, McKinney Fire Department, McKinney, Texas.

ANSI/ISEA revised and updated the standard in 2004 and released ANSI/ISEA 107-2004. The new standard sets performance criteria and guidelines for the selection, design, and wearing of high-visibility safety clothing. The new standard defines three protective classes based on background material, retroreflective material, and design and usage requirements. The new standard also provides criteria to assist in determining the appropriate garment based on roadway hazards, work tasks, complexity of the work environment, and vehicular traffic and speed.[99]

The NTIMC also is actively involved in promoting the use of high-visibility safety apparel.[100] Working with ISEA, the NTIMC sought and successfully obtained a standard for a public safety vest designed to address concerns of public safety responders working at incident scenes. In 2007, ANSI/ISEA released a new standard, ANSI/ISEA 207-2006, American National Standard for High-Visibility Public Safety Vests. ANSI 107-2004 specifically prohibited the classification of sleeveless garments when worn alone. However, this standard did not meet certain special needs of responders, that of apparel that can fit over belt-mounted equipment and apparel that will tear away if caught on a moving vehicle. ANSI/ISEA 207-2006 establishes design, performance specifications, and use criteria for high-visibility vests and meets the special needs not addressed under ANSI 107-2004. It should be noted that ANSI 207-2006 does not replace ANSI 107-2004, and that the new standard is intended to primarily meet the needs of public safety response personnel.[101] Functionally, the public safety vest is a Class II garment.

3.3.3 Traffic Management / Vehicle Placement / Emergency Lighting

The primary goals of TIM-related traffic management, vehicle placement, and emergency lighting are defined in the following excerpt from MUTCD, chapter 6I:

An essential part of fire, rescue, spill clean-up, highway agency, and enforcement (Traffic Incident Management) activities is the proper control of road users through the traffic incident management area in order to protect responders, victims, and other personnel at the site while providing reasonably safe traffic flow.[102]

These same goals also are reflected in Objective 1 – Responder Safety and Objective 2 – Safe, Quick Clearance the TIM National Unified Goal developed by the NTIMC.[103]

The key issue here is that all partners involved in TIM activities and incident response are concerned with safety for responders and the traveling public, as well as the safe, quick clearance of incidents. Where consensus is still developing, however, is on how such key factors in incident response such as traffic management and vehicle placement should be accomplished.

The following subsections present a summary of practices recommended by TIM stakeholder groups for addressing these issues. The intent is not to recommend a particular approach but to enhance awareness that there are different recommendations regarding approaches, and that as of the publication date of the Handbook, there is no national consensus on these issues.

Traffic Management

Current DOT traffic management practices for TIM are based on MUTCD, chapter 6 (Temporary Traffic Control-TTC). The MUTCD defines a traffic incident as "an emergency road user occurrence, a natural disaster, or other unplanned event that affects or impedes the normal flow of traffic"[104] and establishes the structure for managing incident response activities.

MUTCD, chapter 6I (Control of Traffic through Traffic Incident Management Areas) describes three levels of traffic incidents: Major, Intermediate, and Minor.[105] A "Major Traffic Incident" typically requires closing all or part of the roadway for a period exceeding 2 hours. An "Intermediate Traffic Incident" typically affects travel lanes for a period of 30 minutes to 2 hours. When the use of traffic control is discussed, usually it is focused on these two incident types, which require the close coordination emblematic of mature TIM Programs.

A "Minor Traffic Incident" typically last no more than 30 minutes and does not require lane closures or extensive traffic control. This type of incident is handled by law enforcement, towing and recovery, or a service patrol alone or in combination.

A "Traffic Incident Management Area" (TIMA) is defined as an area of a highway where TTC is imposed by authorized officials responding to a road user incident, natural disaster, hazardous material spill, or other unplanned incident. The TIMA extends from the first warning device (such as a sign, light, or cone) to the last TTC device, or to a point where vehicles return to the original lane alignment and are clear of the incident. MUTCD, chapter 6I contains detailed guidance on the recommended size of a TIMA, depending upon road configuration, vehicle speed, and weather conditions.[106]

The MUTCD further establishes the primary functions of TTC at a TIMA: to move road users reasonably, safely, and expeditiously past or around the traffic incident; to reduce the likelihood of secondary traffic crashes; and to preclude unnecessary use of the surrounding local road system. Examples include a stalled vehicle blocking a lane; a traffic crash blocking the traveled way; a hazardous material spill along a highway; and natural disasters such as floods and severe storm damage.[107] Decades of research by transportation agencies and practitioners into the science and practical application of traffic control have led to "Typical Applications for Traffic Incident Management Areas". They have established an accepted and expected standard that emergency responders should meet.

Figure 7 presents a diagram that displays how an MUTCD-compliant TIMA should be established. Key elements of a TTC/TIMA include:

• Advance Warning Area: The advance warning area is that area of the highway where advance warning signs are placed to inform road users as they approach an upcoming incident area. Typical distances for advance warning sign placements on expressways and freeways should be longer because drivers are conditioned to uninterrupted flow. Since rural highways are normally characterized by higher speeds, the effective placement of the first warning sign also is substantially longer. Advance warning is provided by traffic control flaggers, DMS, and cone placement, and the key is to ensure that motorists receive adequate advance notice. Considerations with respect to the starting point for providing advanced warning depends upon traffic speed, weather conditions, roadway configuration, and user expectations. (For additional information, see section 3.4 Additional Resources, in particular, the MUTCD, chapter 6I, the USFA's "Traffic Incident Management Systems", and the Calgary Fire Department's "Emergency Traffic Accommodation" [authored by Battalion Chief Richard Elvey]).
• Transition Area: The transition area is that section of the highway where motorists are redirected from their normal path. The MUTCD provides guidance for the length of taper required and for the structure of multi-lane transitions. The MUTCD does state that longer tapers are not necessarily better than shorter tapers (particularly in urban areas characterized by short block lengths, driveways, etc.) because extended tapers tend to encourage sluggish operation and to encourage drivers to delay lane changes unnecessarily. The test concerning adequate lengths of tapers involves observation of driver performance after temporary traffic control plans are put into effect.
• Activity Area: The activity area is the section of the highway where the work activity takes place, and is comprised of the work space, the traffic space, and the buffer space. The "work space" is that portion of the highway closed to road users and set aside for workers, equipment, and material. The "traffic space" is the portion of the highway in which road users are routed through the activity area. The "buffer space" is a lateral and/or longitudinal area that separates road user flow from the work space or an unsafe area, and might provide some recovery space for an errant vehicle. Neither work activity nor storage of equipment, vehicles, or material should occur within a buffer space. When work occurs on a high-volume, highly congested facility, an incident management vehicle storage space may be provided so that emergency vehicles (for example, tow trucks) can respond quickly to road user incidents. When used, an emergency vehicle storage area should not extend into any portion of the buffer space.
• Termination Zone: The termination zone marks the end of the incident area and the location where vehicles are able to resume normal driving patterns and driving speeds.

In the following diagram, the TIMA begins at the first warning sign. General considerations must be given to the speed of the highway when placing the first warning sign. The higher the speed, the less time the motorist has to make decisions; therefore, the greater the need for a longer advance warning area. The same considerations are true for the taper in the transition area, and the need to close or block two 12-foot lanes requires twice the taper distance than one lane.

Advanced warning signs are placed off the shoulder of the roadway at an appropriate distance upstream from the point where the transition (taper) begins. On slower speed or urban roads, this distance is measured at four to eight times the speed limit in miles per hour (mph). The greater the speed limit, the greater the need for advance warning. Therefore, on high-speed roadways the first advance warning sign is placed 8 to 12 times the speed limit in mph.

When a piece of equipment, such as a response vehicle or arrow board, is considered for use at this incident scene, the equipment is positioned at the shoulder and at the beginning of the taper. It is important to note that the start of the taper is in the shoulder lane, and not in a travel lane.

Figure 7. MUTCD Traffic Incident Management Area.
Source: Diagram courtesy of Mr. Ronald Moore, and the McKinney Texas Fire Department's "Safe Parking" Training course, McKinney, Texas.

A flashing arrow board or lighted vehicle helps draw the motorist's immediate attention to the start of the taper. The taper length is a combination of the speed in mph of the roadway and the distance in feet at which traffic is required to merge. Although various formulas exist within the MUTCD and are dependent upon the speed of the roadway, for illustrative purposes here, the length of a typical taper is speed times width. Channelizing devices, such as cones, are placed no more than the speed of the roadway measured in feet apart, i.e., no more than 55 feet apart when the speed limit is 55 mph.

Vehicles and equipment should not be in the transition area, since this area is designed for vehicle merging, and in many cases, this activity tends to be performed at high speeds. Sufficient distance should be allowed for the act of transitioning. After traffic has transitioned from its normal path, it should be moving parallel to the incident scene in the traffic space. Sometimes, however, the act of merging does not proceed as smoothly as designed. Therefore, as indicated in the diagram above, an additional buffer space should be provided. This buffer space is measured from the end of the transition area to the beginning of the work area (identified as the first safe-parked vehicle in the parallel or fend-off position.)

Proper application of positive and unambiguous traffic control measures is needed to protect responders and to ensure that motorists are able to safely pass the incident. Typical applications for traffic incident management have been developed as a joint effort of the National Committee on Uniform Traffic Control Devices and the NTIMC. The typical applications are available as a companion to MUTCD, chapter 6I. Two of the better known models developed by the responder community are "Safe Parking" (also known as "vehicle positioning"), developed by the McKinney Fire Department, McKinney, Texas, and the "Emergency Traffic Accommodation," (ETA) developed by the Calgary, Alberta Fire Department.

The "Safe Parking" concept advocated by the Emergency Responder Safety Institute (ERSI)[108] uses MUTCD, chapter 6, in particular, the guidance on establishing a TTC zone, and is MUTCD compliant.

The ESRI has developed a Standard Operating Procedure (SOP)[109] for Safe Parking that expands upon the MUTCD requirements by incorporating the following elements:

• Safety Benchmarks: These benchmarks are specific tactical procedures that should be taken to protect all crewmembers and emergency service personnel at the incident scene.
• Apparatus and Emergency Vehicle Benchmarks: These benchmarks involve procedures for safe parking of apparatus and emergency vehicles at an incident location when operating in or near moving traffic.
• Incident Command Benchmarks: These critical benchmarks provide procedures to ensure that a safe and protected work environment for emergency scene personnel is established and maintained.
• Emergency Crew Benchmarks: These benchmarks provide tactical procedures to ensure individual safety.
• High-Volume, Limited-Access Highway Operations: These benchmarks provide procedures for responding to incidents on turnpikes, toll roads, freeways, and other limited access, high-volume roadways.

The ETA developed by the Calgary Fire Department in Alberta, Canada, also builds upon MUTCD, chapter 6, and provides additional detail, such as the inclusion of an additional buffer space between the first emergency vehicle and other responders, "Fend-Off" vehicle positioning (Canadian terminology for "Safe Positioning"), and additional guidance on how to establish a TTC to enhance responder safety.[110]

Vehicle Placement

The responder community is testing a new concept for vehicle placement at an incident known as "Safe Positioning" (shown as the "Fend-Off Position" from the original concept design as presented by the Calgary Fire Department in Alberta, Canada) and represented in Figure 8.[111] Key elements of Safe Positioning include:

• When establishing the buffer, place the vehicle at a 30° angle to the road, which is referred to as the "fend-off position". If the vehicle is struck, the angle of the buffer may help to deflect a vehicle that otherwise may run into the incident scene. This positioning follows the National Fire Protection Association (NFPA) 1451 guideline about shielding emergency responders, and with emphasis on showing more of the vehicle's retroreflective striping and emergency lights. This vehicle positioning placement improves the ability of oncoming motorists to recognize the emergency vehicle.[112]
• When establishing the buffer, the driver should attempt to position the front bumper of the fire truck at least 2 feet from the longitudinal pavement marking line as shown in Figure 8. This area is referred to as the lateral buffer, and is designed to reduce encroachment into designated traffic lanes. A traffic cone with a strobe light inserted into the top also should be placed on the longitudinal pavement marking line beside the apparatus to allow personnel safer access around that corner of the vehicle.[113]

When emergency medical services are involved in incident response, the vehicle should always be positioned such that the rear doors are positioned away from traffic. The wheels also should be turned away from the incident. This vehicle placement enables the apparatus itself to shield the patient loading area.

Figure 8. Safe Positioning Diagram.
Photo Source: Emergency Traffic Accommodation A Guide for First Responders publication, p. 8.

Figure 9 shows an MUTCD-compliant TIMA that incorporates the elements of safe positioning.[114] As shown, the larger fire apparatus in the left foreground is parked at the 30° angle with wheels turned out. This placement creates the appropriate buffer and space for the incident work area. The vehicle's left front end is located approximately 2 feet from the cone, creating the lateral fend-off area. Cones are placed to mark the incident and a law enforcement vehicle is placed between the buffer vehicle and the incident to help with traffic control. The EMS vehicle is parked mid-way and angled to the right to protect the patient loading area.

Figure 9. MUTCD-Compliant TIMA.
Photo source: U.S. Fire Administration, "Traffic Incident Management Systems", p. 46.

Emergency Lighting

MUTCD, chapter 6I.05, addresses the use of warning lights as follows:

The use of emergency lighting is essential, especially in the initial stages of a traffic incident. However, it only provides warning; it does not provide effective traffic control. Emergency lighting is often confusing to drivers, especially at night. Drivers approaching the incident from the opposite direction on a divided roadway can be distracted by the lights, causing a slowed response, which can result in a hazardous situation for them and others traveling in their direction. (It also often results in traffic congestion in the unaffected opposite lane[s] and increases the chance of a secondary collision.)[115]

While there is a consensus within the responder community that some lighting is necessary to warn approaching motorists about the presence of emergency responders, it also is suspected that too much or certain types of lighting can actually increase the hazard to on-scene personnel, particularly during nighttime operations.[116] The USFA Emergency Vehicle Safety Initiative,[117] a project with a long-term goal of reducing the number of firefighters killed when responding to and returning from emergencies, and from being struck on the roadway, includes extensive research on emergency vehicle warning lighting to assess the impact of warning lights on responder safety. One key finding is the effect and disorientation of motorists caused by using day and nighttime emergency warning lights.[118]

The USFA's 2008 report, Traffic Incident Management Systems,[119] provides additional guidance on the impact of warning lights. Specifically, the USFA identifies several critical issues related to the use of warning lights. The first deals with the color of the lights being used. Research has shown that as the human eye adapts to the dark, it is less able to identify all colors of the spectrum. The first color within the spectrum that the human eye is not able to see is red, which is the color of most emergency lights. As a result of this research, many emergency response agencies are switching to amber-colored lights, which are easier to see at night, since amber lights do not blend in to the nighttime surroundings in the same way that red lights do, and therefore, are easier to detect.[120]

The second critical issue deals with the impact of vision recovery from the effects of glare. USFA notes that vision recovery from dark to light takes 3 seconds, and from light to dark takes at least 6 seconds. A vehicle traveling at 50 mph covers approximately 75 feet per second—or 450 feet in the 6 seconds before the driver fully regains night vision. This is extremely important when emergency vehicles operate on roadways at night, especially on two-lane roads. Headlights on the apparatus that shine directly into oncoming traffic can result in drivers literally passing the incident scene blind, with no sense of apparatus placement.[121]

The USFA further notes that wearing protective clothing and/or ANSI-compliant traffic vests does not improve the ability of the blinded driver to see personnel standing in the roadway. Studies show that the opposing driver is completely blinded at two and one-half car lengths from a vehicle with its headlights on. USFA notes that existing research indicates that stimuli such as the combination of lights, light colors, and varying degrees of reflection and flashes, hold a driver's central gaze, with the driver tending to steer in the direction of gaze. This has been termed the "moth effect".[122]

USFA and ISEA are currently engaged in additional research on emergency vehicle lighting, visibility and conspicuity, and the impacts these have on responder safety.

Both USFA and the ESRI Safe Parking SOP[123] offer guidance on reducing the potentially negative effects of emergency lighting. Vehicle and apparatus headlights and fog lights should be turned off at night scenes. Floodlights should be raised to a height that allows light to be directed down on the scene, thus reducing shadows and the potential blinding of motorists.

USFA, the MUTCD, chapter 6I,[124] and the ESRI Safe Parking SOP[125] all note that the key to reducing emergency vehicle lighting is by establishing good traffic control. When good traffic control is established by placing advanced warning signs and TTC devices, minimal emergency vehicle lighting is needed for responders to safely perform their duties. All cited resources recommend that departments review their policies on emergency vehicle lighting—especially after a traffic incident scene is secured—with the goal to reduce vehicle lighting usage at the scene, with special consideration given to reducing or extinguishing forward-facing vehicle lighting. The MUTCD emphasizes, however, that any reduction in emergency vehicle lighting should not compromise responder or motorist safety.[126]

3.4 Additional Resources

The guidance provided in this chapter is intended to help States develop and maintain a sustainable, dedicated, and active TIM program involving Tactical operations to expedite scene response and clearance, while providing for the safety of incident responders and motorists. There are numerous related examples from established programs discussing safe, quick clearance. A listing of potential resources is contained in the following section, "Want to Know More?"

Want to Know More?

Resources:

• Connecticut Statutes, Chapter 248 – Vehicle Highway Use, Section 24-224(D), available online: http://www.cga.ct.gov/2005/pub/Chap248.htm#Sec14-224.htm.
• "Dude, Where's My Truck? Non-Consensual Towing Issues," American Trucking Associations' (ATA) Litigation Center 2008 Forum for Motor Carrier General Counsels, June 30, 2008.
• Emergency Responder Safety Institute Web site, available online: http://www.respondersafety.com/Default.aspx.
• Georgia DOT Web site, available online: http://www.dot.state.ga.us/travelingingeorgia/hero/Pages/default.aspx.
• Indiana Quick Clearance Web site, available online: http://indianaquickclearance.org/.
• ITE Web site available online: www.ite.org.
• Missouri Revised Statutes, Traffic Regulations, Chapter 304, Section 151, available online: http://www.moga.mo.gov/statutes/C300-399/3040000151.HTM.
• Montana Code, Title 61 Motor Vehicles, Good Faith Immunity, Chapter 8, Part 9, available online: http://law.justia.com/montana/codes/61/61-8-909.html.
• "Move Over America" Web site, available online: http://www.moveoveramerica.com/#.
• National Conference on Incident Management, June 2002, available online: http://onlinepubs.trb.org/onlinepubs/archive/conferences/TIM/TIMProceedings.pdf.
• NCHRP Synthesis 318: "Safe and Quick Clearance of Traffic Incidents – A Synthesis of Tennessee Code Annotated, Title 54 – Highways, Bridges and Ferries, Title 54, Chapter 16, Section 113, available online: http://www.michie.com/tennessee/lpext.dll?f=templates&fn=main-h.htm&cp=tncode.
• "Highway Practice," Transportation Research Board, 2003, available online: http://onlinepubs.trb.org/Onlinepubs/nchrp/nchrp_syn_318.pdf.
• NIMS Resource Typing System, available online: http://www.fema.gov/emergency/nims/ResourceMngmnt.shtm#item4.
• NTIMC Web site available online: http://www.transportation.org/?siteid=41&pageid=2782.
• "Safety Service Patrols – Improving Mobility and Saving Lives," available online: https://www.fhwa.dot.gov/tfhrc/safety/pubs/its/pabroch/improveobil.pdf.
• Simplified Guide to the Incident Command System for Transportation Professionals, FHWA-HOP-06-004, 2006.
• Society of Automotive Engineers International Web site, available online: www.sae.org/servlets/index.
• Tennessee Code Annotated, Title 54 – Highways, Bridges and Ferries, Title 54, Chapter 16, Section 113, available online: http://www.michie.com/tennessee/lpext.dll?f=templates&fn=main-h.htm&cp=tncode.
• The National Response Team, Incident Command System/Unified Command (ICS/UC) Technical Assistance Document, available online: http://www.nrt.org/Production/NRT/NRTWeb.nsf/AllAttachmentsByTitle/SA-52ICSUCTA/$File/ICSUCTA.pdf?OpenElement.
• TRAA, "Towing and Recovery Association of America Vehicle Identification Guide," available online: http://www.towserver.net/products.htm.
• Traffic Incident Management Self-Assessment: 2007 National Report, prepared by American Transportation Research Institute for the Office of Transportation Operations, Federal Highway Administration (September 2007).
• Texas Statutes, Code of Criminal Procedure, Section 49.25 Medical Examiners, Part 8, available online: http://law.justia.com/texas/codes/cr/001.00.000049.00.html.
• U.S. Department of Homeland Security publication, National Incident Management System, March 1, 2004, available online: http://www.fema.gov/good_guidance/download/10243.
• U.S. Department of Labor, Bureau of Labor and Statistics, available online: https://www.bls.gov/news.release/cfoi.t01.htm.
• U.S. Department of Transportation, National Strategy to Reduce Congestion on America's Transportation Network, May 2006, available online at: http://isddc.dot.gov/OLPFiles/OST/012988.pdf.
• USFA Traffic Incident Management Systems, 2008, available online: http://www.usfa.dhs.gov/downloads/pdf/publications/tims_0408.pdf.
• Washington State Joint Operations Policy Statement, available online: http://www.watimcoalition.org.

Footnotes

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