Module 1.2 Road Safety – A Complex Filed Unit 1 Module 1.2 The Nature of Road Safety Road Safety – A Complex Field Learning Objective Duration 35 Minutes At the conclusion of this module, participants will be able to: Describe road safety as a complex, multidisciplinary, multimodal field devoted to the prevention and/or mitigation of crashes, injuries, and fatalities. The major topics include: • The complex nature of road safety • Safety disciplines • 4 Es of road safety • Road safety modes • Crash prevention paradigm shift NCHRP 17-40, June 2010 Page 1 of 15 Module 1.2 Road Safety – A Complex Filed Protecting the public from roadway crashes and the related injuries and fatalities involves solutions that address the issue from multiple perspectives, involve multiple disciplines, and affect many different types of road users. Historically, road safety has developed over the last century with the development of the automobile. Crashes and fatalities increased as the automobile became more popular and as vehicle-miles of travel increased. Road safety, however, was not officially recognized at the national level until 1966 when Congress passed the National Traffic and Motor Vehicle Safety Act. The law authorized the federal government to set and regulate standards for motor vehicles and the roadway and, as such, much of the initial safety efforts focused on the contributions of the roadway, the automobile, and the driver with respect to crashes. Many of the solutions were, therefore, related to roadway and vehicle engineering. While the design and operation of the roadway is primarily an engineering task, road safety is not exclusive to engineering. Road safety professionals include anyone who has an influence on the safety of road users including those in public health, public safety, and many other disciplines. Each of these disciplines is able to provide a unique perspective and each has specific methods for addressing road safety. However, the actions of one discipline or even each discipline alone will not address road safety completely. It is the interaction and collaboration among these professionals that will lead to continued safety improvements. The challenge in creating these interactions and collaborations stems from the diverse backgrounds and perspectives of individuals within each discipline. First, each discipline has its respective goals and objectives. While improving safety is the overall goal, there are several means to the end (e.g., through the roadway, vehicle, or road user improvements). There are also diverse training and education curriculums for each specific discipline. This creates various skill sets, which can benefit road safety, but also creates barriers among the disciplines including terminology and mindsets. NCHRP 17-40, June 2010 Page 2 of 15 Module 1.2 Road Safety – A Complex Filed To add to the complexity, these various disciplines are often represented at the local, regional, State, and Federal level. So, not only is it a challenge to improve collaboration among the various disciplines, but also a challenge to overcome the barriers within the disciplines. Since 1966, road safety has substantially improved. Vehicle and roadway designs have improved over time and many countermeasures have been implemented to improve safety. Law enforcement and education have been used to change driver behavior and human factors considerations have been incorporated in roadway and vehicle designs to better suit road users. In addition, significant advancements in the medical field and emergency response have helped mitigate the consequences of crashes. However, these improvements have only been effective up to a certain point and crash-related injuries and fatalities remain a significant issue. Safety professionals have continued to work within their disciplinary “silos” with little interaction. As the graphic above shows individual silos for storing grain, the disciplines have also worked within walled off areas. Also, the local, state, and federal agencies have worked mostly at their respective levels, with limited knowledge and information sharing. Thus, more recent efforts have sought to examine road safety from a coordinated approach, with solutions that are directed at road users, vehicles, and the roadway environment, and carried out by professionals in multiple disciplines at various levels. The challenge is to enhance and develop this coordination in the future to realize the full potential of road safety initiatives. Several approaches for addressing the safety of a roadway exist, and no single approach will address the issue completely. Road safety professionals typically recognize four major categories for addressing road safety; engineering, education, enforcement, and emergency response. These four categories are commonly known as the 4 Es of road safety. The 4 Es have typically been used either as measures to correct existing road safety issues or as crash prevention strategies. Let’s take a look at each of the 4 Es. NCHRP 17-40, June 2010 Page 3 of 15 Module 1.2 Road Safety – A Complex Filed Engineers address road safety issues related to the roadway, roadside, and vehicle. It is the engineers’ obligation and responsibility to ensure the transportation system, including all modes of transportation, is designed to meet the expectations and limitations of road users. Roadway design manuals are based on human and vehicle performance. When roadway safety problems arise, often several engineering and operations measures can be implemented to improve the physical environment of the roadway and overcome the human or vehicle limitations. For example, when crashes at a particular location are associated with dark and unlit roadway conditions, many options exist for improving visibility and guidance through pavement markings, signage, and lighting. The roadside is another area where engineering can lead to significant safety benefits. Engineering improvements such as paved shoulders and rumble strips may prevent vehicles from leaving the roadway, but several opportunities exist for improving the roadside. When vehicles leave the roadway it is important to provide a forgiving roadside environment. Roadside slopes and obstructions (e.g., drainage structures, trees, and utility poles) are specific attributes of the roadside that fall within the realm of engineering. The engineer can also impact safety through the design of the vehicle. Vehicle design can affect safety during all three stages (i.e., pre-crash, crash, and post-crash). Pre-crash countermeasures include anti-lock brakes, vehicle stability, and collision warning devices. Safety enhancements that mitigate the severity during a crash include safety belts, airbags, and vehicle integrity. In-vehicle technologies that automatically notify emergency response can mitigate the post crash environment. Human behavior can be modified through other means, particularly education and enforcement. The purpose of education in road safety is to change the behavior of road users (i.e., reduce unsafe behaviors and increase safe behaviors). Education can be a powerful tool for improving road safety because the human element is listed as the primary cause in over 60 percent of crashes and a contributing factor in over 90 percent of crashes. Educational campaigns can be used in conjunction with engineering and enforcement measures or as a single countermeasure. As a single measure, education can be used to improve driving skills and knowledge of the rules of the road as well as to increase general awareness about road safety. NCHRP 17-40, June 2010 Page 4 of 15 Module 1.2 Road Safety – A Complex Filed Education can take the form of instructor-led training or invehicle training. When education is used in conjunction with engineering or enforcement, the educational aspect is typically used to explain why the countermeasure (engineering or enforcement) has been implemented and how road users should respond. For example, red light cameras are related to both engineering and enforcement; however, it is important to explain the issue of red light running to the public and the need for the cameras or it is likely that such a tactic will be met with serious opposition. Educational campaigns can also be targeted to address specific unsafe actions (e.g., driving under the influence, texting while driving, and not wearing a safety belt) or to address specific road user populations (e.g., teen drivers, motorcyclists, and pedestrians). Unfortunately, engineering and education do not completely solve road safety issues. For example, the engineer can design a roadway and post a specific speed limit while an educational campaign explains the dangers of excessive speed. Despite engineering and education, some drivers will choose to exceed the posted speed limit. Hence, enforcement is needed to modify the behavior of the road user. Speeding, driving under the influence (DUI), and safety belt use are associated with a relatively large proportion of the total crash-related injuries and fatalities. In other countries such as Australia, a high level of success has been attained in reducing crashrelated injuries and fatalities through enforcement of these behaviors. The United States is slowly improving safety belt use through educational and enforcement campaigns; however, the use of automated enforcement techniques (e.g., red light running and speed detection cameras) has met with opposition. The intensity of DUI campaigns in the United States lags behind other developed countries. Furthermore, to be effective, enforcement must result in consequences. Often judges and prosecutors do not understand the seriousness of the issue and fail to ensure citations are followed by maximum penalties. Once a crash has occurred, emergency responders are responsible for rescuing victims from the crash, providing primary care, and protecting other road users from further harm. While emergency responders typically deal with postcrash issues, it is important for these professionals to establish a well-conceived incident management plan before the crash NCHRP 17-40, June 2010 Page 5 of 15 Module 1.2 Road Safety – A Complex Filed occurs. Emergency responders include law enforcement, traffic engineers, fire and rescue, and emergency medical services; each with a specific purpose. In general, law enforcement officers are in charge of investigating the crash and controlling traffic with assistance from traffic engineers. Fire and rescue are responsible for removing victims from the vehicle, if necessary, and often provide primary care. In some jurisdictions, emergency medical services are carried out under a separate public agency or privately contracted company. Emergency responders often rely on assistance from others including transportation agencies, towing and recovery services, hazardous materials contractors, and traffic reporting media. Through effective incident management, these professionals can work in collaboration to mitigate the consequences of crashes for those involved and reduce the potential for further harm and traffic delay. Historically, the 4 Es have been used as a means to address crashes and the related injuries and fatalities. Over the years, awareness of the 4 Es has increased, and they are now commonly referenced in literature related to road safety countermeasures. One positive result has been the increased recognition that several different disciplines can contribute to road safety. However, these disciplines have often confined their prevention efforts to activities that relate centrally to their core competencies, and have neglected to work together. In essence, division of prevention efforts has created a silo effect. It is time to move away from the traditional line of thinking regarding the 4 Es (i.e., four separate and distinct disciplines for addressing safety) and time to start thinking of this as a method for addressing safety through partnerships across the four disciplines. Beyond the 4 Es of safety, other disciplines are also critical for improving road safety including public health, human factors and biomechanics, public and private administration, and transportation planning. Public health professionals deal with issues that affect the general well being of society (i.e., morbidity and mortality). As roadway-related crashes are the leading cause of unintentional injuries and the sixth leading cause of death in the United States, road safety is a major public health concern. Public health officials have various opportunities to influence road safety. In 2004, road safety was the theme of the annual World Health Day celebration. This worldwide recognition of NCHRP 17-40, June 2010 Page 6 of 15 Module 1.2 Road Safety – A Complex Filed road safety included events of various forms, ranging from new legislation, to hosting conferences and seminars, and conducting high profile advocacy events for the general public. Human factors and biomechanics professionals study the capabilities and limitations of the human body, often in relation to the design of various devices and systems. Within the transportation field, the human factors and biomechanical elements are critical to the safe design of the vehicle as well as the safe design and operations of the roadway. Biomechanics help explain the physical durability and limitations of the human body. Examples of human factors that affect road safety include the physical strength required to depress the accelerator or brake pedal, reaction time, visual acuity, and the affect of age on these characteristics. Driver vision and reaction time influence the total distance required to stop a vehicle, which is a critical factor in the design of horizontal and vertical curves as well as signal timing. Height, weight, and physical durability are all factors related to the design of airbags and the required force of deployment. If roadway and vehicle designs do not consider the human element, the system could easily exceed the limitations of the human body. Public and private administrators affect road safety in a variety of ways. In the private sector, loss control administrators analyze insurance claims to help set rates for vehicle and health insurance. Public administrators develop and enforce policies, procedures, and regulations to ensure the safe design and operation of vehicles and roadway systems. Transportation planners are involved with all modes of transportation and, as such, can significantly influence safety. Planners assess the need for various facilities, identify and evaluate alternatives, and develop implementation plans. However, the traditional planning process has considered economic development, environmental quality, and mobility and accessibility as the three primary concerns when evaluating alternatives. Safety is often assumed to be a part of improvements within these areas rather than a priority on its NCHRP 17-40, June 2010 Page 7 of 15 Module 1.2 Road Safety – A Complex Filed own. Planners have the opportunity to consider safety directly in the evaluation of alternatives, and thus, an opportunity to significantly impact road safety. More details on the transportation planning purpose, process, and potential safety impact are addressed in Unit 5. Beyond the various disciplines involved in road safety, we need to consider the various modes of travel as well. The multimodal aspect of transportation and interaction among the various modes adds to the complexity of road safety. The modes of transportation include passenger vehicles, motorcycles, pedestrians, bicycles, commercial vehicles, and transit. However, the design of vehicles and facilities is often focused on a specific mode with little or no consideration for its interaction with other modes. It is important to realize the limiting factors and issues associated with the various modes and how they affect the overall safety of the facility. Each mode is discussed below in further detail with specific emphasis on the interaction between modes and how the interaction affects safety. The most popular mode of transportation is the passenger vehicle (e.g., cars, SUVs, vans, and light trucks) when considering total miles traveled. As such, the design of transportation facilities has reflected the desired use of the automobile. However, the passenger car is also represented in the largest percentage of crashes. In 2005, more than 94 percent of the 11 million vehicles involved in motor vehicle crashes were passenger cars (NHTSA, 2006). Often little attention is paid to the connectivity of other modes when designing facilities for the automobile. While all trips begin and end with some form of pedestrian activity, the auto is the primary consideration, and several examples exist where the auto has been the primary consideration, with little regard for pedestrians. One example is parking lots. Numerous parking lots are constructed with no sidewalks or designated areas for pedestrians traveling to and from their vehicles. Other safety considerations regarding the automobile include the size and performance characteristics of the various types of personal vehicles. Certain types of automobiles may be more likely to be involved in specific crash types. For example, when considering specific vehicle types involved in crashes, NCHRP 17-40, June 2010 Page 8 of 15 Module 1.2 Road Safety – A Complex Filed SUVs have the greatest percentage of rollover crashes compared to all other vehicle types. This is noteworthy because the proportion of vehicles that rolled over in fatal crashes (21.1 percent) was four times higher than the proportion in injury crashes (5.3 percent) and 16 times higher than the proportion in property damage only crashes (1.3 percent) (NHTSA, 2006). Potential hazards are associated with the diversity in the vehicle fleet. Vehicles range in height and weight, which can influence the crash severity (e.g., small car hits small car versus large truck hits small car). These are all issues associated with road safety, and they must be understood before noteworthy safety improvements can be made. The interaction between commercial vehicles and other road users, particularly passenger vehicles, can also create safety concerns. The relative size of commercial vehicles creates difficulties related to safety including blind spots, vehicle control, and stopping distance. Roadways are often designed based on the performance of passenger vehicles, rather than larger commercial vehicles. In 2005, large trucks accounted for eight percent of vehicles in fatal crashes, but only three and five percent of vehicles involved in injury and property damage crashes, respectively (NHTSA, 2006). While passenger vehicles are represented in the greatest percentage of crashes, other motorized vehicles are represented in the greatest percentage of severe crashes when adjusting for vehicles miles traveled and number of registered vehicles. After adjusting for total vehicle-miles traveled and number of registered vehicles, Table 1 on the next slide shows the percentage of motorcycles and large trucks involved in fatal crashes compared to passenger cars and light trucks. Considering the total vehicle miles traveled and number of registered vehicles, large trucks, and motorcycles are overrepresented in fatal crashes when compared to passenger cars and light trucks. The passenger car, however, tends to be overrepresented in crashes resulting in injury or property damage. In other words, when large trucks or motorcycles are involved in crashes, the outcome is often severe. Transit creates safety issues similar to large trucks when considering the relative vehicle size. However, other distinct safety considerations are associated with transit. Transit serves as a form of mass transportation and, as such, transit facilities need to accommodate pedestrians, particularly those with NCHRP 17-40, June 2010 Page 9 of 15 Module 1.2 Road Safety – A Complex Filed disabilities. While transit serves the pedestrian and bike community, it often operates on the same facilities as other motorized vehicles, which can create significant safety issues. Transit stops are often located along commuter routes or other routes with popular destinations. However, the placement of the stop along the route can affect safety. It is desirable to have the transit vehicle exit the traffic flow and stop in a designated area; however, this can lead to issues when the vehicle enters back into the traffic stream. If the transit vehicle must stop in traffic, it is desirable to locate the transit stop where adequate stopping sight distance is available for motorists approaching from behind. These are just a few of the many examples of safety concerns related to transit. This slide clearly shows passenger vehicles are involved in many more fatal and injury crashes than other types of vehicles. However, controlling for vehicle miles of travel and number of registered vehicles, passenger vehicles are the least likely to be involved in serious crashes. Does this mean that passenger vehicles are “safer” than other types of vehicles? Not necessarily. We have to consider who is driving; where they are driving; and break the data down much further to answer this question. For example, the fatal and injury rate for large trucks is higher than passenger vehicles; however, it is generally not the truck occupants who are injured or killed but rather the passenger vehicle occupants. Pedestrian and bicycle fatalities are significant issues related to overall road safety. While the total number of pedestrian- and bicycle-related crashes is of concern, the severity of these crashes is of greater concern. In 2006, 4,784 pedestrians and 773 cyclists were killed in traffic crashes in the United States (NHTSA, 2006). In addition, 61,000 pedestrians and 44,000 cyclists were injured in traffic crashes in 2006 (NHTSA, 2006). Pedestrians and bicyclists are the most vulnerable of the road users, but all too often they are not considered in the design of roadway facilities. Higher type facilities (e.g., Interstates and freeways) are not designed to facilitate pedestrian and bicycle travel because their primary purpose is high-speed movement of motorized vehicles. However, several other functional classifications should provide for pedestrian and bicycle mobility. One example of inattention to pedestrian safety issues is the lack of NCHRP 17-40, June 2010 Page 10 of 15 Module 1.2 Road Safety – A Complex Filed connectivity of sidewalks, which creates “sidewalks to no where”. This section discussed the various modes of transportation and the interactions that occur among modes. Examples were provided to illustrate the interaction among various modes and how these interactions affect safety. It is important to understand and address the multimodal aspect of transportation; otherwise, the overall safety of the facility is compromised. As discussed in the previous sections, road safety is multimodal and multidisciplinary in nature. Not only does this create a complex environment, it also has fostered single disciplinary and modal perspectives. It is often easier to address safety issues related to a specific discipline or mode; in part because that is how we have historically addressed safety issues. However, the previous sections explain that safety issues are often not related to a single mode or discipline. The road safety profession, and the general public for that matter, needs a paradigm shift. We need to move away from the traditional approach to road safety (i.e., addressing safety issues from a single disciplinary or modal perspective) to one that addresses road safety with a coordinated, interdisciplinary, multi-modal, and systems perspective. While crash and fatality rates continue to decline as vehicle-miles traveled increases, the total number of fatal crashes has leveled over the past decade. Many of the single modal and disciplinary countermeasures have been implemented, (i.e., the “low hanging fruit” has been picked). Further reductions in crashes and related injuries and fatalities will come from interventions where disciplines work together to address road safety across all modes and disciplines. Consideration of several modes of transportation as well as the collaboration among various disciplines has led to successful crash prevention and safety improvements. The following examples illustrate the benefits of interdisciplinary relationships and multimodal considerations. Many crash types and situations are more effectively addressed through multidisciplinary collaboration. We will consider two areas to demonstrate the more effective approach: young drivers and safety corridors. NCHRP 17-40, June 2010 Page 11 of 15 Module 1.2 Road Safety – A Complex Filed Alcohol-related traffic crashes are a prevalent problem in the US, especially among young males. A research study was undertaken to understand issues and concerns surrounding underage drinking and driving and to identify an effective solution. The first safety issue noted with teen driving is teens are involved in nighttime crashes at significantly higher rates (per 100 million miles driven) than all other age groups. The researchers also noted that the age when a teen learns to drive effects their crash risk, with younger drivers posing greater risk than drivers who are licensed even one year later. The table shows that drivers learning at age 14 and licensed at 14 to 15 have significantly higher crash risks. Conversely, drivers learning at age 16 and licensed between 16 and 17 have the lowest crash risk. The researchers examined the available evidence and devised a solution that involves a multi-disciplinary effort using a twopronged approach to reduce underage drinking and driving. The two effective strategies found to reduce impaired youth driving include: “Zero-Tolerance” laws prohibiting drivers under 21 from driving with even small amounts of alcohol in their systems. Allowable blood alcohol content is from 0.00 to 0.02. Graduated licensing systems that ease young people into full driving privileges more gradually and prohibit unsupervised night driving from 90 days to 6 months. These two programs are typically operated by different agencies, once passed by the legislature. Typically the zerotolerance law is implemented by law enforcement agencies, whereas driver licensing is administered by the department of motor vehicles. Taken together, these programs illustrate that a multi-disciplinary approach to addressing traffic safety issues may be more powerful than individual programs. NCHRP 17-40, June 2010 Page 12 of 15 Module 1.2 Road Safety – A Complex Filed These programs are even more effective with parental participation where parents enforce the laws themselves and with full scale education programs to inform both parents and novice drivers as to what the law is and why it is important to abide by it. The education program may be undertaken by the SHSO, the Department of Health, or some other agency working in conjunction with law enforcement and the licensing agency. By 2006 most states had passed a graduated driver licensing law although the elements of the laws vary greatly. One analysis concluded that the strongest GDLs result in a 38% reduction in fatal crashes and a 40% reduction in injury crashes among 16 year old drivers. Even the weakest laws resulted in fatal and injury crash reductions although to a lesser extent. The Insurance Institute for Highway Safety studied and rated all the state laws. The map shows states with good, fair, marginal, and poor laws. You can find out more about their rating methods by visiting their website at http://www.iihs.org/laws/gdl_intermediate.aspx. From there, you can click on any state for the IIHS analysis. Question: Where does your state fall in the rating scheme? Answer: If anything less than good, you might find out what elements are missing from your state’s law and begin to educate your colleagues and officials on the effectiveness of the missing elements. Some states have legislative permission to identify “Safety Corridors” which are high crash road segments in need of attention. In these cases, the legislature directs the DOT to identify corridors where the crash experience is higher than average for all roads with similar characteristics, e.g. Interstate, freeways, etc. The DOT places signs along these corridors announcing to the public that the road segment has been designated as a Safety Corridor and fines for speeding are doubled. In addition, the state police or local law enforcement increases enforcement in these areas. In some cases, local advocacy groups are engaged to educate the public about the dangers associated with the road segments and high risk driving behavior, e.g., speeding and impaired driving. NCHRP 17-40, June 2010 Page 13 of 15 Module 1.2 Road Safety – A Complex Filed Finally, the state or local transportation authority may conduct a RSA and make improvements to the infrastructure, e.g. upgrade the guardrails, install cable median barrier, etc. For example, the legislature directed the New Mexico Department of Transportation (NMDOT) to identify hazardous road segments and implement a safety corridor program. NMDOT designated 12 safety corridors (two in each district) to reduce speeds and serious crashes. The first step in corridor selection was to identify the 10 segments of roadway in each District with the highest number of serious crashes. The lists were prioritized according to crash severity. NMDOT met with local law enforcement and NMDOT District personnel to discuss current projects on those segments. If construction work was currently being implemented or if there was no safe place for law enforcement to stop vehicles and issue citations, the segment was deleted from the list. The remaining top two locations in each District were selected for implementation. A map of the corridors is available at: http://nmshtd.state.nm.us/main.asp?secid=14476. By the beginning of 2008, crashes were reduced in all corridors except one where the amount of traffic had increased significantly. NMDOT coordinates crash data analysis with the Districts; reviews existing law enforcement and engineering initiatives; conducts public awareness campaigns to elicit local support; installs signs designating the safety corridors; and provides support to local law enforcement to increase traffic law enforcement. This case study shows how multidisciplinary approaches can work effectively to save lives and reduce injuries. These programs are not easily replicated because of the need for legislation and the complexity involved when state and local agencies must work together. Identifying the sites can also be problematic. The DOT must be able to justify the designations using crash data analysis and exposure metrics to differentiate the safety corridors from other roadway segments. Often the data are not available to conduct the analyses. Even when the corridors can be identified, it may not be possible to implement the campaign because construction work is underway or enforcement activity is impractical due to the volume of traffic or the lack of safe pullover places along the roadway. Finally, the different disciplines, e.g., law enforcement, engineering, emergency response, advocacy groups, and others have different structures, missions, and methods for conducting their business. Connecting the NCHRP 17-40, June 2010 Page 14 of 15 Module 1.2 Road Safety – A Complex Filed agencies to work hand in hand together requires good communication and persuasion skills. Road safety is a major health and economic issue. Protecting the public from roadway crashes and the related injuries and fatalities involves solutions that can address the issue from multiple perspectives, involves multiple disciplines, and affects many different types of road users and modes. While interdisciplinary efforts are necessary to improve road safety, the interaction among disciplines is often difficult to achieve due to diversity in backgrounds, perspective, education, and goals and objectives. Further, various levels of government are often involved within a discipline. Therefore, barriers must be overcome within and among the various disciplines to further improve road safety. Within the various disciplines, the four primary areas for addressing road safety include engineering, education, enforcement, and emergency response. These four areas are known as the 4 Es. While recognition of the 4 Es has helped emphasize the multidisciplinary nature of road safety, the various disciplines often consider singular actions. Collaborative efforts among the various disciplines have been neglected in most situations. Road safety includes all modes of transportation (e.g., passenger vehicles, motorcycles, pedestrians, bicycles, commercial motor vehicles, and transit). The personal automobile accounts for the greatest miles of travel and greatest percentage of crashes. However, motorcycles and large trucks are over-represented in fatal crashes after adjusting for total vehicle miles and number of registered vehicles. Also, specific safety concerns are related to the interaction among the diverse vehicle types and modes of transportation. Vehicles range in height, length, and weight, create specific safety issues. Pedestrians and bicyclists are the most vulnerable road users because they are completely unprotected and move at different speeds than motorized vehicles; each of these factors influences safety. It is important to realize the limiting factors and issues associated with the various modes and how they affect the overall safety of the facility. While it is often easier to consider safety within a specific discipline or mode, it is important to move toward multimodal and multidisciplinary actions. NCHRP 17-40, June 2010 Page 15 of 15