So far in 2019, 113 people have died on Victorian roads compared to 74 at the same time last year, marking the worst start to a year since 2008.
Victoria Police Assistant Commissioner Stephen Leane said the state's reputation as one of the safest places in the world to drive was being challenged.
"We're having a shocking year this year. I just wonder whether as a community we're having a collective brain fade and we all just need to think about it," he told Melbourne radio 3AW on Wednesday.
Of the people who died, 18 weren't wearing seatbelts and it appeared a "significant number" could have been saved if they had, Mr Leane said.
Over the Easter long weekend, 350 people were fined for not wearing seatbelts.
People killed in car crashes were also more likely to have drugs in their system than alcohol.
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