FMCSA published its long awaited proposal for Minimum Entry-Level Driver Training Requirements on August 15. Sadly, however, the agency has missed an opportunity for dramatically improving the skills and safe driving practices of entry-level drivers.
The proposal would require drivers with less than two years of experience to undergo approximately 10 hours of classroom training covering such topics as physical driver qualification standards, e.g., vision, hearing and hypertension, HOS rules, driver health guidelines and federal whistleblower rules.
But first a little background. In 1991 Congress required FMCSA's predecessor agency to assess the effectiveness of private sector efforts to train entry-level commercial drivers. So the agency defined minimum training standards (known today as the PTDI Model Curriculum) and surveyed drivers, employers and training schools about their efforts to meet those standards. In a follow-up report to Congress, FMCSA said “neither the heavy truck, motor-coach, nor school bus industries were providing adequate entry-level training.”
In the mid-90s, FMCSA initiated a series of “Advanced Notice” rulemaking proposals and public meetings to get input on appropriate training standards, industry training efforts and the efficacy of government-mandated standards.
While trucking voiced strong opposition to any government mandated training efforts, many agreed that the PTDI Model Curriculum was an appropriate entry-level training benchmark. The industry rationalized that CDL knowledge and skills testing programs were an adequate measure of training effectiveness.
Having been “inside the beltway” then, I can tell you that “strong opposition” to government training standards is a gross understatement. Trucking was so successful in promoting the idea of “best industry training practices “that government-mandated entry-level training requirements moved off the radar screen altogether‥
But that all changed last year when public and labor advocate groups sued FMCSA in order to advance a series of stalled Congressional mandates, including the one for entry-level driver training standards.
In analyzing the current proposal, two questions need to be asked. The first is whether the CDL testing program can adequately assess an entry-level driver's ability to demonstrate comprehension and knowledge of the “Model Curriculum.”
Here's why I think the answer is “no.” The safety vp of a “Top 50” trucking firm recently described his carrier's entry-level training program to me. Four days of classroom instruction is followed by three weeks of behind-the-wheel training. Trainees then take the CDL knowledge and skills tests. If they pass, they go onto Part 2 of the company's training program, which consists of 90 days of “follow on” training, including defensive and decision driving skills. Why the need for Part 2? The safety vp said that new CDL holders are woefully inadequate to be certified as “competent” CDL drivers.
The second question is whether the current proposal will measurably reduce truck crashes. In its cost-benefit analysis, FMCSA determined that crashes would have to decrease by 285 to 318 per year to offset the cost of the rule, which the agency estimates at $25 million annually. Yet they offer no proof of how the rule would achieve this. In any case, this would represent only a 0.07% reduction in truck crashes Excuse me if I'm underwhelmed by such a lofty goal.
This rule will do little to reduce truck crashes. FMCSA has missed a golden opportunity to advance toward DOT's “50[%] by 2010” crash reduction target. A far better investment would be to require behavior based on defensive and decision driver training. We have seen that such efforts can produce a 10-30% reduction in rear-end, intersection and lane change/merge crashes.
Unfortunately, we're stuck with a much less ambitious effort. I urge you to comment in support of stronger, more common sense entry-level training requirements.
Jim York is the manager of Zurich North America's Risk Engineering Team, based in Schaumburg, IL.