On March 4, 2016, the FMCSA released the Proposed National Training Standards for Entry Level Truck and Bus Drivers (FMCSA Press Release https://www.fmcsa.dot.gov/newsroom/fmcsa-proposes-national-training-standards-entry-level-truck-and-bus-drivers). Since its release, I’ve been scrutinizing the related ‘for public inspection’ Federal Register document of the 49 CFR Parts 380, 383, and 384 [FMCSA 2007-2007-27748 Minimum Training Requirements for Entry-Level Commercial Motor Vehicle Operators Proposed Rules]. (Proposed Rule NPRM: https://s3.amazonaws.com/public-inspection.federalregister.gov/2016-03869.pdf)
In speaking with different industry committee members who were brought in by the FMCSA to participate in varied workshops to iron out this proposal, the one comment I heard over and over was “I'm surprised that they actually came out with anything at all.” One member told me while it wasn't as bad as the mudslinging and disagreement we're hearing from the GOP presidential debates, there was most definitely a large group of people with different agendas, and not all of them in the interest of safety.
So, from what appears to be a number of different stakeholders having a wide range of differing opinions and ideas on how best to develop a comprehensive curricula, along with standards for training facilitators to put the safest entry-level Commercial Motor Vehicle drivers on the road, we now have a proposed rule from the FMCSA.
On May 15, 2015, the ELDTAC (Entry-Level Driver Training Advisory Committee) had their final session. The Committee unanimously approved a final package of recommendations, as set forth in the Consensus Agreement, on which this Notice of Proposed Rule-Making (NPRM) is based. (See page 30 of the NPRM link above for details).
With all this said and read, and while I could bore everyone reading this with detail after detail of the NPRM document, there are a lot of very good aspects to this Entry-Level Driver Training (ELDT) proposal. But I'm going to cut to the chase of one area that caused me the greatest amount of concern regarding the effectiveness of the program in actually training qualified CMV drivers for the challenges they'll face every moment they're behind the wheel of a truck or bus.
First a disclaimer as to why I'm qualified to make comments on this: I spent nearly a quarter of a century and 2.5 million miles in the left seat of an 18-wheeler. I have driven in every one of the lower 48 states on all types of roads and in all types of conditions. And I'm proud to say I accomplished every one of those miles accident- and ticket-free. I have a wall in my office lined with multiple safety and exemplary service awards. I'm also a licensed insurance agent specializing in trucking and logistics insurance.
I’m detailing this to say I have the experience; I have the knowledge, and the expertise to know what is required to maneuver a CMV safely in nearly every type of situation imaginable - and some no one but another long-term trucker can imagine. And what is the major underlying reason for this safe driving accomplishment? The bottom line: it was the training I received and the instructor who provided that training.
Now to the biggest complaint I have with the proposed ELDT rule § 380.605 Definitions. In the rule, the following is the definition of an experienced truck driver, used to determine who is qualified to be a CMV driving instructor (Page 96 of the NPRM link above): Experienced driver means a driver who holds a CDL of the same (or higher) class and with all endorsements necessary to operate the CMV for which training is to be provided and who: Has at least 1 year of experience driving a CMV requiring a CDL of the same or higher class and/or the same endorsement; or Has at least 1 year of experience as a BTW CMV instructor; and Meets all applicable State training requirements for CMV instructors.
On the first reading of the requirements to be an “Experienced Driver” you’ll note that they are recommending he/she have only one year of experience in the type of vehicle along with the appropriate endorsements. Any trucker with more than five years driving a CMV professionally will tell you, “You are not an Experienced Truck or Bus Driver after just one year.” In fact, any trucker with more than five years’ experience will tell you he/she really didn't have the honed skills and knowledge of what the road will toss in your path along with experiencing the multitude of challenges and dangers of driving a truck until they reached the 500,000 mile threshold behind the wheel.
A trucker with only one year’s experience has only one winter season behind the wheel; one spring, one summer, and one fall. And with that they'd be hit-or-miss on what type of inclement weather conditions they've encountered: slick road conditions, congested traffic, construction zones. Not to mention at least 90 days (25%) of that first year they would have been with a driver-trainer still learning the basic skills. Most carriers place first year drivers on a 90-to-180 days probationary period where they're monitored and watched very carefully to correct any unsafe practices. The idea that this same person is qualified to teach an entry-level, never-driven-a-truck student to handle a CMV safely is beyond comprehension.
Finally, within the rules, I could not find one word, sentence or paragraph as to what the qualifications are for a Driver Trainer at a trucking company. Currently I have seen driver trainers at many of the “training carriers” have only six months of experience. This can mean an inexperienced Driver-Trainer attempting to teach an entry-level driver how to drive in winter conditions where neither one has any experience in those conditions.
What we need is far more definitive rules covering what the qualifications for a CMV Driver Instructor and a Carrier Driver-Trainer need to be.
For the CMV Driver Instructor, I recommend a minimum of 400,000 verifiable, accident-free and major ticket-free CMV driving; completion of an FMCSA certification course and testing, and required continuing education every three years to stay updated on new rules and changes to existing rules.
For the Carrier Driver-Trainer, I recommend a minimum of 300,000 verifiable, accident-free and major ticket-free CMV driving; completion of an FMCSA certification course and testing, and required continuing education every three years to stay updated on new rules and changes to existing rules.
We don't need inexperienced or under-experienced truckers training new drivers. All you have to do to see the results of this type of approach is to look at all the multi-vehicle accidents involving more and more CMVs that occur every winter.
I will follow this article up with writing a comment to the FMCSA on the ELDT proposal concerning these CMV Driver Instructor and Carrier Driver-Trainer requirements, and I suggest you do the same when it's been opened for comments.