[Federal Register Volume 61, Number 81 (Thursday, April 25, 1996)]
[Proposed Rules]
[Pages 18355-18366]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 96-10206]
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DEPARTMENT OF TRANSPORTATION
Federal Highway Administration
49 CFR Part 383
[FHWA Docket No. MC-93-12]
RIN 2125-AD05
Training of Entry-Level Drivers of Commercial Motor Vehicles
Agency: Federal Highway Administration, DOT.
Action: Notice of availability and request for comments.
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SUMMARY: Section 4007 of the Intermodal Surface Transportation
Efficiency Act of 1991 (ISTEA), (Pub.L. 102-240, 105 Stat. 2151-2152)
directed the Secretary of Transportation to report to Congress on the
effectiveness of the efforts of the private sector to ensure adequate
training of entry-level drivers of commercial motor vehicles (CMVs).
With this notice, the Federal Highway Administration (FHWA) is advising
members of the general public that copies of the study entitled
``Assessing the Adequacy of Commercial Motor Vehicle Driver Training:
Final Report'' and a cost-benefit analysis of requiring entry-level
training for CMV drivers are now available from the National Technical
Information Service (NTIS). Two copies have also been placed in the
FHWA Docket number MC-93-12. The Agency is also requesting comments
from the general public regarding the content and conclusions of the
final report and cost-benefit analysis.
DATES: Comments must be submitted on or before October 22, 1996.
ADDRESSES: Submit written, signed comments to FHWA Docket No. MC-93-12,
Room 4232, HCC-10, Office of Chief Counsel, Federal Highway
Administration, 400 Seventh Street, SW., Washington, D.C. 20590. All
comments received will be available for examination at the above
address from 8:30 a.m. to 3:30 p.m., e.t., Monday through Friday,
except Federal holidays. Those desiring notification of receipt of
comments must include a self-addressed, stamped postcard.
FOR FURTHER INFORMATION CONTACT: Mr. Ronald Finn, Office of Motor
Carrier Research and Standards, (202) 366-0647, or Mr. Charles Medalen,
Office of Chief Counsel, (202) 366-1354, Federal Highway
Administration, 400 Seventh Street, SW., Washington, D.C. 20590. Office
hours are from 7:45 a.m. to 4:15 p.m., e.t., Monday through Friday,
except Federal holidays.
SUPPLEMENTARY INFORMATION:
Advance Notice of Proposed Rulemaking
In response to the requirement in Sec. 4007 of the ISTEA that the
Secretary commence a rulemaking proceeding on the need to require
training of all entry-level drivers of CMVs, the FHWA published an
advance notice of proposed rulemaking (ANPRM) on entry-level training
on June 21, 1993 (58 FR 33874). There were 104 comments to the ANPRM,
but no consensus was reached on the issue of mandated entry-level
driver training. The heavy truck and bus industries were against
mandated entry-level driver training. The main objection of these
industries to the proposed training requirement was that the existence
of uniform licensing standards rendered training unnecessary. The
International Brotherhood of Teamsters and the trucking schools were in
favor of the training requirement. The trucking schools argued that if
training was not mandated, the motor carriers and schools generally
would not offer or require training.
Adequacy Study
In order to formulate a basis for the report to Congress on entry-
level driver training required by the ISTEA, the FHWA hired a
contractor to assess the adequacy of entry-level training for CMV
drivers. In analyzing the adequacy of entry-level training, the
contractor examined the training provided to entry-level drivers of
heavy trucks, motorcoaches, and school buses. This examination
disclosed that the percentages of employers who hire entry-level
drivers and provide them with adequate training were as follows: school
bus operator employers (24 percent), motorcoach driver employers (19
percent), and heavy truck driver employers (8 percent).
Consequently, the contractor concluded that neither the heavy
truck, motorcoach, nor school bus segments of the CMV industry provided
adequate entry-level driver training.
Cost-Benefit Study
The FHWA also had the contractor carry out a cost-benefit study of
requiring entry-level driver training.
This study showed that the cost of mandating entry-level training
for 360,000 drivers a year in the heavy truck industry would be $4.5
billion over a 10-year period. The societal benefits of fewer
accidents, reduced health care costs, and reduced delays caused by
accident-related traffic congestion over the same 10-year period were
estimated to range from $5.8 to $15.3 billion.
Report to Congress
The Secretary of Transportation submitted the ``Assessing the
Adequacy of Commercial Motor Vehicle Driver Training: Final Report''
and the cost-benefit analysis to the U.S. Congress on February 5, 1996.
The FHWA is requesting comments from the general public on the
entry-level training final report and cost-benefit analysis prior to
taking any additional action. The FHWA is considering holding a public
meeting at the close of the comment period on the issue of mandating
entry-level training.
[[Page 18356]]
If the FHWA decides to hold such a meeting, a separate notice will be
published in the Federal Register.
Availability of the Report
Copies of the study entitled ``Assessing the Adequacy of Commercial
Motor Vehicle Driver Training: Final Report'' and the cost-benefit
analysis of requiring entry-level training for CMV drivers are
available from the NTIS, U.S. Department of Commerce, 5285 Port Royal
Road, Springfield, Virginia 22161. The telephone number for placing an
order from NTIS is 703-487-4650. The report number is PB 96-141536. The
domestic price per copy is $61.00 while the foreign price is $122.00
per copy. Checks or money orders should be made payable to ``NTIS.''
American Express, VISA, MasterCard, or NTIS deposit account are also
accepted. The final report, consisting of an Executive Summary;
Technical Overview; and Findings, Conclusions, and Recommendations
totals over 550 pages. The Executive Summary of ``Assessing the
Adequacy of Commercial Motor Vehicle Driver Training: Final Report'' is
reproduced as Appendix A to this notice. Two copies of ``Assessing the
Adequacy of Commercial Motor Vehicle Driver Training: Final Report''
and the cost-benefit analysis of requiring entry-level training for CMV
drivers have been placed in FHWA Docket MC-93-12 and are available for
public inspection as noted in the ``Addresses'' section above.
Members of the motor carrier industry and other interested parties
may access a Word Perfect 5.1 version of the report and the cost-
benefit study, through the FHWA's Electronic Bulletin Board System
(FEBBS) using a personal computer and a modem. The FEBBS allows read-
only access to information. Access numbers for FEBBS are (202) 366-3764
for the Washington, D.C. area, or toll-free at (800) 337-3492. The
system supports a variety of modem speeds up to 14,400 baud line
speeds, and a variety of terminal types and protocols. Modems should be
set to 8 data bits, full duplex, and no parity for optimal performance.
Once a connection has been established, new users will have to go
through a registration process. Instructions are given on the screen.
FEBBS is mostly menu-driven and hot keys are indicated by <> enclosing
the hot key. After logging on to FEBBS and arriving at the MAIN MENU,
select for Conference: then for Motor Carrier; then either
for McRegis or for Information (more detailed help).
For technical assistance to gain access to FEBBS, contact: FHWA
Computer Help Desk, HMS-40, room 4401, 400 Seventh Street, SW.,
Washington, D.C. 20590. The telephone number is (202) 366-1120.
Authority: 23 U.S.C. 315; 49 CFR 1.48; Sec. 4007 of Pub. L. 102-
240, 105 Stat, 1914, 2151.
Issued on: April 18, 1996.
Rodney E. Slater,
Federal Highway Administration.
Executive Summary
This document is Volume I of a three volume, final report of a
project titled, ``Assessing the Adequacy of Entry-Level Commercial
Motor Vehicle Training in the Private Sector.'' In this volume, we
summarize the background, methodology, findings, conclusions and
recommendations of the study. Volume II provides a more extensive
technical overview of each of these topics. Volume III contains
detailed discussion of these topics, plus appendices containing a
summary of the literature review and an explanation of training
adequacy scoring.
Background
The Intermodal Surface Transportation Efficiency Act of 1991
(ISTEA), Public Law 102-240 mandates that the FHWA report to Congress
on the effectiveness of private sector efforts to ensure adequate
training of entry-level drivers of commercial motor vehicles (CMVs).
The act directed the FHWA to initiate a rulemaking on the need to
require training of all entry-level drivers of CMVs. If, as the result
of the rulemaking proceedings, the FHWA determines that it is not in
the public interest to require training of all entry-level CMV drivers,
the FHWA must submit a report to Congress explaining the reasons for
this decision, including a cost-benefit analysis.
To satisfy this mandate from Congress, FHWA needed to collect
information that would permit them to determine the adequacy of private
sector training efforts. This project was initiated to support FHWA in
collecting, compiling and analyzing this information.
Objectives
The principal objective of the project was to satisfy the
congressional mandate. In the words of the ISTEA, this meant that the
principal objective was to determine ``the effectiveness of private
sector efforts to ensure adequate training of entry-level drivers of
commercial motor vehicles.'' ``Commercial Motor Vehicles'' for the
purposes of this study included heavy trucks, motorcoaches and school
buses. Each of these CMV types represented a separate private sector.
In addition to determining the adequacy of training, FHWA must go
further and determine whether or not it is in the public interest to
require training of all entry-level CMV drivers. So, an important
secondary objective of the study was to support FHWA in its decision-
making process.
Conclusions and Recommendations
This section presents the conclusions and recommendations of the
study. The first subsection below addresses the conclusions related to
the training adequacy issue. The next subsection presents conclusions
related to the various factors that could affect FHWA's decision making
process. Finally, recommendations are presented for future actions.
Data and discussion to support the conclusions and recommendations
occur in later sections.
Are the Private Sectors Effective at Ensuring Adequate Training?
Are the three private sectors--heavy trucks, motorcoaches and
school buses--effective at ensuring adequate training for their entry-
level drivers? The conclusion of this study is that none of the three
private sectors are effectively providing adequate training. What
evidence exists that the training is inadequate? The data comes from
both the motor carriers and the drivers surveyed in this study.
Table 1 presents data for the motor carriers. The first row of the
table shows the percent of motor carriers hiring entry-level drivers
that provide formal training for them. The percentages are calculated
from data in Volume III, Tables 3.3, 4,3 and 5.2. For example, Table
3.3 shows that 24 of the 111 heavy truck carriers who hire entry-level
drivers provide formal training. This calculates to 21.6 percent, as
shown in Table 1. The second row in Table 1 shows the percent of motor
carriers whose formal training was judged as ``Adequate.'' For
motorcoaches and school buses, the percentages comes directly from
Volume III, Tables 4.5 and 5.4. For heavy trucks, the percentage is
derived from Table 3.5 by combining the Number Adequate values for For-
hire and Private Fleets (i.e., nine of the 24 company programs were
adequate). The third row in Table 1 provides an estimate of the percent
of motor carriers hiring entry-level drivers that provide adequate
training for them. This figure is obtained by combining the data in the
first two rows. For example, if 21.6 percent of the heavy truck
carriers hire entry-level drivers and provide formal training for them,
but only 37.5 percent of the carriers had adequate formal
[[Page 18357]]
training, then multiplying 21.6 by .375 gives 8.1 as the estimate of
the percent of heavy truck carriers that provide adequate formal
training.
``Effectiveness'' was defined as the prevalence or frequency with
which the motor carriers in each domain provided formal training for
their entry-level drivers. Some sort of formal training (as defined
later in this document) was deemed necessary in order to provide the
opportunity for development of the essential knowledge, as well as the
minimum skills, needed to operate the CMV. That is, just because a
motor carrier offers formal training does not mean that the training is
adequate, but it would be very difficult for a carrier's training to be
judged adequate, unless it was formal.
See the End of the Report for Table 1
As can be seen from the table, relatively few (22 percent) of the
heavy truck motor carriers surveyed that hire entry-level drivers
provided formal training for them. However, well over half of the
motorcoach and school bus carriers that hire entry-level drivers did
so.
``Adequacy'' was defined in terms of how the formal training
provided by a sub-sample of the carriers in each domain compared to the
recommended minimum requirements for entry-level driver training
established by industry experts. To be judged ``Adequate,'' a program
had to be, on average across various sub-scores, in conformance with
the criteria set by these experts. (The scoring system is described
later in this document and in Volume III, Appendix B.)
The table shows that only about one-third of the carriers with
formal training that were sampled had training that was adequate. The
heavy truck private sector had the largest percentage of adequate
training programs and the motorcoach private sector, the smallest. The
third line of the table combines the prevalence information (the first
line) and the adequacy information (line two) to provide an estimate of
what percentage of the motor carriers in each domain, that hire entry-
level drivers, provide adequate training for them. The motor carrier
findings can be summarized as follows:
--The heavy truck private sector has the smallest percentage of
carriers offering adequate training (about 9 percent). This means that,
of those heavy truck carriers that hire entry-level drivers, only about
one in ten would be expected to provide adequate training.
--The school bus private sector had the largest percentage of carriers
providing adequate training (about 24 percent). Even with this, the
highest percentage, only about one carrier in four carriers would be
expected to provide adequate training.
None of the private sectors can be considered effective in ensuring
adequate entry-level training, given these figures.
While Table 1 provides an estimate of the number of motor carriers
in each domain that provide adequate training, a more basic question
is, ``What percent of the drivers are being adequately trained?'' Also,
it is known that publicly funded and proprietary schools are other
sources of formally trained drivers for the heavy trucking industry, so
a second question is, ``To what extent do the schools add to the
percent of adequately trained truck drivers?''
Data to answer these questions come from Tables 3.15, 3.18, 4.9,
4.11, 5.8, and 5.10 in Volume III, which present findings from the
Driver surveys. Several of the industry experts supporting the project
indicated that training within the heavy truck industry has improved
substantially within the last five years. So, it was considered
desirable to examine the data for ``New'' drivers only, i.e., drivers
with five or fewer years experience. The data for New drivers are
compiled and summarized in Table 2 below.
It can be seen that about 62 percent of the 141 heavy truck drivers
in the sample report receiving formal entry-level training. There were
four sources of this formal training. By far, the most frequently
reported source was proprietary schools (48 percent) followed by
publicly funded schools (about eight percent). Military schools and
company-operated schools combined accounted for only about six percent.
The second column of the table indicates what percentage of the
drivers receiving each type of formal training reported receiving
training that was judged as ``Adequate.'' The criteria used to evaluate
the training reported by the drivers were the same as those used to
evaluate the company training programs, as reported in Table 1 above.
The estimate of the percent of drivers adequately trained (the
third column) was derived from the first two. For example, 44.8 percent
of the 47.5 percent of drivers reporting proprietary school training
received adequate training. So, 47.5 times 0.448 equals 21.3 percent as
the estimate of the percent of New drivers who receive adequate
training from this source. Publicly funded schools contribute another
4.2 percent and the combination of military and company schools account
for 5.6 percent.
See End of the Report for Table 2
To summarize, 62 percent of the New heavy truck drivers reported
receiving formal training, about 50 percent of which scored as
adequate. This resulted in the estimate that 31 percent of New heavy
truck drivers are receiving adequate training. It is interesting to
compare these numbers with the numbers (not shown in the table) of the
``Experienced'' driver group. These are drivers who have been driving
between six and 10 years. About 32 percent of the 229 Experienced
drivers reported receiving formal training, about 51 percent of which
scored as adequate, resulting in the estimate that about 16 percent of
the Experienced drivers received adequate training. So, while the
percentage of New drivers who report receiving formal training is
almost twice that of Experienced drivers, the percent receiving
adequate training is the same. The percentage of New drivers that
receive adequate training is higher than for Experienced drivers
because more New drivers receive formal training, not because a greater
proportion of that formal training is adequate.
Comparing the Percent Drivers Adequately Trained figures from the
table, it can be seen that the figure for School Buses is highest
(about 35 percent) followed closely by Heavy Trucks (31 percent) then
Motorcoaches (18 percent).
It is possible to answer the two questions that began this
discussion as follows:
--How many drivers are adequately trained? For new drivers (driving
five years or less), between 18 and 35 percent are adequately trained,
although these figures may be optimistic.
--To what extent do the schools contribute to the percent of adequately
trained truck drivers? They contribute substantially. The proprietary
and publicly funded schools produced about seven times the number of
adequately trained heavy truck drivers as did the company programs.
Based on the driver data, are the private sectors effective at
ensuring adequate entry-level training? At best (school buses), only
one-third of the recently trained entry-level drivers received adequate
training and more than 40 percent of the reported training was not
adequate. At worst (motorcoaches), only about two in ten drivers
received adequate training, two-
[[Page 18358]]
thirds of the formal training was not adequate, and 50 percent of the
drivers did not even receive formal training. Given these statistics,
none of the private sectors can be considered as effective in ensuring
adequate training of their entry-level drivers.
Thus the conclusions are the same, whether the data upon which they
are based comes from the motor carriers (i.e., Table 1) or the drivers
(Table 2).
There are three corollary issues related to training adequacy that
deserve mention. The first has to do with ``exemplary'' training
programs/activities. In order to assure that the study did not overlook
good training programs or activities that were being carried out in any
of the domains, survey respondents were asked to identify programs/
activities they believed were exemplary, i.e., worthy of imitation. It
should be emphasized that no criteria were imposed on the respondents--
they used their own criteria to determine what was exemplary.
Information was collected on these programs and their adequacy was
scored.
The heavy truck respondents had no trouble identifying programs
they thought were exemplary. Nearly all of the 27 programs they
identified involved formal pre-service training. Fourteen (14) of the
programs were run by carriers and, of this group, almost half included
on-the-job training. The five programs recommended by the motorcoach
respondents were formal training. Only one of the school bus
respondents was able to recommend an exemplary formal training program.
In general, the adequacy of the ``exemplary'' programs was no
better than the adequacy of the programs selected at random from the
various domains. The programs recommended by our heavy truck
respondents as being exemplary did not quite achieve the minimum
standards determined by our trucking industry experts. On average, the
motorcoach exemplary programs scored at about the recommended minimum
level. The one school bus exemplary program was above the minimum
standard.
Examination of the ``exemplary'' programs provided corroboration
that the programs selected at random, at least from the heavy truck and
motorcoach domains, were representative of the industries as a whole.
The second corollary issue relates to how big a motor carrier must
be in order to provide formal training. Across all domains, even the
smallest carriers offered formal training. While most of the exemplary
programs were operated by medium to large carriers, several adequate or
better heavy truck and motorcoach programs were operated by small
carriers. It is apparent that adequate entry-level training need not be
limited to the larger carriers.
The third corollary issue relates to industry plans that could
result in future improvements in training program adequacy. Across all
domains, few motor carriers, associations or insurance companies
expressed plans that would increase the prevalence of formal training
of entry level drivers. As noted earlier, without at least increasing
the prevalence of formal training, it would be difficult for the
overall adequacy of the training to improve. Therefore, it appears that
the present level of training adequacy is not likely to improve due to
the actions of the private sectors themselves.
What Are the Decision Factors and the Conclusions Related To Them?
Four decision factors (in addition to the adequacy of training)
were identified that should be considered in determining FHWA's
response to Congress. These decision factors are as follows:
--The accident problem, including both the magnitude of the accident
problem and recent trends.
--The effectiveness of training as a solution to the problem, i.e., the
relationship between training and accident reduction.
--The impact of mandated training, including factors that will
negatively impact the condition of the industry, if training is
required, such as:
--The impact of other Government Regulations.
--Driver turnover.
--Driver demand/shortage.
--Existence/effectiveness of other government programs, including the
potential impact of the Commercial Drivers License (CDL), as well as
the impact of other Government programs (if any) intended to reduce the
CMV accident problem.
The conclusions of the study with regard to each of these factors
are presented below. To provide perspective, the size of the industries
(private sectors) is summarized prior to the presentation of the
conclusions themselves.
Size of the Industry. The heavy truck domain is by far the largest
of the three domains, and the motorcoach domain is the smallest. The
heavy truck domain is also the most complex of the three. It is
comprised of a number of different types of carriers, each with its own
unique characteristics, problems and needs. In particular, the
specialized fleets have different (but over-lapping) entry-level
training needs, when compared to the needs of the for-hire and private
carriers of cargo.
The accident problem. Discussion of the accident problem must
include both the magnitude of the problem today and the problem trend
over recent years.
Concerning the magnitude of the problem, the tabulation below shows
the number of crashes, injuries and fatalities for each of the domains
(to the extent known), for 1990:
------------------------------------------------------------------------
School
Trucks Motorcoaches buses
------------------------------------------------------------------------
Number of Crashes............ 318,500 Unknown.............. 28,500
Number of Injuries........... 130,000 Unknown.............. 24,000
Number of Deaths............. 5,254 39................... 128
------------------------------------------------------------------------
The table shows that, in absolute numbers:
--Heavy truck accidents result in far more fatalities than either
motorcoaches or school buses.
--School buses are involved in far fewer crashes, injuries and
fatalities than large trucks, but they have about three times the
fatalities of motorcoaches.
Our data source for non-fatal accidents does not discriminate among
school buses, intercity buses (i.e., motorcoaches) and transit buses.
However, it estimates that in 1990, injuries in bus accidents account
for only about 1.1 percent of the injuries for all accidents (as
compared to about 4 percent for medium and large trucks). For 1992, the
bus injury accidents were about 0.7 percent of the total.
In addition:
--Heavy trucks have less than half as many accidents per 100 million
miles
[[Page 18359]]
traveled than passenger vehicles, but they have 56 percent more fatal
accidents.
--In about 25 percent of the fatal accidents, the truck driver was
reported to have made an error or otherwise contributed to the
accident; in 72 percent of these accidents the other driver was
reported to have made an error, but not the truck driver.
Conclusions concerning the magnitude of the accident problem are as
follows:
--It is clear that, for fatal accidents, heavy trucks have the greatest
problem, followed by school buses, then motorcoaches. The percentage of
all injuries attributed to bus accidents (motorcoaches, school buses
and other types combined) is only about one-fourth of the percentage
attributed to trucks.
--Truck drivers are involved in fewer accidents per 100 million miles
driven than passenger vehicle drivers and they are less likely to be
noted as having made an error contributing to the accident. However,
when a truck driver is involved in an accident, it is more likely to
involve at least one fatality. Comparable data were not available for
motorcoach and school bus drivers.
With regard to accident trends, there are three conclusions:
--For heavy trucks, fatal accidents are less frequent (relative to the
number of miles driven by trucks) than ten years ago. The vehicle
involvement rate per 100 million miles traveled reduced from 5.8 in
1980 to 3.9 in 1990.
--The fatal accident involvement rate per 100 million miles traveled
has decreased over the 11 years period between 1980 and 1990 by the
same amount (32 percent) for both heavy trucks and passenger vehicles.
Heavy trucks decreased from 5.8 to 3.9 and passenger vehicles decreased
from 3.7 to 2.5. ``Passenger Vehicles'' are defined as vehicles,
including automobiles and light trucks, with GVWRs of 10,000 pounds or
less.
--There does not appear to be any trend in the accidents rates for
motorcoaches and school buses.
There are at least two implications for decision-making within
these conclusions:
--The magnitude of the accident problem parallels the size of the
industry, i.e., heavy trucks is the largest industry and has the
highest fatalities. However, heavy truck fatalities appear to be over-
represented when size of the industry (number of drivers) is taken into
consideration. The number of truck drivers is estimated to be about
5,600,000 while the number of motorcoach drivers is estimated at
156,000 and the number of school bus drivers at 742,000. There were
5,254 fatalities involving heavy trucks in 1990, 39 involving
motorcoaches and 128 involving school buses. This calculates to 0.93
fatalities per 1000 truck drivers as compared to 0.25 fatalities per
1000 motorcoach drivers and 0.17 per 1000 school bus drivers.
This should not be taken to mean that truck drivers are poor
drivers. The difference in the fatality rates is more likely due to
exposure--the truck drivers drive more miles on average than motorcoach
and school bus drivers. So, they are at higher risk of accident
involvement. However, it does imply that any efforts to improve the
safety of truck drivers (such as requiring adequate safety training)
will likely have a greater return, in terms of accidents avoided, than
the same efforts aimed at motorcoach and school bus drivers. Some ANPRM
and survey respondents indicated that training should not be mandated
because the industries are already doing a good job with various
activities intended to reduce accidents. The trend data do show a
reduction in fatality rates for combination trucks, but a reduction of
the same magnitude occurred for passenger vehicles. It was beyond the
scope of this study to determine the reasons for the declines. However,
given the data available to the study, it was not possible to
demonstrate any special effect of industry training activities, beyond
whatever factors could be causing a general decline for both trucks and
passenger vehicles.
The effectiveness of training as a solution to the problem. The
findings as to the effectiveness of training were contradictory. While
some in-house studies by carriers reported that training reduced
accidents, other studies using random samples of drivers (including
this study) noted a tendency for trained drivers to have slightly more
accidents. Some researchers have attributed this tendency to the high
variability in training quality, indicating that poor training may give
the new driver a false sense of confidence in his/her abilities.
However, this study found no evidence of a relationship between
adequacy of the training the driver reported receiving and his/her
frequency of accidents.
What implications for decision-making can be derived from these
contradictory findings? The answer to this question seems to be that,
while adequate training is a necessary condition for the reduction of
CMV accidents, it is not a sufficient condition. Something more has to
happen in order for training to have its effect. A discussion of these
additional factors is contained in Volume III, Section 7.
The impact of mandated training. Survey respondents were asked
whether mandated training would impact the condition of the industry or
the drivers, the turnover problem or the driver shortage problem. For a
given question, the individual groups within a domain sometimes
differed greatly in their response distributions. However, none of the
samples provided a uniformly extreme response to any of the questions.
There was no consensus in the samples that requiring entry-level
training would strongly influence any of these factors, one way or the
other.
The following statements capture the general nature of the opinion
within each domain:
--There are probably more people presently against mandated training
than are for it, but not by a large margin. While the responses to the
Advance Notice of Proposed Rulemaking (the ANPRM, as discussed in a
later section) were heavily against mandated training, the responses of
the random samples surveyed in this study were more equally divided (as
discussed above). In addition, the CVSA Survey respondents were
overwhelmingly in favor of mandated training. However, these persons
were already drivers and not likely to be affected by the mandate.
--The majority of each domain could support mandated training if a
program were developed that addressed and resolved the numerous
economic and administrative issues. This is based on the responses to
the ANPRM as well as comments made by the respondents to this study.
--There is also a substantial number of people who would support a
performance-based (i.e., testing) alternative centered around
strengthening the existing CDL program. The basis for this statement
comes mainly from the responses to the ANPRM.
Clearly, any decision made by FHWA will have supporters and
detractors. However, opposition will be reduced to the extent that the
program (if any) promulgated by the agency addresses the economic and
administrative issues.
[[Page 18360]]
Existence/effectiveness of other government programs. The
conclusions related to this decision factor are as follows:
--Concerning the CDL program, the large majority of the survey
respondents believed that the CDL would increase the likelihood of
adequate training. The majority of the drivers believed that their CDL
training went beyond what they needed to pass the CDL tests. There
appears to be a general agreement that the CDL will have a positive
impact on the adequacy of training.
--Concerning other government programs, it was concluded that:
--The activities of the Research and Special Programs Administration
(RSPA) also includes the training of heavy truck drivers who transport
hazardous materials. However, RSPA's intent is generally to prevent
incidents involving hazardous cargo, rather than teaching driving
skills to drivers. So, there is no conflict, and minimal overlap, with
the driver training promulgated by RSPA.
--There appears to be nothing in any of the other programs that would
conflict with, or substitute for, an intervention strategy intended to
reduce CMV accidents.
Recommendations
It was stated earlier that none of the private sectors--heavy
trucks, motorcoaches or school buses--are effectively providing
adequate training. Data were presented to support the fact that none of
the private sectors were totally effective in providing formal training
for their entry-level drivers, i.e, the prevalence of formal training
in all sectors could be improved. Data were also presented to show that
relatively few of the formal training programs that were provided met
the study criteria for adequacy.
However, FHWA should not make a decision concerning any
intervention strategy, including requiring entry-level training, based
on prevalence and adequacy information alone. The other decision
factors discussed in this report must be considered in determining
whether it is in the public interest to take some action, and for
determining which action to take.
The data on the accident problem lead to one recommendation: If it
is desirable to target fewer than all three domains, the heavy truck
domain should be considered first priority, followed by motorcoaches.
The study data and the ANPRM responses suggest that there are three
intervention strategies (in addition to doing nothing at all) that FHWA
should consider:
--Training-based. This strategy involves requiring the training of
entry-level CMV drivers.
--Performance-based. With this strategy, entry-level CMV drivers would
be required to pass more comprehensive knowledge and skill tests than
are presently required to obtain a Commercial Drivers License (CDL).
--Industry-based. Here, reduction in CMV accidents would be achieved by
means of a carefully structured set of cooperative FHWA-industry
initiatives intended to encourage better training of CMV drivers.
The conclusion was stated earlier that training, by itself, is not
sufficient to reduce CMV accidents. This suggests that a combination of
the above strategies would produce the best results. Either the
Training-based strategy (which regulates the content of training) or
the Performance-based strategy (which regulates the outcome of
training) should be combined with the Industry-based strategy.
Which strategy--Training-based or Performance-based--should be
selected? There are compelling arguments for both strategies. The
Training strategy permits detailed control of the training content,
even content like attitudes and accident avoidance skills, that is
difficult to measure on a performance test. The Performance strategy
provides the industries with greater flexibility in training their
drivers, and the CDL structure exists as a starting point.
A more extensive analysis is needed to determine which alternative
is preferable. To select between the two strategies, the recommended
next steps are as follows. FHWA should:
--Develop draft program specifications. The objective should be to
describe model Training and Performance-based programs in enough detail
that their respective costs and impacts can be assessed. The
Recommendations section in Volume II provides a listing of the elements
that should be included in the program specifications.
--Obtain feedback on the draft programs from industry and the states.
Revise the program specifications to address problems, reduce costs and
improve potential effectiveness.
--Select between the two programs based on which provides the better
cost/effectiveness.
One possible outcome of the above process could be a hybrid
program, i.e., a combination of the Training- and Performance-based
approaches that embodies the advantages of each.
When a strategy is determined, detailed training/performance
standards should be developed. To establish the groundwork for
standards development, it is recommended that FHWA adopt the three-
element definition of entry level training that was used in this study,
rather than pre-service training alone.
In this study, entry-level training was defined as all training
received during the first three years of the driver's experience.
Entry-level training included the following three elements:
--Pre-service Training. This is training received prior to starting
work as a CMV driver. Pre-service training is the most reliable way to
provide the basic skills and knowledge needed before the new driver
goes on-the-job.
--On-the-job Training (OJT). OJT is provided when the new driver first
begins actually hauling cargo or passengers. It provides a cost-
effective way for the new driver to develop his/her skills.
--In-service Training. In-service training includes those activities
provided by the motor carrier that are specifically intended to improve
the safety- related skills and knowledge of its drivers, including (but
not necessarily limited to) entry-level drivers. In-service training
provides a means of refreshing skills, such as accident avoidance, that
can degrade over time.
To develop the standards:
--The model tractor-trailer curriculum should be revised and expanded
to include OJT and In-service training. This revised curriculum would
be an essential component of either the Training-based or the
Performance-basedstrategy.
--If the intervention is to include motorcoaches and/or school buses,
FHWA should develop three- element model curriculum specifications for
operators of these CMVs. These curricula should be developed in close
cooperation with motorcoach and school bus industries.
FHWA should consider revising the model tractor-trailer curriculum,
and developing the model motorcoach and school bus curricula, even if
FHWA decides not to proceed with required training or some other
intervention strategy. The existence of these up-to-date standard
curricula will make it easier for concerned elements within the private
sectors to voluntarily implement adequate formal training.
With regard to the Industry-based strategy, the recommended first
step is to investigate and select initiatives for inclusion in the
program. Possible initiatives are discussed in Volume III, Section 6.
Once additional data are
[[Page 18361]]
collected, FHWA should develop a program specification for this
strategy. It is recommended that FHWA advocate and act to initiate some
form of Industry-based program whether or not a Training- or
Performance-based program is carried out.
Supporting Detail
The remainder of this document contains summaries of study findings
from which the foregoing conclusions and recommendations were derived.
The section begins with a description of the scope of the effort and
the definition of key concepts. Then the study methodology is briefly
described. After this, the supporting detail leading to the conclusions
and recommendations is summarized in the same order that the
conclusions were presented in the previous section.
Scope of the Effort
Several definitions and decisions were made early in the project
that limited the scope of the study. They are described below.
Commercial Motor Vehicles Included in the Study. ``Commercial motor
vehicle'' was defined in accordance with the Commercial Motor Vehicle
Safety Act of 1986. The study included all heavy duty trucks (i.e.,
over 26,000 Gross Vehicle Weight Rating), but passenger carrying CMVs
were limited to Long Haul Regular Route (LHRR), Charter/Tour (C/T) and
School Buses. Private Motor Carriers of Passengers (PMCP) and Metro/
Transit Buses were excluded because they were not generally subject to
the Federal Motor Carrier Safety Regulations (FMCSRs) at the
commencement of the study. However, PMCPs are presently subject to the
FMCSRs.
Thus, the study focused on three CMV ``domains'': Heavy duty trucks
(hereafter referred to as ``Heavy Trucks''), Motorcoaches (including
long haul and charter/tour buses) and School Buses.
Scope as Related to Hazmat Vehicles. With regard to vehicles used
in the transportation of hazardous materials requiring placarding
(``Hazmat'' vehicles), the study was limited to determining the
prevalence and adequacy of the entry-level driving training received by
drivers of these vehicles.
What is the ``Private Sector?'' In this study, the terms
``industry'' and ``private sector'' are used interchangeably. There is
a different ``private sector'' or ``industry'' for each of the three
CMV domains - heavy trucks, motorcoaches, and school buses.
A private sector includes companies, organizations, and individuals
that have a direct interest in the transportation-related activities
surrounding that particular domain and that are in a position to
impact, directly or indirectly, the training of entry-level drivers.
These groups and individuals fall into the following categories and
subcategories (although not all private sectors have them all): driving
schools (proprietary, publicly funded and company-operated),
certification/accreditation groups, motor carriers, associations
(including unions), insurance companies and drivers.
Definition of ``Adequate Training.'' Two focus groups were
assembled, one from the trucking private sector and the other from the
motorcoach and school bus private sectors. They were asked to define
the minimum acceptable curricula for entry-level heavy truck,
motorcoach, and school bus training. They reached consensus on minimum
criteria on eight factors including classroom hours, practice (off-
street and on-street) hours, student/teacher ratios, behind- the-wheel
time and course content topics.
An adequacy scoring algorithm was derived that consisted of eight
adequacy sub-scores and an Overall Adequacy Score (OAS). An adequacy
sub-score reflects the extent to which a training program (or the
training reported by a driver) deviates from a training criteria. For
example, a school program that has a score of zero (0) on the Class/Lab
Hours Sub-score would be exactly in conformance with the number of
class/lab hours recommended by the experts. The OAS is the average of
the eight sub- scores. So, a school with an Overall Adequacy Score of
-11 has adequacy sub-scores that are, on average, 11 percent below the
criteria values established by the experts.
Details concerning the criteria and the adequacy scoring procedures
are contained in Volume III, Appendix B.
Support for Rulemaking
In addition to carrying out data collection activities for the
decision factors listed above, another aspect of the project involved
providing support for the rule making process.
The ISTEA required FHWA to issue a rulemaking on the need to
require training of all entry-level drivers of CMVs. As a first step in
rulemaking process, the Federal Highway Administration published an
Advance Notice of Proposed Rulemaking (ANPRM) titled, Training for All
Entry Level Drivers of Commercial Motor Vehicles (CMVs) in the 21 June
1993 issue of the Federal Register. The responses to the ANPRM were
analyzed, organized and abstracted for this report.
Methods
The collection of data for the study involved six data collection
activities:
--Industry Surveys. Representatives of the private sector (as defined
above) of each domain were interviewed.
--Schools Surveys. A random sample of the schools that presently
provide training for entry-level drivers in each domain were surveyed.
The term ``school'' was defined broadly to include motor carriers who
provide formal training for their own entry-level drivers, as well as
proprietary and publicly funded schools.
--Driver Surveys. The drivers themselves were interviewed.
--Accident Data Collection. Truck, motorcoach and school bus accident
and accident trend data were obtained from National Highway Traffic
Safety Administration and National Safety Council Publications.
--Federal Agencies Data Collection. Federal government agencies were
contacted to determine the existence of policies, regulations or
practices that could impact the effectiveness of the private sector's
efforts to ensure adequate training of entry-level CMV drivers.
--CVSA Data Collection. The Commercial Vehicle Safety Alliance (CVSA)
agreed to include eight questions about driver training in their
Roadcheck '93 survey. This survey was performed in June 1993.
In addition to the data collection activities listed above, there
was a seventh data collection activity referred to as the Exemplary
Programs Data Collection. This activity was considered apart from the
others because it did not directly impact any of the decision factors.
The goal of the Exemplary Programs data collection was to identify
the best of the training programs that presently exist within each
domain, i.e., to define what is possible for the industry to
accomplish. Exemplary Programs were identified by the Industry Survey
samples and contact was made with these organizations to obtain
information about the programs/activities.
The adequacy of the entry level formal training programs
recommended as being exemplary was determined, as was the adequacy of
the formal training programs identified from our random samples of
schools and motor carriers. We also examined the adequacy of the entry-
level training described by our driver samples.
Table 3 shows the number of industry organizations of each type
that were included in the Industry Survey for each
[[Page 18362]]
domain. It also shows the number of schools, exemplary programs and
drivers surveyed.
In addition, a total of 5869 CVSA questionnaire forms were received
and analyzed. As expected, very few buses (only 17) were included in
the sample. The large majority of the drivers (88.6 percent) were
operating tractor/single trailer combinations, but a small number (146)
of twin, double and triple drivers were included. Straight trucks
comprised 8.5 percent of the sample.
See end of the Report for Table 3
Prevalence/Adequacy of Private Sector Programs
The study focused on three types of private sector programs:
--Training Programs, i.e., formal, structured courses.
--Training Activities, i.e., isolated, short duration, events such as
watching videos, reading manuals and attending safety meetings.
--Training Support Activities, i.e., anything that encouraged/supported
the actual training of entry- level drivers.
In the following paragraphs, the findings for the ``exemplary''
programs recommended by our survey respondents will be summarized
first, then the findings obtained from our random samples of industry
associations, motor carriers and schools.
Exemplary Training Programs/Activities. The exemplary training
programs and training activities are first described and then their
adequacy is discussed.
What is an Exemplary Training Program/Activity? The heavy truck,
motorcoach and school bus Industry survey respondents were asked to
recommend training programs or training activities that they believed
were exemplary, i.e., worthy of imitation by the rest of the industry.
The respondents were free to define exemplary programs/activities using
any criteria they chose.
Program/Activity Descriptions. The heavy truck industry survey
respondents recommended 27 exemplary training programs/activities.
Fourteen (14) were company-operated training programs. The companies
themselves were generally large to very large. Nearly all reported that
they require their entry-level drivers to have graduated from a truck
driving school and they provided on-the-job training (OJT) ranging from
four weeks to six months. Six reported that they operate their own
company schools.
Thirteen (13) were school programs. All reported offering classroom
instruction and both range and on-street practice. The average duration
for the proprietary schools was 235 hours; for the publicly funded
schools it was 334 hours.
Five motorcoach exemplary training programs were identified, all
carried out by Long Haul Regular Route motor carriers. These companies
were medium in size to very large and the schools ranged in duration
from 152 hours (including 50 hours on-the-job) to 250 hours.
Four school bus exemplary programs/activities were identified, but
only one was a formal training program. The program had a total
duration of 40 hours with 10 hours of actual behind-the-wheel time per
student.
Proportionally more exemplary training programs/activities were
identified by the heavy truck group. Possibly one reason is that the
training of drivers has higher visibility in the trucking industry due
to the public attention that has been focused on truck safety in the
last few years.
Adequacy. We determined adequacy scores for the exemplary formal
training programs. The Overall Adequacy Scores (OASs) were as follows:
--For heavy trucks, the mean OAS across the 17 programs was -11 (i.e.,
the sub-scores were, on average 11 percent below the criterion values).
Seven of the programs (41 percent) were adequate, i.e., had zero or
higher Overall Adequacy Scores.
--For motorcoaches, mean OAS for the five programs was -1.6. Two of the
five programs had an OAS of zero or higher.
--The OAS for the one exemplary school bus program was +16.1.
Sampled Training Programs/Activities. Within the Industry Survey
groups, with one exception, only the motor carriers and schools
actually trained drivers, i.e., had formal training programs or
training activities. The one exception was the teamsters union, which
does provide formal training.
Prevalence. Table 4 compares the three domains in terms of the
proportions of each that hire entry level drivers, and that provide
either formal training or training activities for them.
While over half of the heavy truck and motorcoach motor carriers
hire only experienced drivers, over 95 percent of the school bus fleets
hire entry level drivers. Also, not only are the heavy truck motor
carriers least likely to hire entry-level drivers, they are also the
least likely to provide formal training for them, once they are hired.
Concerning the sizes of the fleets reporting formal training:
--Heavy truck carriers of all sizes report that they provide formal
training, but 58 percent of the fleets in our sample larger than 200
drivers provide formal training, while only six percent of the smaller
companies do.
--Motorcoach carriers of all sizes reported that they provide training.
LHRR fleets as small as 15 drivers, and C/T fleets as small as nine
drivers, reported having formal training.
--School bus fleets of all sizes offer formal training.
See End of Report for Table 4
Effectiveness. Table 5 summarizes the adequacy score data for the
random samples of formal training programs across the three domains.
The tabulation shows that, for heavy trucks, the mean Overall
Adequacy Score (OAS) for the schools was substantially lower than the
mean OAS for the company operated programs.
Comparing company programs across the three domains, it is clear
that the heavy truck company programs group has the highest mean OAS.
On average, they were about 20 percent above the criterion values, as
compared to only about 2 percent for the school bus programs and a
minus 17 percent for the motorcoach programs. Also, more of the heavy
truck company programs scored zero of better.
Plans for the Future. The following summarizes the plans for future
training programs and activities reported by our Industry Survey
groups:
--Within the heavy truck domain, only 10 percent of the for-hire fleets
and 18 percent of the private fleets had plans. Generally, these plans
were vague and uncertain, beyond obtaining and showing videos and
hiring instructors.
--Only about 14 percent of the motorcoach motor carriers had any plans,
and these were for training activities. The activities mentioned
included a defensive driving course, videos, safety meetings and a
driver recertification program.
See End of Report for Table 5
--Only about one-third of the school bus motor carriers have plans for
future training activities. Three of the operators are uncertain what
they are going to do and two expect to implement formal training
courses.
Size of the Industries
The following tabulation provides estimates of the number of motor
carriers and drivers in each of the three domains.
[[Page 18363]]
------------------------------------------------------------------------
Heavy School
trucks Motorcoaches buses
------------------------------------------------------------------------
Number of fleets.................... 230,000 5,000 14,700
Number of drivers................... 5,600,000 156,000 742,000
------------------------------------------------------------------------
Each of the domains may be further characterized as follows:
--Heavy truck fleets and drivers are approximately equally divided
between for-hire and private motor carriers (including specialized
fleets, e.g., fleets operated by utility companies, construction
companies and refuse haulers). There are about 100,000 owner-operators.
--Of the 5,000 motorcoach fleets presently in operation in the United
States, about 114 are Long Haul Regular Route carriers who employ about
9,400 drivers.
--The 14,700 public school districts that bus students are divided into
3,280 private fleets (contractor operated) and 11,420 public fleets
(school system operated). As to the number of drivers, for private
fleets this estimate is 262,400 drivers and for public fleets, 479,700
drivers.
Relationship Between Training and Accident Reduction
The Industry Survey representatives, the motor carriers and the
schools were asked for any data they had demonstrating the relationship
between training and accidents. Three heavy truck motor carriers
reported in-house studies indicating that training reduced accidents.
None of the motorcoach or school bus respondents were able to identify
relevant studies.
Early in this project, a literature search was carried out to
determine, in part, the extent to which driver training impacts
accidents. Two studies were found that reported accident reduction
following school bus driver training: One reported a 23 percent
decrease in accidents and the other a 22 percent reduction in driver at
fault accidents, during a period in which the number of miles driven
doubled. There were no studies providing information on the link
between training and accident reduction for motorcoach drivers.
However, four other studies found that formally trained drivers
reported having the same or slightly more accidents than drivers
trained informally. The earliest study was published in 1979. It
reported, based on a survey of U.S. truck drivers, that trained drivers
indicated having more accidents than drivers who were not trained. The
Regular Common Carrier Conference (RCCC) asked truck drivers about the
training they received and their accident experience as part of the
motor carrier safety surveys they conducted in 1987, 1988 and 1989.
Analysis of the 1988 survey responses (878 combination truck drivers)
showed that 41 percent of the trained drivers had a truck accident in
the previous five years, compared to only 32 percent of the drivers
without formal training. This was a statistically significant result
(.05 level). A similar result was obtained in the previous year's
survey (1,762 interviews), although no detail was provided. The 1989
survey showed about the same level of accidents for trained (27
percent) and non-trained (29 percent) drivers.
A GAO report describes the wide variation in truck driver training
and the RCCC citations make the point that this variability may mask
the effect of good training. They indicate that their finding ``* * *
points to the need for establishing and maintaining high standards so
that drivers are taught accident-reducing skills, rather than given a
false sense of security.''
In this study, data on drivers' accident history was also
collected. Here also, the formally trained drivers reported having
somewhat more accidents, across all three domains. It was expected that
drivers whose training scored as adequate (i.e., an OAS of zero or
higher) would have fewer accidents than those whose training scored
lower. However, there was no suggestion of a consistent relationship
between training adequacy and accidents in the data. In fact, there
were individual drivers reporting one or more accidents who had
relatively high adequacy scores.
The Impact of Mandated Training on the Industries
Table 6 summarizes the responses of the Industry Survey respondents
in each of the three domains to the eight questions related to the
condition of the industries and the impact of mandated training.
Existence of Other Government Programs
This research area addresses the potential impact of the CDL and
the identification of other Federal government programs that might
interact, conflict or be redundant with mandated training (or some
other intervention strategy).
Potential Impact of the CDL. Data relating to the impact of the CDL
came from our survey respondents from the Industry, Schools and Driver
Surveys, and the ANPRM commenters.
Industry and Schools Surveys Findings. We asked our Industry and
School Surveys respondents, ``What effect, if any, do you think CDL
testing will have on the likelihood that entry-level [name of domain]
drivers will be adequately trained?'' Almost 65 percent of the heavy
truck sample, 74 percent of the motorcoach sample and 64 percent of the
school bus sample said it would increase the likelihood.
Driver Survey Findings. We asked our drivers who began driving on
or after the time when the CDL went into effect, ``How well did your
training prepare you for the CDL [Knowledge or Skill] test?'' The
responses were as follows:
--For the knowledge test question, the most frequent response (across
all domains) was, ``Gave me somewhat more knowledge than I needed.''
--For the heavy truck and school bus samples, the most frequent
response to the skill test question was ``* * * somewhat more practice
than I needed.'' For the motorcoach sample it was, ``Gave me just
enough practice.''
See End of Report for Table 6
Other Government Programs Potentially Impacting an Intervention.
Two listings of government programs/initiatives were identified, in
addition to the CDL, that will or could interface with any FHWA
program/initiative to reduce CMV accidents. The first listing
identifies those government agencies that regulate the activities of
fleet operators/drivers and/or make requirements concerning training,
recordkeeping and reporting. Any mandated entry level heavy truck
driver training curriculum or standard, and the program structure to
administer the requirement should be consistent with (i.e., not
conflict with) these existing Federal requirements. This listing is as
follows:
--Interstate Commerce Commission. Regulations, as well as recordkeeping
and reporting requirements
--Research and Special Programs Administration. HAZMAT training,
inspection and enforcement
--Environmental Protection Agency. Worker Protection Standard, SARA
[[Page 18364]]
Title III requirements, and the Clean Air Act Emergency Response Plan
--Occupational Health and Safety Administration.
Hazard Communication Standard
--Federal Highway Administration. Federal Motor Carrier Safety
Regulations, as well as recordkeeping and reporting requirements
The second listing presents potential sources of funding to
drivers, employers and/or schools. Any program to administer a mandated
training requirement should be developed with such funding sources in
mind, in order to mitigate the economic impact of mandated training and
facilitate acceptance of the requirement. We identified two potential
sources of funding:
--Department of Education. The Literature Review Report describes the
changes in the Title IV funding and its negative impact on both schools
and persons wishing to enter training as a heavy truck driver. ANPRM
respondents suggested that there is a need for further changes to the
Title IV if it is to support a mandated training requirement.
--Department of Labor. The Job Training Partnership Act (JTPA) provides
block funding to states and local jurisdictions. The states, in
particular, could be encouraged to make use of their JTPA funds in
support of the mandated training, should FHWA implement the
requirement.
Responses to the ANPRM and Conclusions
A total of 96 letters, signed by 104 persons, were received in
response to the ANPRM. Of these 104 respondents, 65 were associated
with the trucking industry (including 34 motor carriers), 16 were from
the school bus industry, one represented a motorcoach association, 16
were associated with state government, and 8 were other.
The ANPRM solicited responses to thirteen (13) questions. In
addition to or instead of responding to the questions, many of the
persons responding chose to address other topics related to the subject
area. Analysis of these responses indicated that they related to four
general issues.
In the summary that follows, only the questions with high response
rates are included. Several questions relating to how adequacy should
be defined and what standards exist for determining adequacy have been
combined, since similar answers were provided to these questions. The
questions have been abbreviated to save space. The section ends with a
summary of the four general issues. Refer to Responses to the ANPRM in
Volume II for the complete text of each question and an individual
summary of each question/issue.
Defining Standards for Adequacy of Training (Questions 1, 2, 4 and 8)
A total of 9 standards were identified. By far, the two most
frequently mentioned standards were the FHWA Model Curriculum as
embodied in the Professional Truck Driver Institute of America, Inc.
(PTDIA) Standards, and the CDL Licensing Standards. The PTDIA standard
includes classroom instruction, range practice and on-street practice
totaling 147.5 per-student hours. This is equivalent to the 320 class
hours required by the FHWA Model Curriculum. The CDL tests consist of a
general knowledge test, specialized knowledge tests, a vehicle
component inspection and a road test.
What an Adequate Training Program Should Include (Question 3)
The most frequent response from the truck group respondents (made
by 22 of the 38 respondents) was that the program should conform to the
FHWA Model Curriculum/PTDIA Standard (for both content and hours).
Several of these persons indicated additional topics, or thought the
curriculum should be updated.
The motorcoach respondent offered topics, indicating that they
apply to both trucks and buses. The only school bus group response came
from an association, which provided the outline for a school bus driver
training program they are supporting.
The most frequent suggestion for program methods was to emphasize
behind-the-wheel instruction.
Adequacy of the CDL in Measuring Driver Performance (Question 5)
One-third of the 64 commenters responding to this question think
the CDL tests accurately measure a driver's performance. Roughly one-
third of the commenters answered ``Yes,'' if the CDL were modified in a
specific way. The remaining one-third did not think the CDL tests
accurately measure a driver's performance.
By far, the most common reason given for supporting the CDL was the
respondent's belief that the tests are sufficiently comprehensive to
accurately measure a driver's performance. Those who qualified their
support most frequently indicated the need for additional training and/
or the need to test additional knowledge and skills.
Should Training be Federally Mandated? (Question 6)
Over 93 percent of the 104 respondents addressed Question 6.
Overall, they were against mandating training by a margin of two-to-
one. However, there were important differences among the groups:
--The Truck groups were mixed:
--The Schools/School Association group (11 respondents) was two-to-one
in favor of the mandate.
--The three union respondents were also in favor of the mandate.
--All of the other truck groups (48 respondents) were against.
--The Bus groups were unanimously against.
--The State Government and Other groups were equally divided.
The most frequently mentioned reasons in favor were that, if
training was not required, the carriers and schools generally would not
comply; regulations need to be set; and the FHWA/PTDIA Standard exists
as a starting point.
The most frequent reasons against were that the CDL exists and is
sufficient; mandated training will increase costs for carriers; and the
schools and carriers have or will provide quality training on their own
because it is in their best interest. The school bus operators
indicated that they do not favor mandated training because the state-
required training is sufficient.
General Issues
The four general issues identified from the comments of the ANPRM
respondents were as follows.
Program Administration. About half of the 16 state government
respondents see the need for the states to develop costly programs for
certifying and monitoring training courses. Three commenters indicate
that maintaining records also will be expensive. Some question who will
fund the program and whether the enormous cost would outweigh the
benefits.
Program Quality/Cost and Who Will Pay. A frequent comment was that
the cuts in the Federal Student Loan program have reduced student
access to CMV driver training and reduced the duration and quality of
the courses. Four commenters indicate that the government should do
more to help students acquire the funds they need to attend school.
Broadening the Requirement. Twelve (12) persons provided comments,
indicating that the requirement should also include hazardous materials
training, and the training of transit bus, Longer Combination Vehicle
(LCV), and
[[Page 18365]]
foreign drivers. Two respondents recommended screening existing drivers
and providing training for those with problems.
Effect on Specialized Fleets. Five (5) private fleet respondents
indicated that special fleets have special training requirements and
that a generic mandatory training standard, centered around the
training needs of over-the- road freight haulers, would not be
suitable. Training to this standard would be irrelevant to their needs,
and costly.
Tables 1 through 6 follow.
Executive Summary
Table 1.--Summary of Training Adequacy Findings for Motor Carriers
------------------------------------------------------------------------
Heavy School
trucks Motorcoaches buses
------------------------------------------------------------------------
Percent of motor carriers hiring
entry-level drivers that
provide formal training for
them........................... 21.6 62.5 71.2
Percent of motor carriers
sampled whose formal training
was judged as ``Adequate''..... 37.5 29.6 33.3
Estimate of the percent of motor
carriers hiring entry-level
drivers that provide adequate
training....................... 8.1 18.5 23.7
------------------------------------------------------------------------
Table 2.--Summary of Training Adequacy Findings for Drivers
------------------------------------------------------------------------
Percent
Formal training methods, by Percent Percent drivers
domain \1\ drivers programs adequately
trained \2\ adequate trained \3\
------------------------------------------------------------------------
Heavy trucks:
Proprietary................. 47.5 44.8 21.3
Public funded............... 7.8 54.5 4.2
Company/military \4\........ 6.4 87.5 5.6
---------------------------------------
Total..................... 61.7 50.0 31.1
(Sample Size)............... (141)
Motorcoaches:
Company \5\................. 50.0 36.4 18.2
(Sample Size)................. (22)
School buses:
Company..................... 58.6 58.8 34.5
Other....................... 17.2 0.0 0.0
---------------------------------------
Total..................... 75.9 45.5 34.5
(Sample Size)................. (29)
------------------------------------------------------------------------
\1\ This analysis includes only ``New'' drivers, i.e., drivers with five
or fewer years experience.
\2\ Values are percent of the sample size, which includes both formally
trained and other trained drivers.
\3\ See text for a description of how these values are calculated.
\4\ These groups were combined because they include only nine cases,
four military and five company.
\5\ Motorcoach drivers sampled reported only company programs as their
source of formal training.
Table 3.--Sample Sizes for Each Domain
------------------------------------------------------------------------
Heavy School
trucks Motorcoaches buses
------------------------------------------------------------------------
Industry survey:
Associations................ 12 2 3
Insurance companies......... 11 5 5
Motor carriers.............. 82 22 22
Schools..................... 24 ............ ...........
School survey................... 41 27 30
Exemplary programs.............. 27 5 4
Driver survey................... 371 43 50
------------------------------------------------------------------------
Table 4.--Incidence of Entry-Level Training by Domain
------------------------------------------------------------------------
Heavy School
trucks Motorcoaches buses
------------------------------------------------------------------------
Master sample size.............. 272 155 214
Percent of sample that:
Hire experienced drivers.... 59.2 53.5 4.2
Hire entry level............ 40.8 46.4 95.8
Provide no training..... 1.8 9.0 2.3
Do provide training..... 39.0 37.4 93.5
Training activities. 30.2 8.4 25.3
Formal training..... 8.8 29.0 68.2
------------------------------------------------------------------------
[[Page 18366]]
Table 5.--Summary of Training Program Adequacy Scores by Domain
----------------------------------------------------------------------------------------------------------------
Heavy trucks Motor- School
-------------------------- coaches buses
-------------------------
School Company Company Company
programs programs programs programs
----------------------------------------------------------------------------------------------------------------
Sample size................................................. 41 24 28 30
Mean overall adequacy score (OAS)........................... -7.2 20.6 -16.6 2.3
Percent adequate (i.e., OAS zero or above).................. 22.0 39.1 29.6 33.3
----------------------------------------------------------------------------------------------------------------
Table 6.--Summary of Industry Impact Questions by Domain
------------------------------------------------------------------------
Response index values \2\ by domain
---------------------------------------
Industry impact questions \1\ Heavy School
trucks Motorcoaches buses
------------------------------------------------------------------------
Condition of motor carriers:
Present condition, as
compared with five years
ago [Range: Much worse off
(-2) to much better (2)]... -0.47 0.00 -0.08
Effect of mandated training
[Range: Hurt (-1) to Help
(1)]....................... -0.03 0.15 0.08
Condition of drivers:
Present condition, as
compared with five years
ago [Range: Much worse off
(-2) to much better (2)]... -0.13 0.19 0.61
Effect of mandated training
[Range: Hurt (-1) to help
(1)]....................... -0.33 0.65 0.45
Driver turnover as a problem:
Degree of seriousness
[Range: No problem (0) to
serious problem (-3)]...... -1.99 -1.73 -1.93
Effect of mandated training
[Range: greatly increase
turnover (-2) to greatly
reduce turnover (2)]....... 0.21 0.35 -0.04
Driver shortage as a problem:
Degree of seriousness
[Range: No problem (0) to
serious problem (-3)]...... -1.59 -1.56 -1.89
Effect of mandated training
[Range: greatly increase
shortage (-2) to greatly
reduce shortage (2)]....... -0.14 0.19 -0.30
------------------------------------------------------------------------
\1\ The actual phrasing of these questions, as they appeared in the
Industry Surveys, are presented in Volume III, Sections 3, 4, and 5.
\2\ See the Volume III, Section 7 for a description of how the Response
Index values were calculated.
[FR Doc. 96-10206 Filed 4-24-96; 8:45 am]
BILLING CODE 4910-22-P
