Training of Commercial Motor Vehicle Drivers (2004)

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7CHAPTER 2 CONTENT AND QUALITY OF ENTRY-LEVEL DRIVER TRAINING PROGRAMS As noted by Batts (1999), many truckload carriers rely on entry-level drivers. This author cites a Gallop study commis- sioned by the American Trucking Associations Foundation indicating that more than 80,000 new drivers per year will be needed by the trucking industry over the next decade. Bates further states that the quality of training received by entry- level drivers from three sources—public schools (most often community colleges), for-profit training programs, and carrier-based schools—is inconsistent. While some schools offer quality programs, others, designed solely to help some- one acquire a CDL, put drivers on the road with as little as 1 week of training. TRUCK CRASHES AND TRAINING Beilock et al. (1989) analyzed data compiled by the Office of Technology Assessment and the 1987 Regular Common Carrier Conference’s Motor Carrier Safety Survey. They con- cluded that the most common factors associated with heavy vehicle crashes were driving too fast for conditions (cited as a factor in 20% of all heavy truck crashes and the single high- est factor cited) and the level of driver training (the second most-frequently cited factor). Driver education and training was offered as a solution to reduce the incidence of crashes associated with speed. A decade later, Horn and Tardif (1999) expressed a somewhat modified point of view, i.e., that ade- quate training is a necessary but not a sufficient condition for the reduction of heavy vehicle crashes; they recommended an approach combining regulations that specify the content requirements for training with an industry-based strategy for its delivery. The present research aims are consistent with this viewpoint. In an evaluation of crashes between 1981 and 1985 using the National Analysis Sampling System (NASS), it was found that only 42% of truck drivers involved in crashes had received any training (Beilock et al., 1989). In the aforementioned 1987 survey, only 23% of 1,762 drivers of combination trucks had formal training before becoming professional drivers. The Office of Technology Assessment also found that untrained drivers are overinvolved in fatal crashes, as shown by the finding that 42% of large-truck drivers who were involved in all truck crashes had received training, compared with only 26% of the drivers involved in fatal crashes. These results indicate that, without regard to the quality of training, formal schooling prior to beginning trucking appears to have little effect on crash probabilities. The authors suggest that this result may be explained by the wide variation in course con- tent across schools, underscoring the importance of develop- ing and enforcing standards for training. Beilock et al. (1989) also concluded that training programs that include periodic reexaminations and refresher courses are effective in reducing crash rates. They cite UPS’s prac- tice of periodic retraining. UPS trainers accompany drivers four times each year, using a 120-item checklist to determine if a driver has developed bad habits. Retraining is provided for drivers based on the checklist. Retraining is also manda- tory if a driver is involved in an avoidable crash. In 1986, the UPS crash rate was barely one-tenth that for the motor carrier industry as a whole. Horn and Tardif (1999) state that contin- uous driver training through driver improvement courses that focus on safety and driver behavior—thinking ahead before dangerous situations develop, driving under slippery road con- ditions, etc.—must be supported by senior management, who must view training as useful rather than just as an additional cost or annoyance. The FHWA, in its Commercial Vehicle Preventable Accident Manual: A Guide to Countermeasures (Uzgiris et al., 1991), states, “the great majority of preventable crashes can be shown to be directly related to the performance of the driver; and, therefore, it is extremely productive to any fleet safety program to have careful new driver selection and adequate monitoring procedures for existing drivers.” It recommends that management address the following question when there is an excessive incidence of preventable crashes by individual drivers: “When hiring new drivers, are recruiting efforts suf- ficient to attract an adequate number of qualified applicants for effective selection?” (Uzgiris et al., 1991.) The Manual offers truck driving school as a countermeasure for excessive inci- dents of preventable crashes, explicitly linking fleet safety to driver skills and knowledge. THE CONTENT AND QUALITY OF TRUCK DRIVER TRAINING The following discussion focuses on the current state of the knowledge regarding the content and quality of training pro- vided by truck driving schools, as well as training content and procedures delivered by carriers in so far as this could be

identified in the literature. As noted by Horn and Tardif (1999), the availability of reliable data in the area of truck driver train- ing and evaluation is poor relative to highway safety research and development in general. While the CDL is a federally mandated licensing standard, there is no federally mandated standard for the training of entry-level commercial truck drivers. And while the FMCSA believes that the FHWA Model Curriculum, the PTDI Cur- riculum, the Model Curriculum for Training Motorcoach Drivers, and the NHTSA School Bus Driver Instructional Program represent the basis for training adequacy, such train- ing is not mandated. At the same time, the FMCSA does not agree that training adequacy is ensured simply by having the knowledge to pass the CDL test (Federal Motor Carrier Safety Administration, 2003). PTDI-Certified Courses PTDI was established in 1986 to assist carriers and students in the identification of courses that provide quality-level train- ing. The Institute’s curriculum and other course certification criteria are an adaptation of the 1984 FHWA Model Curricu- lum. The PTDI is the only organization, either public or private, that has established a standard for the training of entry-level truck drivers. PTDI certifies courses at truck driving schools; it is not a school and does not offer courses. The Truckload Carriers Association assumed management of PTDI in 1997; and, since then, PTDI has undergone restructuring that includes the identification of skill standards, a revision in the curriculum, and modification of certification standards. PTDI-certified courses are currently offered at 61 schools in 28 states and Canada, according to PTDI’s Web site.2 PTDI- certified driver-finishing programs are currently offered by two carriers at two locations. Only graduates of a PTDI-certified entry-level course are eligible to enroll in a PTDI-certified driver-finishing program. These standards assure the continu- ity and consistency of training after a driver leaves the school and finishes training at the trucking company. PTDI-certified courses generally offer at least 148 cur- riculum hours, including 44 hours of behind-the-wheel train- ing during which the student actually drives the vehicle. PTDI recommends an additional 21 hours beyond the mini- mum requirements of 148 hours, with the additional time in the classroom distributed across at least five subjects: addi- tional DOT regulations, first aid, CPR, CDL written prepara- tion, defensive driving, and the job search. PTDI-certified courses range from 240 to 600 hours, with many of the longer programs placing students in an externship program with an over-the-road trainer. PTDI states that an externship of 140 to 240 hours of instruction can provide the additional train- ing and experience necessary for an entry-level driver to 8 progress to a solo driver. To be PTDI-certified, programs must include topics in basic vehicle operation, safe operation practices for basic operation (visual search, vehicle commu- nication, speed and space management), advanced operating practices (night operation, extreme driving conditions, haz- ard perception, emergency maneuvers and skid avoidance, skid control and recovery, passive railroad crossings), vehicle systems and reporting malfunctions, and nonvehicle activities (handling and documenting cargo, environmental issues, hours of service requirements, accident procedures, managing life on the road, trip planning, and communication). PTDI is con- cerned with more than just the curriculum and quality of instruction; PTDI-certified courses undergo evaluation by on-site teams that look at areas such as instructional per- sonnel, classrooms, quality of training equipment, accuracy of student records, and employer and student satisfaction (Batts, 1999). The value of training that meets PTDI standards was a con- sensus opinion at a national forum of the Driver Training and Development Alliance, which asserted that “a carrier’s great- est asset is a driver with good driving skills, a solid knowledge of regulations and proper vehicle inspection techniques, and customer service savvy” (Abry, 1998). This group of 185 indi- viduals from business, industry, and government highlighted the need for truck safety through voluntary, industry-wide driver training and development standards; it emphasized that driver training is an investment rather than a cost because training reduces turnover, results in increased driver pride, and reduces wear and tear on the vehicle. The alliance encourages potential drivers to attend schools that deliver a curriculum certified by the PTDI. Current Practices Horn and Tardif’s (1999) review of practices in the Euro- pean Union and North America found that private schools most commonly offer a 150-hour curriculum that includes classroom, range, and on-road training. The vehicle used for on-road training is usually equipped with extra seats behind the driver so that 3 to 4 students can be in the vehicle at the same time and participate in training through observation. During the in-truck training, the instructor uses a commen- tary technique so that the student driver and observers can learn from the on-road exposure. Horn and Tardif found that nonprofit schools tend to offer a more extensive curriculum, with some countries providing 700 hours of training. In France, the curriculum can cover up to 2 years, depending on the student’s experience and knowledge. Perhaps the single most important component of an effec- tive training program is a qualified trainer (Wiggins, 1990; Horn and Tardif, 1999). The International Road Transport Union moved in 1998 to create a vocational training academy at the European level to comply with a European community directive governing admission to the occupation for future transport operators. Wiggins (1990) states that the character- 2 “Schools with PTDI-Certified Courses Listed by State as of March 20, 2004,” avail- able online at www.PTDI.org/schools.schools.htm. The most current list is available at www.PTDI.org/schools/schools.htm. Last accessed September 20, 2004.

istics of a good trainer include confidence, a thorough knowl- edge and understanding of the trucking industry, excellent communication skills, and the ability to think on one’s feet. She describes the Interstate Truckload Carriers Conference (ITCC) program for trainers called “Developing a Company Training Program,” which is a 1-week program designed for trainers working with driver graduates or experienced drivers. Trainers are taught how to identify weak spots in drivers’ skills, how to address them, and how to use objective scoring measures to grade drivers. Occupational and safety professionals recommend that trucking firms adopt training programs that are delivered by qualified driver trainers to ensure driver competence that is above the minimum standards set by law (Smith, 1996). The driver training program should include defensive driving, transportation of dangerous goods (if applicable), the Work- place Hazardous Materials Information System, workplace hazard recognition, load security procedures, vehicle opera- tion, safety equipment, pretrip inspections, road skills, rele- vant legislation, hours of work legislation, first aid, and any other safety-related subjects. Further, the program must have a recall and evaluation system for both the driver and the training program and must have provisions for the identifica- tion of drivers who require further training and retraining. The FHWA has recommended that the management of car- rier companies periodically have a qualified person ride along with drivers to evaluate their defensive driving habits and to ensure that the drivers are aware of the concept of “preventable crashes” (Uzgiris et al., 1991). The FHWA’s Commercial Vehicle Preventable Accident Manual: A Guide to Countermeasures (Uzgiris et al., 1991) highlights the following areas in which managers of carrier companies should ensure that their drivers have received training: • Ways in which drinking and substance abuse affect driving performance. • Defensive driving. • Safe curve negotiating techniques, conditions that make rollover more likely, and the meaning of posted advisory speeds on curves (they are for automobile drivers). • Performance of safe passing maneuvers. • Performance of safe turning procedures. • Safe procedures for crossing intersections. • Safe lane usage and lane changing. • Safe parking procedures. • Controlling their vehicles on downgrades. • Checking the condition of braking systems. • Safe maneuvering on slippery surfaces, including knowl- edge of how to judge safe speed on a slippery surface and causes and prevention of jackknifing. • Emergency equipment requirements and emergency procedures. • How to maneuver safely around pedestrians. • Safe passenger management procedures. 9 • How and why rollovers occur. • How to deal with sealed cargoes, top heavy or offset cargoes, or improper axle weight distribution. • What to do regarding improperly loaded or secured cargoes. • Proper use of hitching equipment, proper coupling procedures, and proper methods for blocking and bracing. • Avoidance of high-hazard locations. • Troubleshooting vehicle deficiencies (worn, failed, or incorrectly adjusted components that can cause or contribute to crashes). • Inspection of safety-critical components to determine the adequacy of their condition. • How to detect deteriorating conditions during brake, tire, and wheel inspections. • Consequences of improper tire inflation and how to check tire inflation. Commercial Motor Vehicle Driver Training Dueker (1995) conducted a study to determine the effec- tiveness of the private sector in ensuring adequate training of entry-level CMV drivers. This study focused on training for CMV drivers of heavy trucks, motorcoaches, and school buses. Operational definitions created for each of the terms included in the study objectives are presented below. “Entry-level training” was defined as all training received during the first 3 years of the driver’s experience, including preservice training, on-the-job training, and in-service train- ing. Included in the definition of “private sector” were driving schools (i.e., public, private, and company-operated); certifi- cation and accreditation groups; carriers and fleet operators; associations; insurance companies; and drivers. Programs were considered as “formal training” only if they provided some number of class or lab hours, to discriminate between programs that just provided on-the-job training. Further, it was deter- mined that on-street hours must be provided in addition to classroom hours for a program to be considered “adequate.” “Adequate training” for heavy trucks and motor coaches was defined by Dueker as shown in Table 1, using the FHWA model tractor-trailer driver curriculum (Federal Highway Administration, 1985) as a starting point and the consensus of a panel of 36 experts on the minimum acceptable require- ments for each of the listed curriculum characteristics. The recommended curriculum topics for “adequate” truck or bus training are presented in Table 2. Data are not provided in the summary tables below for school buses, as they are not a focus of this research. Data regarding the adequacy of heavy truck and motor- coach training were provided by a total of 640 respondents from industry, schools, and individual drivers who were sur- veyed in the Dueker (1995) study. The study concluded that the private sector is not effective in providing adequate train- ing for drivers of heavy trucks, motorcoaches, or school

buses. Data were provided to describe percentages of motor carriers that provide adequate training as well as percentages of drivers receiving adequate training. Of the heavy truck car- riers who were surveyed, only 22% indicated that they pro- vide formal training to the entry-level drivers they hire. This compares with 63% of motorcoach carriers surveyed who provide formal training to their entry-level drivers. In terms of the adequacy of the formal training provided, approxi- mately one-third of the heavy truck carriers and motorcoach carriers provided training that was considered “adequate,” as defined by project criteria. For heavy truck carriers, 38% pro- vided training defined as “adequate;” and, for motorcoach carriers, 30% provided training that was defined as “ade- quate.” Combining the prevalence of formal training and the adequacy of formal training, the findings indicated that only 8.1% of heavy truck carriers who hire entry-level drivers pro- vide adequate training for them, and only 18.5% of the motor- coach carriers who hire entry-level drivers provide adequate training for them. These results are presented in Table 3. Dueker (1995) also reports data provided by 141 heavy truck drivers and 22 motorcoach drivers to describe the num- ber of drivers who are being adequately trained and the extent to which schools (publicly funded and proprietary) add to the percentage of adequately trained truck drivers. The drivers in the sample were limited to those with 5 or fewer years of experience (i.e., “new” drivers). The findings of the driver survey, presented in Table 4, show that both publicly and pri- vately funded schools contribute substantially to the number of CMV drivers who receive adequate training. Responses to the ANPRM As part of the study performed by Dueker (1995), responses to FHWA’s ANPRM, “Training for All Entry-Level Drivers of Commercial Motor Vehicles,” were analyzed. The 104 respon- 10 dents included 65 individuals from the trucking industry, 16 from the school bus industry, 1 from a motorcoach associa- tion, and individuals associated with the government. The most frequently mentioned standard was the FHWA Model curriculum, as embodied by the PTDI Standards and the CDL Standards. The PTDI standard includes classroom instruc- tion, range practice, and on-street practice that totals 148 per- student hour, which is equivalent to the 320 hours required by the FHWA Model Curriculum when accounting for the higher student-teacher ratios in the FHWA Model (Dueker, 1995). The CDL tests comprise a general knowledge test, specialized knowledge tests, a vehicle component inspection, and a road test. When asked what an adequate training program should include, the most frequent response from the truck group (22 of 38 respondents) was that the program should conform to the FHWA Model Curriculum/PTDI Standard for both content and hours; 5 truck-group respondents indicated that the pro- gram should conform to the FHWA/PTDI standard, but addi- tional topics should be included or the curriculum should be updated. Additional topics recommended by truck- and motorcoach-group respondents included the following: defen- sive driving; vehicle safety inspections; handling CMV on all types of roadways; night driving; responding to hazards and emergencies; mountain driving; freight handling procedures and equipment; cargo stacking, securing, and weight distrib- ution; map reading and planning; hours of service/log prepa- ration; state-specific DMV and Public Utilities Commission (PUC) regulations; and brakes. The most frequent suggestion for improving training methods was to place greater emphasis on behind-the-wheel instruction. The need to enhance inclement weather driving skills is emphasized by Kostor and Summerfield (2001). Although driving schools may have modules on driving in inclement weather, there is a need for advanced training to test classroom Curriculum Characteristics Minimum Criteria for Adequate Training Hours: Class/Lab 89 Range 85 Street 116 Total 290 Per Student Hours: Street only 38.7 Range and Street 52.9 Student-Teacher Ratios: Class/Lab 12 Range 6 Street 3 Behind the Wheel: Hours 38.5 Miles 1,000 Content Topics (see Table 2) 49-50 topics TABLE 1 Training criteria employed by Dueker (1995) for heavy trucks and motorcoaches

11 TABLE 2 Curriculum topics recommended by Dueker (1995) for “adequate” training Curriculum Topic Heavy Trucks Motorcoaches Basic Operation Function, location, and proper use of all primary vehicle control systems (e.g., brakes, accelerator, shifters, clutch, and internal transmission retarders). √ √ Function, location, and proper use of all secondary vehicle control systems and instruments (e.g., light switches, wipers, ignition controls, seat belt, gauges, and warning devices) √ √ Door controls √ How air brakes operate √ How hydraulic brakes operate √ Proper use and adjustment of mirrors for maximum visibility √ Equipment-specific engine stop and/or start controls (e.g., emergency, engine compartment switch, and master switch) √ Air/electric horns √ Basic control and maneuvering (e.g., starting, acceleration, braking, steering, shifting, backing) √ √ Turning—understanding location of bus pivot point √ Parking √ Overhead clearance √ Railroad crossing procedures √ Different multirange transmission shift patterns √ Use of retarders and speed controls √ Special Handling of Articulated Vehicles How the center of gravity of your load affects handling and about unstable loads (e.g., tankers and live cargo) √ Special things you should know about handling tractor trailers √ Special things you should know about handling multiple articulated vehicles (twins, doubles, triples) √ Special things you should know about handling tractors alone (bobtail) √ Special things you should know about handling other special rigs (e.g., oversized or low-clearance vehicles and pole trailers) √ Safe Operating Procedures Visual search √ √ Communication with other road users (e.g., signaling, flashers, headlights, backup lights) √ √ Adjust speed to traffic, traction, visibility, road conditions √ √ Monitor space around the vehicle √ √ Understand and use the defensive driving 4-sec following distance technique √ Special Conditions Nighttime operations √ √ Extreme temperature (hot, cold) √ √ Mountainous terrain √ √ Transporting handicapped and exceptional passengers √ Advanced Driving Skills Hazard recognition (e.g., road conditions, driving situations, driver and pedestrian characteristics) √ √ Collision avoidance (e.g., quick stops, evasive maneuvers, making judgments) √ √ Prevention of and recovery from skids √ Prevention of and recovery from skids and/or jackknife √ Equipment-related emergencies (e.g., blow-outs and brake failure) √ √ (continued on next page)

12 Coupling and uncoupling articulated vehicles √ Safety inspections, i.e., using systematic procedures for pretrip, en route, or posttrip inspections √ √ Securing vehicle and contents √ √ Basic familiarization with the location, function, operation, and common failures of vehicle systems √ √ Recognizing vehicle malfunctions √ √ Diagnosing vehicle malfunctions √ Coordinate with maintenance to effect repair of vehicle components √ Safe work methods (e.g., lifting) √ √ Preventive Maintenance and Servicing Check and service engine fuel, oil, coolant, battery, and filters √ Check tire air pressure √ Check tires and check for proper wheel mounting √ Drain moisture from air brake supply reservoirs √ Check brakes √ Clean and repair lights √ Change fuses and reset circuit breakers √ Nonvehicle Activities Handling baggage and package express √ Recognizing hazardous materials and proper refusal to transport these materials √ Hours of service requirements √ √ Keeping a log √ √ General accident procedures √ √ First aid procedures √ √ Fire-fighting techniques √ √ Trip and route planning √ Basic geography and map reading √ How to handle cargo (safe loading, weight distribution, securing the load) √ Hazardous materials paperwork and placard requirements √ Handling special types of nonhazardous cargo (e.g., unstable cargo) √ Inspect cargo (pretrip and en route) √ Special accident procedures for hazardous materials √ Occupational awareness (i.e., instruction regarding the change in lifestyle once becoming a truck driver; promotion of truck driving as a career) √ Loading and Transportation of Passengers Safe boarding and alighting of passengers √ Approaching and leaving a stop √ Rules of the road governing vehicles that transport passengers √ Emergency evacuation procedures √ Stow baggage or equipment inside bus to make aisles and emergency exits accessible √ Passenger Management Understanding government regulations and company procedures regarding alcohol, tobacco, and drug use by passengers √ Communication techniques for handling difficult passengers √ Maintaining Fitness Alcohol and drugs √ √ Personal health and fitness √ √ Cargo handling health and safety (avoiding lifting injuries, falls, proper clothing, safety equipment) √ Curriculum Topic Heavy Trucks Motorcoaches Vehicle-Related, Nondriving Activities TABLE 2 (Continued)

theory and skills in controlled settings (e.g., through the use of a skid pad). The authors assert that, by preventing heavy truck crashes at a per-crash-cost of $100,000, the wider use of such facilities would be very cost-effective. Kostor and Summerfield support their conclusions through analyses of heavy truck crashes that occurred in Manitoba, Canada, between 1994 and 1999. They found that for heavy trucks, higher proportions of crashes occurred under poor weather conditions and under higher wind speeds than for passenger vehicles. Approximately 41% of heavy truck crashes occurred under winter (i.e., icy or snow covered) and spring/fall (i.e., mud, wet, and slush) road surface conditions, compared with 23% of passenger vehicle crashes. Also, more crashes occurred on poor roads under higher wind speeds for heavy trucks than for passenger vehicles. For passenger vehicles, 71% of icy/snow-covered road crashes occurred with low winds (i.e., wind speeds below 25 km/h [15 mi/h]) and 29% occurred with moderate winds. In comparison, 63% of heavy truck crashes on icy/snow-covered roads occurred under low winds, and 37% occurred under moderate winds. Though high-sided vehicles do not perform as well as passenger vehi- cles in inclement weather, truck drivers should be able to compensate for this, given significant training. Kostor and Summerfield (2001) also looked at the crash experience of Longer Combination Vehicles (LCVs) under inclement weather conditions. They found that the LCVs crash experience was not disproportionate to singles under low wind and icy road conditions and, in fact, the number of crashes under moderate wind/icy road conditions for these vehicles was less than those under low wind/icy road condi- tions. In theory, LCVs would be more unstable under icy road 13 and windy conditions than single heavy vehicles and should be overrepresented in crashes under these conditions. The authors explain this finding by noting that most carriers use more experienced drivers on LCVs and instruct all drivers to adjust for conditions or cease operation until the adverse weather has passed. Responses to the NPRM Comments on FMCSA’s proposed training requirements were due to the agency by October 11, 2003. Thirty-eight comments were received. The response from industry and other interested parties relevant to the topic of best prac- tices for training entry-level drivers, as summarized in the following paragraphs, is informative.3 Over one-third of the comments—most of which came from schools—focused on the proposal “falling short of a minimum standard for the training of entry-level drivers.” The majority of these respondents suggested that the four proposed topics be incorporated into the Model Truck Driver and Model Motorcoach Driver curricula, which should then be identified as the minimum standards for training entry-level drivers. A few of these commenters further stated that the delivery of the PTDI curriculum should be more flexible and performance-based, to make the training more effective. TABLE 3 Summary of training adequacy findings for motor carriers (Dueker, 1995) Heavy Trucks Motorcoaches Percent of motor carriers who provide formal training for their hired entry-level drivers 21.6 62.5 Percent of sampled motor carriers whose formal training was judged as “adequate” 37.5 29.6 Estimate of the percent of motor carriers who provide adequate training for the entry-level drivers they hire 8.1 18.5 Formal Training Methods Percent of Drivers Trained Percent of Programs Adequate Percent of Drivers Adequately Trained Heavy Trucks Proprietary Public Funded Company/Military Total (Sample Size) 47.5 7.8 6.4 61.7 (141) 44.8 54.5 87.5 50.0 21.3 4.2 5.6 31.1 Motorcoaches Company 50.0 36.4 18.2 TABLE 4 Summary of training adequacy findings for drivers (Dueker, 1995) 3See the U.S. DOT’s Document Management System at http://dms.dot.gov. To retrieve the comments, search under Old Docket No. MC-93-12; along with some other material, the comments are Document Numbers FMCSA-1997-2199-170 to FMCSA-1997-2199-215. Direct quotations in the following paragraphs are taken from these documents.

In addition to the incorporation of the proposed topics into the model curricula, one respondent suggested the inclusion of training in the proper use of antilock brake systems and proper use of inline or engine retarders. This commenter offered that the PTDI curriculum should be updated every 5 to 10 years to include new technologies. Of the respondents who stated that the proposed require- ments fell short of a minimum standard but did not specify use of the Model/PTDI curricula, one proposed that as a minimum, the Professional Truck Driver 8-hour Defensive Driving course be required and that training should be renewed every 2 years. Another stated that regardless of how many hours a graduate from a training program receives, he or she is still an entry-level driver. He continued with the following comments: “No person should be allowed to test for CDL with- out being able to verify formal training or an adequate amount of on-the-job training. Minimum standards should be estab- lished to establish consistency among states. Filling hours with classroom material or student observation cannot take the place of BTW. Adequate training requires a focus on safety sensitive issues including actual driving, backing, and hours of service. Enough emphasis is not put on the carrier segment regarding finishing programs that ensure an entry-level driver continues to receive training.” Another commenter not specifying the model curriculum but stating that the proposal fell short of a minimum requirement, offered the following: “Specifying a minimum time require- ment for training is unnecessary. Final rule should emphasize specific training content including basic defensive driving top- ics, including space management, proper lane changes and merging, vehicle dynamics, adverse weather, etc., and should require the carrier to be able to provide documentation that all of the elements of the training have been met.” A fourth commenter stated the following: “The Secretary is required by Section 4007(a) to issue a rule to improve entry-level driver training unless the Secretary has deter- mined that it is not in the public interest to require training for all entry-level drivers. Since there has been no Secretarial determination that entry-level training is not in the public interest, the statute requires the Secretary to proceed to issue a rule requiring such universal training. The proposed novice driver training is a legally insufficient response to the statu- tory mandate and clearly violates legislative intent. When the agency’s own contracted research showed that basic knowl- edge and skills transmission through the private sector was inadequate, the result of that finding must be decisive agency action to ensure that basic driver training is provided.” One commenter stated that the FMCSA should do as much as possible to encourage driver training schools to participate in PTDI’s program, with the addition of the four new areas, but that the training should not be mandated. Several other respondents objected to mandated training, with one stating that the motorcoach industry should be exempted. He pro- vided the following comment: “The motorcoach industry should be exempted from the proposed rulemaking, as the 14 safety record of motorcoaches is even safer than that of tran- sit operators, who are exempted.” Approximately one-third of the respondents suggested that instead of requiring that carriers provide training in the four proposed areas, the topics should be included in the CDL pro- gram materials and testing. This would ensure that drivers received the information and would remove the burden for industry to document the training and maintain records. Several comments were focused on the proposed whistle- blower protection training. One respondent objected to whistle- blower protection training, stating that it has the effect of “using the regulations to intimidate and retaliate against the employer while building a protective cocoon around the poor or unsafe worker or driver.” Another commenter who was opposed to this training stated that the whistleblower provi- sion does not address a driver’s ability to safely operate a motor vehicle, so it should be removed. Three others indicated that whistleblower protection training would be redundant, as it is already covered by statute and is provided in many carrier training programs. If not already part of a carrier training pro- gram, the training could be easily accomplished with a poster or a statement signed and read during orientation, as opposed to formal training. Over a quarter of the respondents took issue with the pro- posed definition of an entry-level driver. The majority of these respondents stated that it should apply to drivers with 1 year of experience or less, instead of the proposed 2 years or less.4 Several respondents said that the definition of an entry-level driver should depend on the number of miles driven rather than the amount of time on the job. With respect to the driver wellness component, a few respondents acknowledged that while diet and exercise are important, wellness is an individual’s responsibility addressed through successful completion of a periodic exam; it is not within the purview of the FMCSA. In the same vein, an addi- tional respondent provided the following comments: “The proposal falls short of being an instrument to achieve the goal of improving overall highway safety, given the four training areas cited, and the fact that 75% of all crashes are caused by passenger cars. The four training areas are already addressed by federal statute, and the agency is overstepping its bounds with respect to individual privacy in the driver qualification and driver wellness areas.” Wellness As evidence for including wellness issues as an area in which entry-level drivers should receive additional training, FMCSA sites a study by Roberts and York (2000) indicating that obesity, high blood pressure, alcohol and drug abuse, and 4The definition of an “entry-level driver” was changed in the Final Rule (May 21, 2004) to “a driver with less than one year experience operating a CMV with a CDL” from the original language in the proposed rule (August 15, 2003), which defined an “entry-level driver” as a “driver with less than 2 years experience operating a CMV with a CDL.”

stress are major health issues among truck and bus drivers (Federal Motor Carrier Safety Administration, 2003). Roberts and York (2000) in turn cite a study by Stoohs et al. (1993) indicating that 71% of 125 studied drivers were defined as “obese” because they had a Body Mass Index (BMI) greater than 28. They also cite Korelitz et al. (1993), who found that in a survey of 2,945 truck drivers attending a trade show, 40% were overweight (BMI between 25 and 30) and 33% were obese (BMI greater than 30). In this survey, 33% of the truck drivers had blood pressure measurements greater than 140/90 mm Hg and 11% had blood pressure measurements greater than 160/95 mm Hg. In a related finding, Roberts and York (2000) cite data from Orris et al. (1997) showing that 303 par- tial delivery truck drivers had higher stress levels than 91% of the U.S. population. Regarding alcohol, Roberts and York (2000) cited data from Korelitz et al. (1993) indicating that 23% of the 2,945 truck drivers surveyed could have a drink- ing problem as defined by responses to questions regarding personal drinking perceptions. In Roberts and York’s (2000) review of the literature on wellness programs in the trucking industry, only one evaluation of program effectiveness was uncovered. Holmes et al. (1996) designed a wellness program that emphasized driver nutrition, then conducted a before-and-after study with 30 truck drivers to determine whether such training could produce benefits with respect to health risk factors, including weight, body fat, blood pressure, blood sugar, cholesterol, smoking, and gen- eral physical fitness. This study was conducted in response to a company’s increase in health care claims for heart problems/ heart disease. Participants underwent a health screening con- ducted at their job site and were made aware of their results and health status based on standard guidelines. A nutrition intervention program was developed in which study partici- pants received nutrition publications and daily healthy snacks (e.g., cheese sticks, fresh fruit, juices, raisins, pretzels, and other low-fat items). Tips were provided for eating a healthy diet when dining out, at home, or on the road. Study partici- pants also received an exercise chart showing calories burned for various activities and a slide chart showing calories and grams of fat for specific foods. At the end of a 6-month period, as reported by Holmes et al. (1996), significant improvements were shown for weight, body fat, cholesterol, and smoking. The authors note that a drop of 25 mg of cholesterol may reduce the risk of heart attack by 50% or more. Half of the study group had choles- terol levels exceeding 200 mg at the beginning of the study; and, by the end of the 6 months, only one driver had a cho- lesterol reading over 200 mg. Subjective data from driver interviews suggests that the nutrition treatments also were a positive influence on driver attitudes. The program generated positive feelings about the company, employee ratings of the program and the value of health screenings and discussions were very high, and employees thought the healthy snacks should be continued. The cost of the program was $100 per driver screening and $13,000 in snacks over a 7-month period 15 for 30 drivers. Cost containment for heart problems over the 7-month period could not be ascertained, but the program was considered to be a quantitative as well as a qualitative success. In the authors’ opinion, wellness programs can con- tribute to fewer health claims, lower employee turnover, and higher employee satisfaction. Roberts and York (2000) conducted on-site and telephone surveys of 26 companies to discuss their wellness programs; only 6 companies indicated that they had wellness pro- grams or were willing to discuss their programs, however. In four of the six companies, programs were reaching corporate office workers but not drivers. In the programs that reached drivers, one company experienced a 40% reduction in crashes after the implementation of classroom training addressing fatigue and other health issues and the dissemination of a man- ual providing information on exercise, diet, health, and fatigue. However, the program is no longer supported because the indi- vidual who developed, implemented, and championed the program left the company. In the sixth company, a wellness program has been initiated that offers health fairs; weight maintenance programs; exercise incentive programs; “lunch and learns” covering topics including diabetes, healthy food choices, and fitness; and promoting activities such as golf, basketball, and volleyball tournaments and aerobics. Truck drivers are advised of the program during their orientation and are given nutrition packets with information about healthy snacking and calories, plus a manual with information about stress management, healthy eating, and exercise. The com- pany’s participation rate after 6 months was 20 to 25% of the office staff and 10% of the driver staff. A company spokes- person indicated that there are not enough resources available to reach the target population, nor are hard data available to measure program effectiveness. Notwithstanding these limi- tations, health costs are believed to have been reduced as a result of the program; otherwise, the company would have discarded it. The following elements are required for successful wellness programming according to Roberts and York (2000): (1) com- mitment from senior management (including monetary and personnel support, philosophical support, and participation in programs); (2) a clear statement of philosophy, purpose, and goals; (3) a needs assessment; (4) strong program leadership; (5) use of effective and qualified professionals; (6) accurate, up-to-date, research-based information made available to par- ticipants; (7) effective communication (high visibility, suc- cessful marketing, motivating to employees); (8) accessibility and convenience to employees; (9) realistic budget; (10) a fun, motivating, and challenging program philosophy; (11) a supportive work/cultural environment (company policies, company attitude toward employee); (12) a supportive physical environment (cafeteria and vending with healthy options, available fitness facility, windows, lighting, and truck cab); (13) individualization to meet the needs of each employee; (14) a defined system evaluation; and (15) posi- tive results. The wellness plan they developed is called

“Gettin’ in Gear” and includes the following four core topics, based on focus groups and surveys indicating that these are drivers’ greatest concerns: (1) Refueling (diet and weight); (2) Relating (family); (3) Relaxing (fatigue and stress); and (4) Rejuvenating (exercise). The approach is holistic, in recognition that driver health issues are not one dimensional but part of a larger dynamic system. Included in the “Getting’ in Gear” program were informa- tion presentation (brochures, videos, audios, and a notebook), written lifestyle questionnaires, physical risk factor assess- ment (cholesterol, glucose, body mass index, blood pressure, pulse, aerobic fitness via step test, strength fitness via push ups, and flexibility via sit and reach), goal setting and coach- ing, snack packs, exercise membership with the “Rolling Strong” gyms found in several truck stops across the country or subsidized YMCA memberships, and an evaluation. A pilot study was conducted over a 6-month period to deter- mine program effectiveness, determined by before-and-after lifestyle habits questionnaires and before-and-after physical measurements. Results for 54 individuals indicated that pro- gram participants improved significantly in 7 of the 15 areas with respect to eating habits, in all 6 areas relating to exercise, and in 2 of 13 areas relating to Relaxing; no improvement was found in area 2, Relating. It should be noted that participants scored well initially in this area, however. Significant improve- ments were also found in 6 of 10 physical risk areas: BMI, pulse, diastolic blood pressure, aerobic fitness level, strength fitness level, and flexibility fitness level. This review concludes by noting an initiative by FMCSA and its partners—the American Trucking Associations Foun- dation, the National Private Truck Council, and other indus- try participants—in 1996 to develop a driver/operator fatigue education and outreach program. A major goal of this initia- tive is to educate all 7 million CDL holders in the U.S. about how to master driver alertness (Krueger et al., 2002). Pro- gram elements include “Awake at the Wheel” public service announcements; the printing of 1 million “Awake at the Wheel” brochures and their distribution to truck and bus driv- ers, carriers, motorcoach companies, and other organiza- tions interested in motor carrier safety; the production of a 19-minute video called “The Alert Driver: A Trucker’s Guide to Sleep, Fatigue, and Rest in Our 24-Hour Society” and a 75-page booklet to accompany the video; a series of educa- tional courses on driver fatigue, including a 1.5-hour course for truck drivers, a 1.5-hour course for dispatchers and truck- ing managers, a 4-hour train-the-trainer instructional program, and a 1- to 3-hour course for trucking executives and corporate officials to help them decide whether to implement an employee fatigue countermeasure program. Krueger et al. (2002) indi- 16 cate that the 4-hour train-the-trainer course on operator/driver fatigue has been conducted over 55 times around the country between 1996 and 2002, and 30,000 copies of the “Alert Driver” video and booklet have been produced and distrib- uted to educate truckers and their families about fatigue. As of the date of this report, no evaluation studies of the effec- tiveness of this program could be located. FMCSA’s Final Rule Based on the study by Dueker (1995), FMCSA proposed and recently issued minimum training standards for operators of double- and triple-tractor trailer LCVs, requirements for instructors who train LCV drivers, and standards for entry- level drivers (Schulz, 2003; Federal Motor Carrier Safety Administration, 2003, 2004). According to Schulz, the gov- ernment’s proposal to train entry-level drivers does not require lengthy hands-on driver training. FMCSA’s new rule does not specify a required number of hours for the new training, but estimates that training will require approximately 10 hours. FMCSA’s final rule applies to truck and motorcoach drivers who (1) hold a CDL (and school bus drivers employed by non- governmental entities who hold a CDL), (2) operate in inter- state commerce, and (3) have less than 1 year of experience operating CMVs. FMCSA is not requiring entry-level drivers to receive additional training in the areas covered by the CDL test, stating that such training would be redundant. The new requirement is for these entry-level drivers to receive train- ing in four areas that are not covered in the CDL licensing exams but are areas that FMCSA believes driver knowledge is vital to large truck and bus safety: (1) driver qualification (multiple medical conditions); (2) hours-of-service (including fatigue prevention strategies and causes of fatigue); (3) driver wellness (diet, exercise, stress); and (4) whistleblower pro- tection (Federal Motor Carrier Safety Administration, 2004). FMCSA estimates that the new training for entry-level drivers will need to prevent 201 truck-related crashes (combining fatal, injury-related, and property-damage-only crashes) per year by the 32,400 entry-level drivers affected by its provisions in order to be cost beneficial. Under the FMCSA rule, employers will have 90 days to ensure that all currently employed entry-level drivers receive the required training. Training could be provided by the motor carrier, a training school, or a class conducted by a consortium or association of motor carriers, but documentation that drivers have fulfilled the training requirement must be filed with the drivers’ personnel files and documentation of the curriculum content must be maintained for safety investigation purposes.