Training of Commercial Motor Vehicle Drivers (2004)

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17 CHAPTER 3 STRATEGIES AND TECHNIQUES TO ENHANCE TRAINING EFFECTIVENESS SIMULATORS As discussed by Vance et al. (2002), one of the greatest advantages of simulator training is the ability to recreate dangerous situations without putting drivers and equipment at risk. Simulation can expose drivers to high-risk situations such as blowouts, brake failures, and hazardous road and weather conditions, allowing sufficient practice with infre- quently encountered events so that an automatic behavioral response can be learned. Vance et al. (2002) state that begin- ning drivers benefit most from part-task training, where each situation is separated into components that can be taught incrementally, starting with basic skills such as baking up, steering, maneuvering through traffic, or parking. They indi- cate that experts who need refresher training benefit more from a full-task simulator, where greater interactivity (i.e., system response to a driver’s control inputs) is afforded, permitting better transfer of existing skills into new environments, such as poor road and weather conditions, or when learning how to deal with equipment failures. The development of train- ing scenarios and the platforms used to deliver training are considerably more expensive for full-task than for part-task simulation. Data regarding the effectiveness of simulator training for truck drivers is sparse. In their review of practices in the Euro- pean Union and North America, Horn and Tardif (1999) state that truck driver training has generally remained low tech, with the majority of training done using traditional methods of teaching. Although training simulators are appearing in some schools, they will remain the exception for years to come because the trucking industry and the private training schools do not have the money to pay for these tools. How- ever, Horn and Tardif embrace the continuation of research and development on simulation technologies to identify areas where transfer of training and acquisition of additional expe- rience can be gained through the use of these technologies at a cost that the trucking industry can afford. A potential solu- tion is offered by Brock et al. (2001). Based on their findings that simulator training in the motorcoach industry has safety and efficiency payoffs, these authors have proposed regional training centers as a means of offering simulator training to numerous small- and midsized transit agencies that would otherwise not be able to afford them. Using this approach, a consortium of agencies would manage and fund the regional training center. Alternatively, simulators could be installed in trailers and taken to each agency in the consortium on a set schedule. Pierowicz et al. (2002) evaluated the adequacy of six sim- ulators for use in a three-part study to determine whether simulator-based training can enhance training effective- ness and improve the performance of tractor-trailer drivers, compared with conventional training methods. The bulk of the Pierowicz et al. (2002) report describes the functional- ity of the six simulators and their adequacy for use in three upcoming validation studies. The simulators were evaluated on 183 factors to determine their adequacy in supporting the research design of the three study phases. No procurement for the three study phases had been released at the time of this report, however. The results of this study, when com- pleted, will provide valuable data to fill the gaps in the knowl- edge regarding the effectiveness of simulation in training truck drivers. Regarding the use of simulators for training motorcoach drivers, Brock et al. (2001) conducted a literature review, sur- veys, and site visits. They concluded that transit bus operator training can be improved with selective use of transit bus sim- ulators. They also noted that a critical feature in the success of simulator training programs is the competence and enthusiasm of the instructional staff. The Brock et al. (2001) report discussed three current appli- cations of simulator technology: (1) An open-loop video simulator—Doron L-300; (2) a low-end simulator—Doron L-301 VMT-Vehicle Maneuvering Trainer; and (3) a midrange simulator—FAAC MB 2000. All three simulators are used to train new drivers; they are also often used to retrain more experienced drivers. However, each device trains a subset of the skills required by drivers of transit buses, but none trains them all. The open-loop system is the least expensive of the three systems and is the most frequently used. It uses a video display of traffic, and several students may be trained simulta- neously at different stations, each with steering wheels, brake and accelerator pedals, and other rudimentary controls. It is not interactive, i.e., student inputs do not affect the playback of the training videos. The utility of this tool lies in its ability to train and test reaction time and visual recognition. The fundamen- tals of stopping distances, driving under different road con- ditions, and the relationship of speed and reaction time can be demonstrated and practiced.

Both the low-end and midrange simulators discussed by Brock et al. are limited to training one user at a time; how- ever, this provides one-on-one time with an instructor. The low-end simulator is designed to train students to maneuver a transit bus in relatively tight, unforgiving situations. It is a model-board system that replicates the visual, auditory, and vibratory effects of driving a bus in an urban, crowded envi- ronment. Skills that may be taught with the system include approaching a bus stop, parking, tight turns, and backing. Brock et al. state that students and trainers are convinced that use of this simulator allows new operators to get into actual buses more quickly and results in safer drivers. The midrange simulator is the newest and most expensive, and few are cur- rently in use. Its visual (graphics-based) and auditory systems are much more realistic, and it uses a rear-projection screen allowing drivers to adjust their mirrors to experience the full extent of the driving environment beside and behind the vehi- cle. A student drives in a 50-square-mile virtual world where the instructor regulates other traffic flow and can insert vehicle malfunctions into the scenarios. Brock et al. (2001) note that the use of simulation decreased trainee drop-out rates by 35% for an agency using the mid- level simulator, decreased student failure rates by 50% in an agency that uses the open loop and the low-end simulators, and decreased the collision rate by 10% in an agency using a combination of open-loop and low-end simulators. In addi- tion, the use of simulation reduced training time in one agency from 19 days to 17 days, by replacing classroom bus train- ing with simulator training. In another agency using just the open-loop system, training time was reduced by 5 days when simulation was employed. The only agency surveyed that used the midrange simulator reported that 90 days after train- ing, 32% of their conventionally trained drivers had expe- rienced a crash, compared with 18% of their simulator- trained drivers. In this agency, simulator training in tasks related to overtaking and being overtaken by vehicles on the left and right sides of the bus resulted in fewer crashes by the students performing these maneuvers in the real world (17 crashes by the simulator-trained students compared with 154 crashes for the nonsimulator-trained students). The transit agencies surveyed by Brock et al. reported that simulators are also able to replace some of the hours spent in the actual vehicle. This can have a significant impact on train- ing costs, as simulator costs can run as low as $3 per hour per student versus $40 per hour per student for in-vehicle training. Results of a survey of bus operator trainers conducted by Brock et al. (2001) indicate a high level of satisfaction with their training simulators. Fifty-eight percent of the respondents indicated that simulator training is more effective than tradi- tional training for teaching certain types of knowledge, skills, or attitudes. In particular, simulator training validates defen- sive driving techniques taught in the classroom, provides an opportunity to experience hazardous situations without putting the students or the bus at risk, reinforces proper driving habits and defensive driving principles, and allows instructors to check reaction time, eye-hand coordination, and driving skills. Instructors indicated that trainees with little or no experience 18 were better prepared for their initial driving assignment. Seventy-five percent of the drivers surveyed reported that their bus simulation training enhanced their learning experience, although 6 of the 51 respondents reported motion sickness, dizziness, and disorientation after bus simulation training. Guidelines for what type of simulator should be acquired by agencies wishing to integrate training into their curriculum were provided by Brock et al. (2001). An open loop simulator provides skills-based training opportunities. It can be used to train perceptual skills in a noninteractive environment, includ- ing stopping distances, role of reaction time, and visual recog- nition. It costs approximately $40,000 to $80,000. A low-end simulator provides rules-based training opportunities and some skills-based learning. It can be used to train vehicle maneuvers in a static environment, including parking, backing, turns, and tight maneuvers. It costs approximately $100,000. A midrange simulator provides skills-based, rules-based, and knowledge-based training opportunities. It can be used to train skill integration in a dynamic environment, including forward planning, observation skills, push-pull steering, directional signal use, proper mirror use, and driving in traffic. It costs approximately $300,000. When deciding to use simulation, companies (or schools) must adjust their current training pro- gram to utilize the particular technology appropriately; oth- erwise, just adding simulation to an existing program could add to program cost without increasing effectiveness. Vance et al. (2002) similarly offer that reasoning or cogni- tive ability tasks do not require high physical fidelity simula- tors, whereas training that involves learning perceptual-motor skills or the interaction of the trainee with the layout of the equipment does require high physical fidelity. Also, a close cor- respondence between equipment in a simulator and the actual equipment in the vehicle is desirable to enhance the transfer of training to the real-world situation. At the high end of simulator applications for CMV driver training, a $1-million system recently purchased by the Texas Motor Transportation Association deserves mention. This system is used to allow experienced truck drivers to safely experience dangerous situations such as a veering car, a tire blowout, or dense fog. The full-motion simulator is built into a 53-ft trailer and uses an authentic truck cab that moves in response to a driver’s inputs when viewing driving scenarios on a large screen. The trailer also contains a small classroom with six computers that provide interactive lessons on topics such as space management and securing loads. The associa- tion will rent the unit to carriers for $1,000 per day. No data regarding the effectiveness of this training tool was found in this review. COMPUTER-BASED TRAINING Computer-based training is a means of providing company- wide job consistency and reducing training costs (Kahaner, 2001). UPS, which has been using CD- and web-based pro- grams since 1998, states that they are much more efficient and yield better results than paper manuals. A computer-based

training program that has been implemented by Smithway Motor Xpress (Ft. Dodge, IA) to teach load securement pro- cedures has reduced training costs from $1,000 per driver to $150 per driver. It has been associated with a reduction of claims in that area of 87%. Most of the cost saving results from a reduction in the time it takes drivers to learn the material when presented using computers compared with classroom lecture and on-the-job training. Drivers learn at their own pace and can take laptops with them on the road and study the coursework in their down-time. Also, the statistics that computer-based programs keep (topics trained, length of time to train, and areas of difficulty) can pinpoint areas where additional help is needed. Kahaner (2001) further states that computer-based training is more attractive to younger drivers who were brought up playing computer games and are used to the faster pace of TV and the Internet; these individuals would be bored with training that is limited to classroom lecture. Ryder (2000) describes a computer-program developed by Instructional Technologies, Inc., that delivers 32 1-hour lessons on trucking fundamentals based on the PTDI cur- riculum. This vendor provides schools and fleets with com- puters at no cost and delivers the lessons via a high-speed Internet connection, so that schools and fleets pay only for what they use. The lessons are presented using video, high-quality graphics, and animation to explain concepts and demonstrate driving practices. Students log onto the program with a code, and must answer questions about the instructional material roughly every 3 minutes, which ensures that they are paying attention. A benefit of this program is that it standardizes train- ing and provides documentation that a student has received training. Thompson (1996) describes a CD-ROM training program implemented by Frito Lay to train drivers about DOT regula- tions, focusing on alcohol and drug requirements. CD-ROMS and PCs have been placed in 40 company locations through- out the United States. The program takes 2 hours to complete, and drivers are given 90 days to finish the training. The Safety Director believes that the delivery of training using the CD- ROM is more entertaining than reading text or watching plain voice-over videos, and the methodology allows the training to be delivered in a flexible manner, which eliminates schedul- ing difficulties common with conventional classroom training. A computer tracks driver status in training, time spent in train- ing, and the driver’s scores, producing proof of compliance with training for the DOT. Additional programs on defensive driving, proper use of the onboard computer, and pretrip and posttrip inspections are planned using similar computer-based training technology. VIDEOTAPES AND SLIDE PRESENTATIONS TO SUPPLEMENT CLASSROOM INSTRUCTION Videotape presentations are available today that address virtually any subject a company wishes a driver to know con- cerning product delivery and safety. More than a decade ago, the FHWA stated that the number of training aids was so 19 great that the problem was how to locate, select, and evalu- ate the most appropriate ones for the company (Uzgiris et al., 1991). While audiovisual aids are offered as a countermea- sure for preventable crashes and to improve fleet safety, it is important to determine what mix of audiovisual aids, posters, manuals, pamphlets, and other literature is most effective in improving a company’s training program. Sources of driver training aids mentioned by the FHWA include national and state truck and bus associations, safety organizations, insur- ance companies, company in-house productions, and private- sector providers and consultants. Historical examples include a videotape series to stan- dardize training for drivers who haul bulk liquid and gaseous products, the majority of which are hazardous (Snyder, 1983). Drivers progress from classroom instruction that includes personal and videotape training, to hands-on training, and then back into the classroom several times before being cer- tified for over-the-road work. Another example is a video developed by the American Trucking Associations and FLI Learning Systems; it was designed to improve drivers’ atti- tudes and skills and help them realize how their behavior on the road shapes the public’s perception of the trucking agency (Dandrea, 1986). As part of a 4-hour program, the multime- dia components include a 12-minute film addressing attitude and image and a 6-part audio-narrated slide series designed to improve driver techniques for handling high-frequency crash situations. More recent experience with such tools includes the use by in-house instructors at PST Vans (Salt Lake City, UT) of the product noted at the end of Chapter 2, “The Alert Driver: A Trucker’s Guide to Sleep, Fatigue, and Rest in Our 24-Hour Society,” during orientation for new drivers and at safety meetings for their experienced drivers. This company employs 1,500 drivers who are on the road for 2 to 3 weeks at a time. They train their new drivers in top- ics relating to how to deal with fatigue, how to eat and sleep properly, and how to maintain positive relationships while away from home for long periods of time. Discussions include sleep and rest needs, diet, stress, lifestyle, and how these relate to driving, and leads nicely to discussions about DOT regulations and hours of service rules. Another program employed by PST Vans for all new hires (entry-level as well as experienced drivers) is a video test developed to measure a driver’s traffic-related knowledge and skill level. This can be used by the company for decisions relating to driver training needs and assignments. Drivers watch a 60-minute video, using paper answer sheets to indi- cate whether they agree or disagree with actions portrayed in different traffic scenes, making split-second decisions as they would in real-life driving. Different parts of the video measure driving and traffic knowledge (e.g., traffic laws, road rules, driver readiness, driving in traffic, and vehicle readiness); traffic perception skills (e.g., searching the driving environ- ment, identifying and classifying hazards, predicting what other drivers will do, and deciding which maneuver is most appropriate given the situation); traffic risk recognition and acceptance (e.g., yielding to other roadway users, vehicle

positioning, vehicle speed control, passing other roadway users, and environmental risks); and driving procedure skills (e.g., observing, communicating, speed adjustment, vehicle positioning, and time and space judgment). Results catego- rize a driver’s skill level as low, medium, average, highly skilled, and expert, and estimate the statistical probability that driver training will improve driving performance. They also influence where the company places their newly hired drivers in training. Driving school graduates who score high on the video test and also score high on PST’s on-road test may be placed in the accelerated fleet training program, which pays drivers 2 cents more per mile and puts them on a fast track for a first-seat driver position. The company reports a reduction in crash frequency since program implementation for all crash types, including in-traffic and single-vehicle crashes. In addition, scores improved for entry-level drivers on post- training testing (after 90 days). Within one 6-month period, PST reported a reduction in incidents from 225 to 125, where incidents are defined as anything requiring an incident report, from a DOT-reportable crash to a worker compensation acci- dent (Cleaves, 1997). A search of the Internet identified a number of instructional products, including instructors’ kits and driver workbooks for self-paced courses, as well as a self-paced defensive driving course. The latter course concentrates on critical commercial driver’s license and National Safety Council (NSC) defensive driving principles, including pretrip inspec- tion, cushion of safety (following distance, stopping distances, blind spots, and tailgaters) and effective scanning procedures applied to city, highway, and rural driving situations. It also zeroes in on safe backing procedures, night driving, impaired drivers, adverse weather conditions, triangle placement, and the importance of adequate sleep, exercise, and proper nutrition. The NSC’s Defensive Driving Courses (DDCs) are in many ways the pre-eminent example of how video is used to sup- plement classroom instruction. Some companies use DDC-4 (4 hours), DDC-6 (6 hours), or DDC-8 (8 hours) as a foun- dation for their fleet programs for their new recruits and as a refresher, while others use its 8-hour professional truck driver course (DDC-PTD). Some companies also require employ- ees who have been involved in a preventable crash to com- plete a DDC before they are permitted to return to the road. Companies commonly use the DDCs as the core of their classroom training and add a film on a particular topic or use in-vehicle training to reinforce the concepts taught in the classroom. Training effectiveness statistics provided by Kiell (1989) indicate safety improvements as a result of such train- ing for a wide range of users. ChemLawn reported a 50% reduction in costs from crashes over a 4-year period (1985 to 1989); it also reported its insurance costs decreased, whereas the rates of most other companies increased over the same time period. The Indiana Department of Highways reported a 40% reduction in crashes over a 5-year period (1984 to 1989), while Houston Lighting and Power reported reductions in costs associated with vehicle damage (32%), property dam- 20 age, third-party claims, and lawsuits (8%), and crashes per million miles of vehicle travel in primarily urban driving areas (23.5%). The cycle under which these companies and agencies require their drivers to undergo defensive driving refresher training averages 2 to 3 years. HANDS-ON, ON-THE-ROAD Beginning drivers who complete formal training—includ- ing the PTDI curriculum standard—cannot be considered fully trained drivers without additional road experience and vocational-type training (such as loading tankers, chaining on loads, etc.), under the guidance and supervision of an experi- enced, professional driver. As noted earlier, PTDI not only calls for each student to receive a minimum of 44 hours of actual behind-the-wheel time to complete the basic, or core, curriculum, but also stresses the need for an externship of 140 to 240 hours of additional (on-duty) instruction to provide the training and experience needed for an entry-level driver to progress from a second-seat to a solo driver (Professional Truck Driving Institute, 1999). The procedures and require- ments for finishing training as implemented by a cross-section of schools and carriers are discussed below. Wiggins (1990) describes the requirements for trainers at Contract Freighters, Inc. (CFI) and the training that the com- pany provides to newly hired drivers. CFI’s trainers are com- pany drivers who undergo a 36-hour in-house course that includes methods of motivation, constructive criticism, and mental aspects of the job (teaching drivers why they should do something in addition to what they should do). Prospec- tive trainers observe each others’ driving performance and provide constructive criticism before they begin training new hires. Once a trainer begins working with new hires, he or she undergoes a management review every 6 months. Before they go on the road, new drivers undergo a week-long orientation which includes meeting department managers, attending pre- sentations on equipment maintenance and safety, and federally mandated physical and road testing. Then, a trainer-finisher travels 14,000 miles with the new driver, to supervise regular demands of the driving task, provide practice in backing, and provide training in skills such as brake adjustment. The finisher and driver may act as a sleeper team only after 7,000 miles of training have been completed, and only if there have been no preventable crashes. After the new hire completes the 14,000 miles, the driver undergoes a road analysis test includ- ing a written questionnaire to determine how much was learned and to rate how well the finisher performed in providing train- ing. After the finishing training, the new driver is placed with another driver with similar experience for 25,000 miles as a sleeper team. If a crash occurs, an additional 10,000 crash-free miles must be completed. The drop out rate of the finishing program at CFI is 32%, most of which occurs during the finishing training. According to the company’s director of training, once a new driver has completed the finishing program and sleeper team driving,

there is an 85% likelihood that the driver will stay with the company. Periodic retraining is also important to correct bad habits, reinforce driver safety, and reduce crashes. Refresher training can be accomplished by a range of programs: short courses covering topics most important to the company’s oper- ation, such as braking and brake adjustments, speed and space management, etc.; group simulator training; and individual training in a full motion cab simulator. Certification of training instructors is paramount for PST Vans, which employs a proprietary, hands-on, defensive- driving system for its finishing training (Cleaves, 1997). The PST instructors present the course to drivers in groups of four. Drivers first spend classroom time learning about crash statis- tics and common factors that cause collisions. The training is organized around the concepts of total awareness, emphasiz- ing perceptive anticipation, accurate forecasting, early detec- tion, and deliberate reaction. Drivers also learn the importance of attitude and emotions and how they affect driving. Practical instruction on how to avoid low-speed collisions when back- ing and parking and how to avoid rear-end and intersection collisions is not overlooked. Drivers then go on the road with the instructor for 3 to 4 hours, so the instructor can point out and correct any poor driving habits and poor driving deci- sions in traffic. The training instructors must be recertified every 2 years in refresher training provided by the vendor of the training course. Browning-Ferris Industries (BFI) developed its own train- ing program for entry-level drivers because of the unique characteristics of its garbage trucks, which are 10-wheel vehicles that do not bend in the middle (straight trucks). The requirements for driving these trucks are different from the requirements of driving tractor trailers and van-rig type trucks. The training had to suit the requirements of drivers who drive in low traffic, in residential areas, in low light, and with con- stant mounting and dismounting by crew members to remove trash. In addition, company employees must back their trucks at least 100 times a day, often for relatively long distances. The program includes training videos showing company vehi- cles in situations that BFI drivers typically encounter and booklets that prepare drivers for the CDL written test, pretrip inspection, road test, and special endorsement exams. The training was considered effective, based on in the fact that the first 300 drivers who attempted the CDL had a first-time pass rate of 97%, compared with the first-time pass rate of 50% experienced by other companies who did not train their driv- ers for the CDL. BFI’s CDL program became a standard part of the com- pany’s operating procedures. It only hires drivers who have passed the CDL, and these new hires must undergo classroom training, followed by hands-on training with the specific vehicle they will operate. They then ride as a passenger in the vehicle to learn from an experienced driver or supervisor. After that phase, the new hire may go on-the-road under supervision by an experienced driver. Some new hires com- plete the program in 2 weeks, while others require 6 weeks to become proficient. BFI estimates that its driver-training pro- 21 gram, including refresher training using the NSC’s DDC, reduced the number of collisions about 33% between the years 1988 and 1993. While the success of the BFI training program can be attributed in part to the use of vehicle- and location-specific training and reliance on experienced drivers, the company asserts that its single most effective motivating and training tool is its annual truck and equipment rodeo. In this event, the top drivers, operators, and mechanics (and their families) from company operations all over the world are treated to an all-expenses-paid trip to compete and demonstrate their skills. More broadly, Horn and Tardif (1999) testify to the use of motivational and incentive/recognition programs, beyond the use of company training programs, in offering significant potential for safety improvement and driver retention. Horn and Tardif cite research Tardif conducted in Canada, finding that over 70% of the 40 trucking fleets interviewed had a safety incentive or recognition program in place. The effectiveness of these programs in reducing crashes is “remarkably high” and the benefit–cost ratios are usually greater than 2 to 1. Accord- ing to Horn and Tardif (1999), results of validation research indicate that such programs also improve driver retention. Much of the industry input addressing the question of what constitutes adequate training and the specific nature and extent of requirements to finish training was gleaned from responses by schools and trucking companies to FMCSA’s ANPRM in 1993. The relevant material is available on the Internet through the U.S. DOT’s Document Management System.5 Information from these responses is summarized below. In some cases, the FMCSA information about training methods employed has been supplemented with more detailed or updated material from an organization’s web site. The Wisconsin Decision Driving Center at Fox Valley Technical College, a PTDI-certified school, offers a 1-day workshop to give drivers hands-on experience in learning how to avoid crashes. An off-street driving range simulates emergency situations that test a driver’s limitations and a vehicle’s capabilities. Drivers learn controlled braking tech- niques, off-road recovery techniques, evasive maneuvers, how to handle dry and slippery curves, skid control, jackknife recovery, the antilock brake system, reaction time and vehi- cle braking distance, and vehicle dynamics and control. The center features computer-controlled evasive devices and a 200 ft × 500 ft skid pad. The curriculum offered by this facil- ity provides 1,500 miles of behind-the-wheel training experi- ence by the time a student graduates from the 12- to 15-week program. Training is provided on flat beds, twin trailers, and tanker trucks up to 48 feet long and 102 inches wide. A coop- erative unit of instruction between the college and Wisconsin trucking companies is offered to students who graduate from the program, allowing over-the-road driving experience with a veteran driver. 5See the U.S. DOT’s Document Management System at http://dms.dot.gov; search under Old Docket No. MC-93-12 to retrieve Document Numbers FMCSA-1997-2199-1 to FMCSA-1997-2199-215.

Reiterating the need for finishing training for entry-level drivers, the Becker Driver Training Facility has expressed the view that, “after a few hours of instruction, most students can pass the (CDL) driving test in a controlled circumstance. Unless minimum programs with hands-on training under the direct guidance of a veteran 10-year licensed instructor are established, unskilled heavy duty operators will continue to operate on the highways.” This Minnesota facility offers a 6-month, 1,200-hour interstate course that is 75% hands-on training under the guidance of a veteran driver instructor. In the over-the-road training, there is a 1-to-1 student–teacher ratio. The course includes 338 classroom hours, 366 hours in the yard and on the range, 100 hours of observation and road driving that includes preparation for the CDL, and 400 hours of observation, commercial type driving, and hauling of cargo; these last 400 hours of training involve actual driving and hauling of interstate freight. In addition to basic truck- driving techniques, students learn the following skills: map reading and trip planning, hours of service, preparation of the daily log, vehicle safety inspections; understanding the bill of lading instructions; building personal stamina, proper diet, and how to help the body adjust to different wake/sleep, work hour patterns; and mechanical aptitude. Another school, C1 Professional Training Center in Indiana, indicated in its response to the FMCSA ANPRM that the cru- cial factor in determining the effectiveness of a training pro- gram is the amount of time the student spends in and around the cab of a truck. This school spends over 75% of the train- ing time in and around the cab of the truck, has a student- instructor and student-truck ratio of 2:1, and uses an instructor force that averages over 20 years of truck driving experience. The Director of Training at this school, in concert with other commenters to this ANPRM, stated that it is not how many hours of training that determines whether a student is ade- quately trained but the skill level that the student demonstrates. One comment with multiple signatures stated that truck driving schools do not have students load, unload, and prop- erly secure a load. Drivers are learning how to properly load their trailers by trial and error, and error may cause an accident. One company, Baraboo Sysco, said training for entry-level drivers consisted of a 4-week program, including 32 hours of night driving, 145 hours of day driving, and 32 hours of yard driving (backing and cornering maneuvers). This is followed up by supervisor “ride-withs” twice each month. Similarly, Virginia Power comments indicate the use of on-the-job entry-level driver training procedures. Entry-level drivers are shown films about safe driving and a film on pre- and post- trip inspections specific to company utility service vehicles. They then obtain their CDL learner’s permit and are assigned to a crew with an experienced utility service vehicle operator who trains the entry-level driver to operate the specialized company utility service vehicles. The on-the-job training period lasts from 3 to 6 months. Another company, John Christner Trucking, Inc. (Sapulpa, OK), requires entry-level drivers, who must have graduated 22 from a PTDI-certified school, to undergo over-the-road train- ing under the supervision of an experienced trainer/finisher driver until they reach a suitable level of experience to oper- ate alone. Similarly, EPES Carriers, of Greensboro, North Carolina, provides entry-level drivers, who have graduated from an approved truck driver training school with PTDI or similar standards, with finishing training through a driving school (the Carolina Training Center). This includes DDC- PTD (the 8-hour training for professional drivers developed by the NSC) and supplemental training in handling hazardous materials. At J. B. Hunt, entry-level drivers who have satisfactorily completed a driver training program that meets or exceeds PTDI standards and have obtained their CDL must complete a “preimprovement” interview, road test, and company ori- entation. These drivers are then assigned to a J. B. Hunt Cer- tified Trainer for a supervised Advanced Driver Training Program. Upon completion of the Advanced Driver Training Program, drivers are evaluated with written tests and exams and given an additional Road Skill Evaluation before being upgraded to a lead (first-seat) driver. Federal Express requires entry-level CMV drivers to com- plete a 3-week classroom training program that includes the subjects listed in the PTDI Model Curriculum. Following classroom training, prospective drivers are required to com- plete 1-week of on-the-job training with an experienced driver trainer. Entry-level drivers must successfully complete both phases of Federal Express’ training program before operating a CMV on public highways. Drivers employed by the Wisconsin-based Schneider National trucking organization who have not yet logged 30,000 miles are divided into two categories. The first group consists of drivers who have attended a driving school and have a CDL. They are trained for 1 week (3 days classroom and 4 days over the road). Upon passing the company road test, they spend a minimum of 2 weeks with a training engi- neer. The training engineer does not sleep while the student drives and limits his or her own driving for demonstration purposes to less than 25% of the miles driven during training. The second group of drivers consists of drivers with no expe- rience or CDL. They attend a basic course for a minimum of 2 weeks and must pass both CDL tests and the company road test before moving on to the training engineer stage. Trainees are later teamed with another driver for the next 4 to 6 weeks. Schneider has an on-going program of driver training to ensure up-to-date skills. Annual recertification in hazardous materials and brake adjustment is required. Training is also offered in log- ging, backing, defensive driving, slow maneuvering (e.g., cor- ners, etc.), injury prevention, trip planning, and fuel-efficient driving. Schneider also utilizes regular skid-pad training. Driv- ers who handle special freight are required to complete extra training. For example, those in specialized carriers (flatbed trail- ers) complete 7 days of classroom instruction and hands-on training. Those in bulk carriers (tankers) complete 6 days of classroom and hands-on instruction.

A final set of examples illustrating requirements for finishing training on entry-level drivers includes the following: • Robert Hansen Trucking, Inc. (Delevan, WI): 10,000 to 30,000 miles of hands-on training with a company driver trainer-finisher are required after the trainee has completed a 12-week, full-time truck driving program (classroom, lab, range, and on-street) covering the PTDI curriculum. • ROCOR International (Oklahoma City, OK): After a candidate completes a PTDI-certified driving school pro- gram, trainees without any prior experience are placed 23 with a driver-trainer for a period of 8 to 10 weeks before being assigned their own truck. Trainees with more than 3 months but less than 6 months of experience must com- plete the apprentice program of 6 weeks with the driver- trainer. Trainees with more than 6 months but less than 12 months of driving experience must complete 3 weeks with the driver-trainer. • CRST (Cedar Rapids, IA): Its new drivers must spend a minimum of 50,000 miles on the road with a driver- trainer after graduating from one of seven PTDI- certified training schools.