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

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

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

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

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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)

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12 TABLE 2 (Continued) Curriculum Topic Heavy Trucks Motorcoaches Vehicle-Related, Nondriving Activities 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)

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13 TABLE 3 Summary of training adequacy findings for motor carriers (Dueker, 1995) Heavy Trucks Motorcoaches Percent of motor carriers who provide formal training for 21.6 62.5 their hired entry-level drivers Percent of sampled motor carriers whose formal training 37.5 29.6 was judged as "adequate" Estimate of the percent of motor carriers who provide 8.1 18.5 adequate training for the entry-level drivers they hire TABLE 4 Summary of training adequacy findings for drivers (Dueker, 1995) Formal Training Percent of Drivers Percent of Programs Percent of Drivers Methods Trained Adequate Adequately Trained Heavy Trucks Proprietary 47.5 44.8 21.3 Public Funded 7.8 54.5 4.2 Company/Military 6.4 87.5 5.6 Total 61.7 50.0 31.1 (Sample Size) (141) Motorcoaches Company 50.0 36.4 18.2 theory and skills in controlled settings (e.g., through the use and windy conditions than single heavy vehicles and should of a skid pad). The authors assert that, by preventing heavy be overrepresented in crashes under these conditions. The truck crashes at a per-crash-cost of $100,000, the wider use authors explain this finding by noting that most carriers use of such facilities would be very cost-effective. Kostor and more experienced drivers on LCVs and instruct all drivers to Summerfield support their conclusions through analyses of adjust for conditions or cease operation until the adverse heavy truck crashes that occurred in Manitoba, Canada, weather has passed. 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 Responses to the NPRM vehicles. Approximately 41% of heavy truck crashes occurred under winter (i.e., icy or snow covered) and spring/fall (i.e., Comments on FMCSA's proposed training requirements mud, wet, and slush) road surface conditions, compared with were due to the agency by October 11, 2003. Thirty-eight 23% of passenger vehicle crashes. Also, more crashes comments were received. The response from industry and occurred on poor roads under higher wind speeds for heavy other interested parties relevant to the topic of best prac- trucks than for passenger vehicles. For passenger vehicles, tices for training entry-level drivers, as summarized in the 71% of icy/snow-covered road crashes occurred with low following paragraphs, is informative.3 winds (i.e., wind speeds below 25 km/h [15 mi/h]) and 29% Over one-third of the comments--most of which came occurred with moderate winds. In comparison, 63% of heavy from schools--focused on the proposal "falling short of a truck crashes on icy/snow-covered roads occurred under low minimum standard for the training of entry-level drivers." winds, and 37% occurred under moderate winds. Though The majority of these respondents suggested that the four high-sided vehicles do not perform as well as passenger vehi- proposed topics be incorporated into the Model Truck Driver cles in inclement weather, truck drivers should be able to and Model Motorcoach Driver curricula, which should then be compensate for this, given significant training. identified as the minimum standards for training entry-level Kostor and Summerfield (2001) also looked at the crash drivers. A few of these commenters further stated that the experience of Longer Combination Vehicles (LCVs) under delivery of the PTDI curriculum should be more flexible and inclement weather conditions. They found that the LCVs performance-based, to make the training more effective. crash experience was not disproportionate to singles under low wind and icy road conditions and, in fact, the number of 3See the U.S. DOT's Document Management System at http://dms.dot.gov. To crashes under moderate wind/icy road conditions for these 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 vehicles was less than those under low wind/icy road condi- FMCSA-1997-2199-215. Direct quotations in the following paragraphs are taken tions. In theory, LCVs would be more unstable under icy road from these documents.

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

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

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