The Entry Level Driver Training Advisory Committee, made up of representatives from the CDL training community, motor carrier and operator associations, an owner-operator himself and other constituencies, completed its final meeting last month on an accelerated “negotiated rulemaking” relative to requiring pre-skills-test training for any CDL applicant. This week, it released its final recommendation.
The committee issued a “consensus recommendation” for a regulation requiring CDL applicants be trained according to curricula specified for both Class A and Class B CDL applicants, with separate curricula for passenger, hazmat and school bus endorsements. Also, separate curricula for refresher-course training is also detailed in the group’s written statement, accessible in full via this link.The group recommended refresher training — rather than full re-training — for anyone whose CDL had been canceled, suspended or revoked and who was reapplying.
The recommended regulation, if promulgated, would also establish a registry of FMCSA-certified Entry Level Driver Training Providers, with separate eligibility guidelines for larger schools training more than 3 drivers per year and smaller businesses training 3 or fewer drivers annually.At once, the future for any entry level driver training rule is uncertain. Given the final committee vote was non-unanimous, FMCSA only “agrees to use the Written Statement in any recommended regulation,” not adopt its terms necessarily in whole cloth in a Notice of Proposed Rulemaking.
The primary issue driving the dissenting votes appears to have been a requirement in the curricula for Class A applicants to complete 30 hours of behind the wheel driving on range or road, 15 hours for Class B applicants. Notably, the National Association of Small Trucking Companies voiced its dissent in the written statement itself, worrying the “vociferous advocates” for hours-based training would only keep up such advocacy and ultimately put a burden on new drivers in the form of ever-increasing hours requirements.Thirty hours, NASTC said, “may represent the camel’s nose under the tent. The advocates for hours-based standards refused to hold off initiating efforts to increase the number of hours until actual data from real-world experience under the 30 hours could be gathered and analyzed. This display of bargaining in less than good faith was telling and indicated to NASTC that 30 hours is only the beginning.”
NASTC likewise tends to favor performance standards, it noted. A NASTC member survey conducted in tandem with the data-collection working group within the ELDTAC “demonstrated little connection between type of pre-CDL training received and driver performance. This was borne out in respondents’ actual crash data….
“It stands to reason that if one masters the basic skills and maneuvers satisfactorily in a pre-CDL environment, based on an individual’s performance behind the wheel, these new drivers would be somewhat better equipped to get through their first few years more safely and efficiently as commercial drivers. Performance in preparation generally translates into performance in action. Performance, therefore, would seem a more robust standard for entry-level driver
training than hours.”
from Overdrive http://ift.tt/1HUzRKg
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