ATA, NASTC File Opposition to Hours-Based Training Plan

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This story appears in the June 22 print edition of Transport Topics.

American Trucking Associations and the National Association of Small Trucking Companies have sent letters to the head of an entry-level driver training advisory committee, opposing the recommendation of an hours-based behind-the-wheel instruction rule.

ATA said the recommendation of 30 hours of combined on-road and off-road instruction is not scientifically supported and runs contrary to a pair of executive orders.

“ATA cannot support an hours-based requirement at this time and believes that further study of different training approaches is required before any meaningful conclusions can be drawn about the efficacy



of any hours-based training requirement,” the federation’s Boyd Stephenson wrote to Richard Parker, a University of Connecticut law professor who served as committee facilitator.

“Without an empirical underpinning, the committee’s recommendation of a particular hours-based requirement is purely arbitrary,” said Stephenson, vice president of international supply chain operations for ATA.

Similarly, NASTC said entry-level drivers probably would be better prepared with performance-based standards.

“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,” NASTC wrote. “Performance in preparation generally translates into performance in action. Performance, therefore, would seem a more robust standard for entry-level driver training than hours.”

Students master skills at different paces, which means an hours-based plan would not be as effective, NASTC added.

ATA and NASTC were part of the Federal Motor Carrier Safety Administration’s 26­member panel created to help craft an entry-level training rule.

They both voted in support of the overall package of recommendations but dissented in a separate vote on the hours-­based instruction provision.

The group convened six meetings, spread into two-day sessions, to draft the framework for a “negotiated” proposed rule. The committee completed its work May 29.

Don Lefeve, president of the Commercial Vehicle Training Association, said he views the 30-hour driving instruction time as a minimum requirement.

No qualified instructor would pass a student whom the instructor didn’t believe would be a safe driver, Lefeve told Transport Topics.

“While the skills training must contain a minimum of 30 academic hours, individuals must be certified based on their actual performance,” Lefeve said. “Therefore, while some students will no doubt be competent after 30 hours, many more will not be, and our schools will have to continue to train, as nearly all do now, until that student is competent and ready to take his or her CDL exam.”

Parker said he included the dissent letters in an appendix of his report to FMCSA. The agency declined comment on Parker’s report.

ATA said that a pair of guidance directives from the White House Office of Management and Budget concluded that, in the absence of empirical support for regulations that specify behavior or manner of compliance, the administration’s guidance is clear that performance standards must be adopted.

Committee member Peter Kurdock, director of regulatory affairs for the Advocates for Highway and Auto Safety, said that even students who complete the “hours” requirement will not pass the course if they can’t demonstrate mastery of the basic skills.

“We don’t really see it as hours-based versus performance-based,” Kurdock said. “We view what was adopted by the committee was performance-based with the hours as a floor, a minimum so you guarantee that

candidates are spending enough hours behind the wheel to learn the skills that we outlined in the curriculum.”

Another committee member, David Money, chairman of the Professional Truck Drivers Institute, said, “In my mind, there has to be some way of measuring the capabilities of the individual going through training.”

Money said a minimum number of driving instruction hours was a way of signaling to the public that the committee had safety in mind.