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OTHER ISSUES

Docket Submission To FMCSA On Younger Commercial Driver Pilot Training Program - May 18, 2001 (DOC)

Citizens For Reliable And Safe Highways
Submission to the Docket of the U.S. Department ofTransportation Federal Motor Carrier Safety Administration

Docket No. FMCSA 2000-8410 on

Younger Commercial Driver Pilot Training Program

Respectfully Submitted May 18, 2001
by Michael J. Scippa
Executive Director
CRASH/The CRASH Foundation
1628 Tiburon Blvd.
Tiburon, CA 94920

www.trucksafety.org

CRASH Submission to the Docket of the
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Docket No. FMCSA 2000-8410

I.Introduction

Citizens For Reliable And Safe Highways (CRASH) is pleased to submit these comments in response to the Federal Motor Carrier Safety Administration's (FMCSA) request for comments concerning a Younger Commercial Driver Pilot Training Program. In general we do not believe this proposed program will help the agency in its efforts to improve motor carrier safety and reach its goal of reducing actual truck crash fatalities by 50 percent by 2010.

Every year there are over 400,000 collisions involving heavy trucks. Every year over 5,000 people die in these crashes. Every year over 100,000 are injured, one-third of those life-altering injuries. Behind every death and serious injury is a family, a school, a business, a community, devastated by the loss.

Citizens For Reliable And Safe Highways (CRASH) is solely devoted to preventing deaths and injuries resulting from collisions with large trucks. CRASH was founded in 1990 as a national grassroots organization and now has thousands of supporters scattered throughout all 50 states. Tens of thousands of CRASH members have earned a reputation for making their voices heard in record numbers on issues of truck safety. We represent the millions of Americans who travel the nation's highways every day, including truck drivers, motorists, truck crash victims, and their families. Our goal is to make safety as important as productivity in all U.S. trucking operations.

CRASH is dedicated to reducing the number of fatalities and injuries caused by truck-related crashes by:

· pressing for corporate and government responsibility in transportation;

· raising public awareness of truck-related safety issues;

· reducing truck driver fatigue;

· improving truck maintenance standards;

· enforcing hazardous material regulations;

· assuring clear and consistent truck placarding;

· improving driver training and qualifications.

CRASH believes that the Truckload Carriers Association (TCA) proposed pilot project attempts to solve a complex industry personnel problem at the expense of public safety. The U.S. Congress, the U.S. Department of Transportation and the trucking industry must accept their shared responsibility to truck drivers and to the motoring public and make safety the top priority. Allowing younger, inexperienced drivers behind the wheel of 80,000 lb big rigs may temporarily solve a small part of the industry's problem of attracting new drivers. However, for a number of reasons this "quick fix" solution is destined to fail because ultimately it will be followed by additional crashes, fatalities, injuries and damage. As it is our goal to ensure that safety is the highest priority and never takes a back seat to economic efficiency and productivity, we are fundamentally opposed to the proposal.

II. Concerns with the Proposal

Pilot Programs
CRASH has a long history of opposition to pilot programs and regulatory exemptions in general. They make Swiss cheese out of uniform federal truck safety rules and regulations. They turn truck drivers and American motorists into guinea pigs on the road. The FMCSA should never consider any pilot project unless it demonstrates more stringent regulatory requirements rather than weakening safety rules. While on the surface this proposal appears safe because it is structured to be managed with an exceptionally high degree of safety controls, those very tight controls, and a relatively small sample size, will produce predictable results of little validity.

How the program might work in the real world however is anybody's best guess. But based upon the fact that the program seeks to expand the issuance of CDLs to the statistically highest risk group of young drivers (18-21), the group that is responsible for the greatest percentage of highway crashes, deaths and injuries, we believe the ultimate tragic results of allowing younger interstate truck drivers will be far removed from the tight results engineered by the pilot program.

TEA-21 and FMCSA regulations for pilot programs are quite clear. Safety factors of pilot proposals must not diminish existing regulations. But the fundamental premise of allowing truck drivers from the most at-risk pool of young drivers into this program, (and the small numbers of pilot participants 1,000) support the fact that this proposal does not even meet the government's standards for pilot programs and thus should not be implemented.

Facts The Proposal Ignores
The trucking industry has moaned for years about the chronic shortage of truck drivers. Talk to truck drivers (and we have talked to many) and they tell you why there is a shortage -- low wages, long irregular work hours, and deplorable working conditions. This is particularly true for the truckload carrier sector. Until these factors are remedied, truck driver recruiters will continue to come up short and who they do come up with will continue to either hurt themselves and/or others, or turnover and move on to less dangerous, better paying work like just about anything else.

Will the training under this proposal explain how drivers will be expected to work 25 to 40 hours a week unpaid, "OFF DUTY", on top of their 70 hours of driving -- "ON DUTY"?? Will training include how the new drivers will be expected to load and unload their trucks (unpaid, OFF DUTY)? Will training prepare the new drivers on how to break the hours of service laws and falsify log books to maintain exhausting unrealistic delivery schedules?

We think not, because in general this industry, since deregulation, has been on a negative spiral down to the bottom of the available, exploitable labor pool. This current proposal to seed the pool with younger drivers will only produce younger disillusioned workers, continued exploitation and increased risk of death and serious injury for all motorists.

What this proposal and the FMCSA fail to address is the serious problem of truck driver compensation. Unless drivers are offered a professional, "by the hour" wage, companies will continue to sweat their drivers' labor by "offering", and too often demanding, all the miles they could ever possibly safely drive. But without a professional wage, there will be no respect for their work, no self-respect for the driver, and a continuation of enormous driver turnover, and the lethal conditions caused by fatigued truck drivers.

As enlightened carriers have discovered, with a professional "by the hour" wage, professional caliber drivers are attracted and retained and are the safest, most responsible drivers on the road. And statistically, they are over the age of 25.

A Better Application Of This Training Program
The training standards proposed for this younger driver pilot project would be better considered as a good staring point for the long awaited and Congressionally mandated (1990) entry level training standards for all large truck drivers 21 an older. Still missing would be the federally mandated advanced training standards for those who drive LCVs.

III. Conclusion

In 1999, according to FARS data, an estimated 453,000 crashes involving large trucks killed 5,362 people and injured another 142,000. This means that every day of the year a large truck crash resulted in one fatality every 98 minutes and injuries every 4 minutes. An estimated 1,027,000 people were directly involved in these crashes and economic losses totaled over 25 billion dollars.

The TCA Younger Commercial Driver Pilot Training Program will not produce the solution the industry seeks. It will however waste precious tax payer dollars to keep the door open to more dangerous commercial trucking operating practices and prevent the FMCSA from realizing its goals to reduce actual truck crash fatalities 50 percent by 2010. The proposal deserves to be summarily dismissed.

CRASH believes the highest priority areas for FMCSA actions that will produce substantive and sustained progress include: completing important rulemaking on Hours of Service; working with the U.S. Dept. of Labor to achieve truck driver compensation reform; committing much greater resources to strengthening enforcement; and working more closely with NHTSA, to develop traffic safety programs that benefit all who share the highways, and insure improved safety standards and equipment for new large trucks are required at the same time for trucks already on the road.

We express our gratitude to the agency for being able to participate in this process to create safer commercial trucking and safer highways. We believe it is essential that the voices of victim advocacy groups like CRASH be included wherever and whenever commercial vehicle safety policies are examined, discussed, and formulated.

Because the heart of CRASH is composed of survivors and families who have themselves experienced the devastation of loss, we have the commitment and the credibility to help carry the struggle for enhanced commercial truck safety to a successful conclusion. The CRASH truck safety agenda is a direct reflection of our deepest concerns and desires. For further information on our programs of activism and compassionate support, the public may go to www.trucksafety.org.