ATA Critical of Panel's Recommendation of Hours-Based Over Performance-Based Instruction for New Drivers
An entry-level driver training federal advisory committee’s recommendation that new drivers receive hours-based rather than performance-based behind-the-wheel instruction lacks a scientific basis and runs contrary to a pair of executive orders, according to a “dissent letter” forwarded to the committee’s facilitator by American Trucking Associations.
The letter, written by Boyd Stephenson, ATA’s vice president of international supply chain operations, was in response to the committee’s consensus recommendation that entry-level drivers receive 30 hours of behind-the-wheel training with at least 10 hours required to be performed on the range and another 10 on the road.
The Federal Motor Carrier Safety Administration’s 26-member, broad-based stakeholder advisory panel conducted six two-day meeting sessions drafting the framework for a “negotiated” proposed rule for new driver pre-commercial driver license training. The committee completed its work May 29 after gaining a consensus on issues ranging from classroom and behind-the-wheel curriculum to the certification and oversight of training schools and instructors.
Although they voted in support of the package of recommendations, ATA and the National Association of Small Trucking Companies dissented in a separate vote on the hours-based behind-the-wheel instruction. Each sent letters (below) giving their rationale for voting against the hours requirement for behind-the-wheel training.
In its June 5 letter to committee facilitator Richard Parker, ATA said there have been numerous reports, studies and literature reviews seeking to establish that a certain amount of hours-based training reduces future crash risk, but that connection has yet to be made.
“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 letter said. “Without an empirical underpinning, the committee’s recommendation of a particular hours-based requirement is purely arbitrary.”
StephensonATA also said that a pair of White House Office of Management and Budget directives concluded that “performance standards express requirements in terms of outcomes rather than specifying the means to those ends.”
“OMB considers performance standards to be ‘generally superior’ to design standards and directs agencies that in weighing performance standards versus design standards, ‘[the agency] should take into account both the cost savings to the regulated parties of the greater flexibility and the costs of assuring compliance through monitoring or some other means,’ ” Stephenson wrote.
ATA said 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.
In a separate dissent letter, NASTC said that with performance criteria, entry-level commercial drivers likely would be better prepared for the driver license test, for the job, and for the road.
“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.”
Some student drivers will master a skill or maneuver faster than others, and individuals will vary by which skill may come faster or slower, or how quickly or slowly one masters all the required driving maneuvers, NASTC said.
