Training for Entry Level Drivers of Commercial Motor Vehicles (CMVs)

October 14, 2003 U.S. Department of Transportation Federal Motor Carrier Safety Administration 400 Seventh Street, SW Nassif Building Room PL-401 Washington, DC 20590-0001 Re:Docket No. FMCSA-97-2199: Minimum Training Requirements for Entry-Level Commercial Motor Vehicle Operators Dear Docket Clerk: The Truckload Carriers Association (TCA) submits the following comments to the Federal Motor Carrier Safety Administration (FMCSA) in response to the Notice of Proposed Rulemaking (NPRM) published in the August 15, 2003 Federal Register at 68 Fed Reg. 48863. TCA is the national trade association representing the truckload segment of the trucking industry. Truckload carriers account for approximately 97 percent of the for-hire freight tonnage annually transported by motor carriers. Matters relating to and affecting training requirements for those drivers who operate commercial motor vehicles are especially important to our members, since a substantial number of truckload carriers hire entry-level drivers. In fact, the truckload segment of the trucking industry is the predominant, if not exclusive, segment of the industry that hires entry-level drivers. Moreover, TCA is a strong supporter of the Professional Truck Driver Institute (PTDI) and the training standards that it has established for entry-level drivers. TCA therefore appreciates the opportunity to submit our thoughts and concerns regarding FMCSA's proposed training rule for entry-level drivers. SUMMARY OF POSITIONS ·The truckload segment of the trucking industry is the predominant, if not exclusive, segment of the industry that hires entry-level drivers. ·PTDI provides the most reliable and practical way to facilitate FMCSA's goal of ensuring that entry-level drivers have been adequately trained prior to entering the trucking industry. ·FMCSA should therefore do as much as possible to encourage driver training schools to participate in PTDI's program. ·TCA does not believe that training on the four proposed subject matters needs to be mandated by FMCSA. ·TCA's opposition notwithstanding, in the event that FMCSA elects to require carriers to provide some or all of the training being proposed, carriers should only have to train drivers newly entering the industry. ·TCA's opposition notwithstanding, in the event that FMCSA elects to require carriers to provide some or all of the training being proposed, carriers should have more than ninety (90) days within which to train drivers. TCA'S COMMENTS A.PTDI provides the most reliable and practical way to facilitate FMCSA's goal of ensuring that entry-level drivers have been adequately trained prior to entering the trucking industry. FMCSA should therefore do as much as possible to encourage driver training schools to participate in PTDI's program. As the administrator for the Professional Truck Driver Institute (PTDI) program (see Footnote 1 -- bottom of page), TCA was extremely pleased and gratified by FMCSA's endorsement of PTDI. As FMCSA is aware, PTDI was established through the thoughtful and cooperative efforts of a coalition of representatives from the trucking, driver training, and insurance industries. Their purpose for establishing PTDI was essentially two-fold: (1) to develop a voluntary uniform standard that driver training schools throughout the United States and Canada could use as their baseline for ensuring that entry-level CMV drivers have, at a minimum, been adequately trained prior to entering the trucking industry; (2) to develop a certification program and process that would objectively verify and recognize driver training school courses that are able to demonstrate that their course meets or exceeds PTDI's standards. In combination, the PTDI curriculum and course certification provides a substantive structure and process to ensure that graduating drivers will receive the level of training adequacy to which FMCSA strives (see footnote 2 -- bottom o…