The agency will be gathering “less detailed information on the training experience” with the survey than with a study ongoing at nine CDL training programs that takes a deep dive into CDL curricula and driver safety performance down the line.
That study is farther along, “more of a project where we have a small group of schools and drivers, but we’re getting a deep level of information from this group,” Smith said. The effort “identifies types of driver training and looks at information from the MCMIS system and the CDLIS system,” the former the primary information well from which the Compliance, Safety, Accountability Safety Measurement System draws to produce carrier CSA scores. As FMCSA will do with the ELDT survey, with the study the agency is attempting to correlate “driver safety performance with the amount and type of training received.” The agency expects to finish that component of the study this summer.
A second component is that “we’re having conversations with fleet managers and insurance companies about whether they have perspective on different types of training,” Smith said. “The third component of the project is going out and looking at several different states that have minimum standards for driver training curricula,” such as Illinois.
Smith shared news that the study is making a comparison between drivers from the state of Illinois and “drivers in neighboring Indiana, which does not have the same kind of standards,” he said.
Owner-Operator Independent Drivers Association Regulatory Affairs Director Scott Grenerth cautioned Smith on making the comparison with Indiana-based drivers, given the state’s known proclivity for writing moving violations, often without an attendant citation, on inspection reports.
Further, if the agency relies to a large extent on MCMIS and crash databases for its data on safety performance in these analyses, the final results would seem to be tainted by all of the problems of reliability that have dogged the CSA program itself – from the lack of crash fault accounting to the inclusion of violations that have no correlation to safety and the geographical disparity issue.
“I’ve always been pessimistic about the capability of data” to show the efficacy of entry level driver training, noted David Money of the Professional Truck Driver Institute training-curricula-certification organization. Smith’s presentation sparked ideas, however, for Money, given “we have data that’s already out there from components of what would be involved in our curriculum. How many crashes can be saved by doing training on fatigue management and hours of service?” for instance, he asked.
Smith said the national ELDT survey would also bring in drivers’ safety data from MCMIS and CDLIS, likewise any crash history. “Since this is a large-scale national study,” he said, “we have published a notice announcing the project. We got very good comments back, and now we’re preparing to put out a 30-day notice that will hopefully lead to Office of Management and Budget approval for the project.”
None of the results Smith detailed would be “available in time for us to finish our work,” noted committee facilitator Richard Parker. The ELDTAC committee is working on a timetable that has it concluding its work on a “term sheet” identifying key components of a proposed rulemaking on pre-CDL driver training standards that FMCSA hopes to write before year’s end. Find the full committee’s schedule here. Various ELDTAC subcommittee conference calls, in addition to the main meetings, will be announced via the committee’s official website.