Points of Fact Concerning the Proposed Entry-Level Driver Training Rule
There are a couple of points of fact that need disclosing concerning the proposed entry-level driver training rule.
1. This was the first negotiated rule-making (reg-neg) in the history of the FMCSA. The 26 entities asked to contribute input did so largely at their own expense. NASTC was one of those entities. There were no precedents or points of reference from which to draw guidance. A contracted facilitator and representatives from FMCSA guided us through the process and did an outstanding job, as did the participants.
2. The participants didn’t write the rule, FMCSA did using our input.
3. The participants recommended the training criteria and in that proposal was a certain amount of behind-thewheel training.
4. The Office of Management and Budget (OMB) determined that there was not enough cost/benefit data with the behind-the-wheel training recommendation and took this requirement out or changed it.
5. NASTC and ATA were the only participants who endorsed the proposal without the behind-the-wheel hours-based requirements.
A very important distinction should be clearly emphasized:
This rule proposal could only address PRE-CDL training. This proposal only requires training to obtain a CDL. Post CDL training, driver school training, apprenticeships or 2nd seat training were not a part of the discussion, nor could it be. During our discussions in the negotiated rule-making we addressed the pros and cons of classroom, behind the wheel off-road, and on-road training. NASTC and ATA advocated performance-oriented driving criteria for applicants, not some set number of hours behind the wheel. NASTC totally agrees with the OMB’s conclusion that hours of behind-the-wheel training in this rule-making is too expensive, will greatly restrict entry into the industry, and is inappropriate in PRE-CDL training requirements.
As an aside - In small, full-truckload, long haul trucking, our insurance providers will not allow our companies to hire drivers without a minimum of three years driving experience. The larger entities who are self-insured and who own and operate driving schools are overwhelmingly in charge of POST CDL TRAINING. If the requirements for getting a CDL were too stringent, all interested parties would be forced to pay the expenses and make the career commitment to driving pre-CDL. Many would be forced to go through large company, government supported, driving schools who predominantly feed large carriers.
Also, just so it’s clear – the driver still has to prove proficiency in the operation of the vehicle to obtain his CDL. His qualification is performance-based, as it is today.
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