1.1 Project Description
As a result of a fatal truck-bus accident in May 2001, the National Transportation Safety Board (NTSB) issued several recommendations to the U.S. Department of Transportation's (DOT's) Federal Motor Carrier Safety Administration (FMCSA) based on their findings that the probable cause of the accident was the truck driver's inability to stop the tractor semitrailer due to the reduced braking efficiency of the truck's brakes, which had been poorly maintained and inadequately inspected.
Two of the NTSB's recommendations to FMCSA concerned brake maintenance and inspection. They are:
Safety Recommendation H-02-15: Revise 49 Code of Federal Regulations 396.13, Driver Inspection, to require minimum pre-trip inspection procedures for determining brake adjustment.
Safety Recommendation H-02-18: Revise 49 Code of Federal Regulations 396.25, Qualifications of Brake Inspectors, to require certification after testing as a prerequisite for qualification and specify, at a minimum, formal training in brake maintenance and inspection.
This project, Assessment of Potential Benefits and Costs of Revising Brake Inspection Procedures and Certifying Brake Technicians, was designed to address NTSB's concerns and to assist FMCSA in:
- Estimating the potential benefits and costs of implementing the NTSB's recommendation to establish Federal testing and certification requirements for persons who maintain or repair commercial motor vehicle (CMV) brakes.
- Estimating the time and level of training required for CMV drivers to conduct pre-trip inspections of sufficient depth to discover defects or deficiencies that were not corrected by a certified brake technician.
1.2 Project Methodology
Battelle assembled and led a project team that included the American Transportation Research Institute (ATRI), the Commercial Vehicle Safety Alliance (CVSA), and the Technology and Maintenance Council (TMC) of the American Trucking Associations. The work performed for the study involved conducting a literature review, collecting data, and interviewing and collecting information and data from stakeholders. All information obtained was examined and fed into safety and economic models to determine the benefits and costs that could be expected from implementation of the NTSB recommendations.
1.2.1 Literature Search and Data Gathering
The literature search for this project focused on gathering data and sources related to brake condition, maintenance, training and certification of technicians and inspection of brake systems by both technicians and drivers as contributing factors related to CMV brake problems including crashes and out-of-service (OOS) conditions. The literature search was also designed to review books, documents, and data on the need for brake training for drivers and technicians, specific training programs, and techniques for economic analysis.
1.2.2 Stakeholder Interviews-Brake Condition and Maintenance as Crash Factors
In an attempt to corroborate and/or gather information not available in the literature quantifying the extent to which brake condition and maintenance could be related to CMV crashes, survey/interview questions were developed. It was expected that individuals responsible for preventing losses, reducing or assessing the risks of motor carriers, or involved in determining the cause of crashes might be in possession of such unpublished information, and willing to share it with the project research team. A list of questions was e-mailed in advance to a previously developed list of potential respondents, and the subsequent surveys were administered by phone or by return of the e-mail questionnaire. Follow-up phone calls were required in some cases to clarify any ambiguities. In addition, the TMC was able to compile data from its membership to augment the external surveys. The results of the surveys were compiled and fed into the benefits analysis portion of this study.
1.2.3 Stakeholder Interviews-Training, Testing, and Certification Programs
A similar activity sought to corroborate and/or gather additional information on current training, testing, and certification programs as well as the recommended structure for future training, should the NTSB recommendations be implemented. The targeted groups for this effort were motor carriers, training schools, certification entities, association member companies, and insurance companies. As with the first round of stakeholder interviews, these interviews were conducted with the help of e-mailed questions to the respondents that facilitated their responses. The collected information was augmented with data obtained internally from the project team members that represented large groups of stakeholders.
1.2.4 Safety Analyses
The data and information obtained in the earlier stages of the project were used to develop the safety and economic models needed to determine the potential benefit-cost ratio (BCR) for implementing the NTSB recommendations. The primary benefits are the safety impacts of crash prevention, avoidance of high crash costs, and avoidance of costs resulting from OOS brake violations due to the improved manner in which brakes are tested and maintained on commercial motor vehicles. The primary costs include the costs of driver and brake technician training, per trip driver inspection costs, and the costs associated with brake inspector testing and certification.