4. STAKEHOLDER INTERVIEWS—TRAINING, TESTING, AND CERTIFICATION PROGRAMS

4.1 Approach

The next phase of the project involved conducting interviews with up to nine entities concerning (a) training and certification for drivers, brake inspectors, and technicians and (b) the management of the process, along with safety and economic analysis. The intent of these interviews was to gather data unavailable from the literature search or database analysis and to gather information that was available from a sampling of fleets, schools, certification entities, association member companies, and insurance companies.

Nine interviews were conducted, involving commercial motor carriers (both truck and bus), a technician training school, a testing and certification organization, and insurance industry representation. This document summarizes the interviews and the information gathered.

Potential interviewees included individuals known to the project team. Motor carrier and insurance contacts were provided by CVSA as well as through prior personal knowledge. The final list of interviewees was reviewed and approved by FMCSA. Several potential interviewees indicated they were unable to respond, but referred the project team to other individuals. Survey questions were tailored to three groups of such individuals, consisting of (1) trucking or bus motor carrier safety representatives, (2) insurance industry representatives, and (3) driver/technician schools and testing/certification organizations. Further, during the course of the data collection, it became apparent that some of the initially proposed sources were unable to provide adequate answers to the questions. Substitute sources were approached in these cases.

The specific information sought from the respondents was forwarded to them in advance of the interview to allow the respondent time to gather the data. For some respondents, scheduling conflicts made it difficult to coordinate phone interviews within the desired period and they provided written responses. The project team then followed up with these individuals to clarify their responses or to obtain additional information.

Ultimately, nine interviews were conducted, involving a range of commercial motor carriers (both truck and bus), insurance industry representatives, a school for brake technicians, and a testing and certification organization. General information on the respondents is summarized in Table 4-1.

Several of the respondents represented constituencies of many organizations and they were able to provide data for a cross-section of their membership, thereby increasing the effective number of entities for which data were obtained. Overall, the motor carriers represented included a wide range of operations, including tanker/hazardous materials, refrigerated, specialized, retail, and private. Both truckload (TL) and less-than-truckload (LTL) carriers were represented.

To better understand the relevance of the data obtained from the respondents, a brief summary of the characteristics of the carriers represented in the collected data is presented.

Brake inspectors have an average of 12.8 years of experience, according to the carriers. The insurance representative provided an estimate of 10 years of experience. Carriers reported that an average of 58 percent of their brake inspectors have completed a formal training program rather than on-the-job training or an apprentice program (with estimates ranging from 20 to 100 percent). The insurance representative put that figure at only 20 percent.

Carrier respondents varied among the number of power units they operated. Some had fewer than 20, while others had more than 5,000; the median number of power units was 200. Of these, carriers estimated that 9.1 percent were older than October 20, 1994, when automatic brake adjusters and push stroke indicators were required on certain air brake systems. The absence of the devices may make it more difficult for certain brake inspections to be conducted by a driver. The insurance representative placed the average motor carrier size that they insure at 85 power units, with only 3 percent older than October 20, 1994.

Trailer fleets ranged from 30 to 14,000, with a median of 396. Of these, carriers estimated that 22.2 percent of them were older than October 20, 1994, when automatic brake adjusters and brake adjustment indicators were required to be installed on certain air brake systems. As for power units, the absence of the devices may make it more difficult for certain brake inspections conducted by a driver. The insurance representative estimated his firm's average insured fleet to include about 312 trailers, with about 9 percent older than October 20, 1994.

Vehicle OOS rates for brake-related conditions were reported to be approximately 3.4 percent. This excludes one carrier that reported a rate of 39 percent but whose rate in FMCSA's SafeStat system is approximately 11 percent. The insurance representative estimated the brake-related OOS rate to be 2.3 percent. These figures were considerably lower than the Operation Air Brake data presented in Section 2.2, indicating that the respondents may have better-than-average brake inspection, repair, and maintenance programs.

Carrier annual maintenance expenditures averaged around $10,200 per power unit (ranging from $3,500 to $22,000) and $2,250 per trailer (ranging from $600 to $5,000). The total annual maintenance expenditures that were considered preventive (e.g., inspections, replacement of parts before failure) was estimated to be about 55 percent (ranging from 13 to 85 percent). The proportion of total maintenance expenditures that were brake-related was not available. The insurance representative's estimate for preventive maintenance is 18 percent (and he would not disclose annual maintenance expenditures).

4.2 Stakeholder Input Regarding the Impact, Cost and Implementation Feasibility of the NTSB Recommendations

The data gathered from the interviews related to training, testing, and certification programs are presented in three subsections: (a) driver inspection, (b) training and certification of brake inspectors, and (c) safety and economic analysis. Each addresses the responses from motor carrier, insurance, and school representatives.

4.2.1 Driver Inspection

Impact of inspection on operations

It is important to understand how stakeholders viewed the feasibility of drivers performing functional pre-trip brake inspections, and whether these inspections could be performed with the driver alone or whether a second individual was necessary. Respondents were asked to consider that a brake inspection with two people would add one minute per axle to a pre-trip inspection and that a driver conducting the inspection alone would require two additional minutes per axle for a pre-trip inspection. They were also asked to consider that one-person inspections would require the driver to use a device to apply the service brakes or to measure the free stroke. Respondents were not provided any additional details on what these inspections would entail and were provided per-axle time estimates to allow them to determine the impacts on their fleets based on the vehicle configurations that they operate. The per-axle time estimates were based on the NTSB recommendation, which focused on determining brake adjustment during pre-trip inspections. A more complete inspection might consider, in addition to brake adjustment, checking for other deficiencies, including air leaks, cracks in the linings, contaminated linings, chafed hoses, incorrect connections or splices, and holes in the chambers resulting from corrosion or other damage. Outside the cab, the driver could check the tractor protection valve. Then in the cab, he or she could check the air loss rate and low-pressure warning device.

While some carrier respondents indicated that there would not be appreciable impacts on their operations if two-person inspections were required (and actually believed that safety would be improved), most reported significant negative impacts on their operations. Among motor carriers, 24.5 percent indicated that two-person inspections would have little or no negative impact or a net positive impact on their operations. Some common themes included:

• Operational feasibility
  • Team drivers - in some cases, this would require the driver to come out of the sleeper, with significant implications due to hours of service rules.
  • Availability of second person - for many carriers, additional staff are not available during all operational periods (such as late night) when pre-trip inspections are conducted. This would require hiring additional staff just to serve this inspection function. Additional staff may not be available in remote locations.
• Cost
  • One company with 1,500 3-axle vehicles indicated it would add 16,500 hours per year (based on 220 days of operation per year).
  • Another company estimated the additional effort would require two technicians for two hours each day, seven days a week (1,456 hours per year).
  • Companies that reported total annual costs cited estimates of
    • $152,000 (10 minutes per driver per day × 45 drivers × 5 days per week × 52 weeks per year × 2 drivers per inspection ≈ 4000 hours × $38 per hour),
    • $175,200 (800 buses × 3-axles × 1 minute per axle × $12 per hour = $480 per day × 365 days per year),
    • $750,000,
    • $3.72 million (10 minutes per driver per day × 1,431 drivers × $60 per hour × 5 days per week × 52 weeks per year), and
    • $13 million (based on a minimum cost of at least $50,000 per day).
  • Another indicated annual costs of $3,250 per driver, but did not indicate the number of drivers.

Most carrier respondents seemed much more comfortable with the idea of drivers performing the inspections alone; however, the added cost and reduction in available driving hours was still an issue for many. Several carrier respondents still thought that a two-person inspection would provide better results and that the approach was preferred. Overall, about one-third of motor carriers indicated that one-person inspections would have little or no negative impact or a net positive impact on their operations. Representative issues included:

• Reductions in driving time due to the inspection and necessary clean-up (as the drivers would get very dirty doing the inspections) would limit available driving hours
  
  • One motor carrier indicated that their drivers might not be able to unload and get home at the end of their day; another stated that it would increase the likelihood that a driver could not reload or take on a second load.
  • For motor carriers that quantified the total additional time required per day, the estimates of reduced available driving time were 14, 15, 20, 25, and 30 minutes in a 14-hour period.
• Operational feasibility
  • Several respondents indicated that they were concerned about having their drivers getting dirty from crawling under a truck, particularly in adverse weather conditions such as rain or snow. While not specifically identified by any respondents, this would also apply to motor coach operators whose drivers typically wear a coat and tie. This would require additional time to change clothes or the use of a protective coverall.
• Cost
  • One company with 1,500 3-axle vehicles estimated the effort to require 33,000 hours per year, but believes the time required to be closer to 5-minutes per axle rather than 2-minutes per axle; resulting in an annual increase of 82,500 hours.
  • One motor carrier with 150 mostly 8- or 9-axle semi trailer trucks with 2 to 3 trailers estimated annual costs exceeding $300,000. Others that quoted specific costs estimated total annual increased expenditures of
    
    • $11,400 (15 minutes per driver per day × 45 drivers × 5 days per week × 52 weeks per year × 1 driver per inspection ≈ 3000 hours × $38 per hour),
    • $1.5 million, and
    • $13 million (based on a minimum cost of at least $50,000 per day).
  • Another estimated annual costs of $6,500 per driver.

There were also some recurrent themes that apply to the overall idea of drivers examining brakes as part of their pre-trip inspections.

• Some felt that drivers were only qualified to do visual inspections and that only certified brake technicians were appropriate for physical inspections.^4-1 They stated that drivers should not be “overriding” certified technicians.^4-2 One respondent indicated that current union rules preclude drivers from performing these types of inspections.
• There was also a concern from an insurance representative that drivers, even if required to crawl under the vehicle to physically inspect brakes, would not actually do it every time, particularly during inclement weather. Driver safety concerns included the provision of protective eyewear and headgear and additional clothing for those crawling under vehicles. Increased driver injuries could be expected from this activity.
• Others felt that these inspections would increase the drivers' familiarity with brake systems, thereby improving safety. One indicated that having two-person inspections would increase safety because “two people will see more and be more aware.” One person indicated that brakes could not be inspected enough and that the overall impact would be positive on his company's operations.
• A couple of carrier respondents indicated that they believed the time estimates for added inspection per axle were too low. One, mentioned above, indicated that 5 minutes for a one-person inspection was needed and the other indicated that a two-person inspection would take more than one minute per axle, as it is difficult to get to the brake chamber on their 7-axle trailers.

Training content

Some individuals contacted expressed specific ideas on what the training should include, subject to their beliefs on exactly what the driver should be required to do during a pre-trip inspection; they were not provided a list of specific inspection activities to be required.

For those that felt the driver should not be required to crawl under the vehicle, one suggestion was to have the driver view the angle of the pushrod, the thickness of the pads, and the gap between the pads and drum; however, this would apply only to certain types of brake systems.

Driver training optimums

Respondents were asked about the appropriate amount of initial and refresher training and the frequency for refresher training for drivers. This training would include conducting pre-trip inspections and being able to identify brake deficiencies that were not correctly repaired by a technician. Table 4-2 provides a summary of the carrier responses.^4-3

The insurance representative indicated that 1/2 day was appropriate for both initial and refresher training and that refresher training should be conducted biennially. The testing organization felt that more time is needed for initial training—2 days—and that refresher training should be 1/2 day and offered every 3 to 5 years.

Anecdotally, one individual from a motor carrier mentioned that today's drivers are generally not mechanically inclined and extensive training would be necessary to impart the appropriate knowledge. This individual was not able to recommend a specific amount of training, however.

Data were also collected from carriers on the recommended class size for driver pre-trip inspection training, as shown in Table 4-3.

One carrier indicated that classroom training can accommodate up to 20 students; whereas, hands-on instruction should be limited to only four or five students. The insurance representative would recommend training in groups of up to four drivers per instructor. The school indicated that training, in general, should be able to accommodate each individual's requirements and learning style.

When carriers were asked about the effort required to convert their current class size and format to the optimum (as they saw it), only 6 percent indicated that they were already using the optimum configuration. Forty-eight percent would require a little effort and 45 percent would require a considerable effort.

Based on carrier responses, drivers learn best when there is a combination of hands-on training used in conjunction with classroom instruction. Some indicated that a video could suffice for classroom instruction, provided the drivers still had an opportunity for hands-on experience. The insurance representative felt that formal one-on-one instruction followed by hands-on experience was the preferred approach among the motor carriers he insured.

Most carriers would develop additional required training for drivers in-house (79 percent). The insurance representative also indicated that in-house development was likely among his carriers. The average annual salary of driver trainers was reported to be $40,000 to $60,000 for salaried drivers and $10 to $20 per hour for drivers paid hourly.

Driver training recordkeeping is done in-house (98 percent) and slightly more than half done in-house is done manually (56 percent). Of the recordkeeping done electronically, listed systems included standard spreadsheet and database programs and custom systems. The one carrier that indicated their recordkeeping was handled by a third party cited monthly costs of $495 to cover eight drivers.

4.2.2 Training and Certification of Brake Inspectors

As highlighted by the testing and certification organization, "the scope of the technical [training] content is quite different for an individual performing brake inspections from that of the technician who must also have the requisite knowledge and skill to diagnose and repair deficiencies identified in the inspection process."

For those carriers who have technicians as employees (some do not), an average of 73 percent of the technicians were brake inspectors per 49 CFR 396.25(b). In 75 percent of motor carriers, drivers were not brake inspectors, but at least some drivers were brake inspectors in 25 percent of the motor carriers from which data were obtained. The insurance representative indicated that, for the motor carrier they insure, approximately 90 percent of the technicians are brake inspectors.

Not a single carrier would alter the number of technicians from current levels if certification of brake inspectors were required.

Respondents were asked about the appropriate amount of initial and refresher training and the frequency for refresher training for brake inspectors. This training would include conducting proper inspection, maintenance, service, and repair of CMV brake systems as well as appropriate testing and certification as recommended by the NTSB. Table 4-4 provides a summary of the carrier responses.^4-4

Carriers that recommended a longer initial training class also recommended longer periods between refresher training. The insurance representative indicated that two days was appropriate for initial training of brake inspectors and that refresher training should be offered biennially as a one-day class. The testing organization representative felt that 4 days was appropriate for initial training and that 1/2-day refresher training should be offered biennially. The school felt that more than one week was necessary for initial training and that a full day of refresher training should be completed annually.

Data were also collected from carriers on the recommended class size for brake inspector training, as shown in Table 4-5.

The insurance representative indicated that on-the-job training is the best approach for training brake inspectors. A school indicated that more than 20 technicians/inspectors per instructor was the optimal learning arrangement. Most of the carrier respondents indicated that hands-on training was the most effective, with some mentioning the added benefit of video or classroom training in addition to the hand-on learning. The school stated that it was best to evenly split the time between classroom and hands-on training.

Employee training recordkeeping for brake inspectors was done primarily manually in-house (88 percent), with the remaining done electronically in-house (using either custom software or integrated commercial business applications, including those from PeopleSoft and TMW Systems Inc.). This is consistent with the response from the insurance representative indicating manual in-house recordkeeping.

Training challenges

According to the respondents, the challenges that carriers face with delivering effective training for brake inspectors include:

• Not all employees are fluent in English.
• Many brake inspectors have never familiarized themselves with the FMCSRs and the requirements in 49 CFR 393 and 396 and Appendix G to Subchapter B, Minimum Periodic Inspection Standards.
• Employee turnover.
• Fitting training into the normal work schedule, while maintaining the ability to continue operations.
• Providing defects to diagnose (i.e., components with defects for use in hands-on training).
• Wide variety of system designs.

Accreditation

Only one quarter of carriers contacted for this study indicated that they have developed a structured periodic brake inspection accreditation program for their company technicians, usually conducted annually (one respondent repeated the accreditation every three years). However, only one of these extended the program to their third-party vendors.

Just over one third of carriers contacted for this study indicated that they have developed a structured periodic brake inspection training program for their company technicians, usually conducted annually (one respondent repeated the training every two years). Two of these carriers extended their programs to their third-party vendors.

The testing and certifying organization provided some general comments that are illustrative of the key issues in the area of accreditation:

• Independent, third-party certification is an objective method of validating training, provided the assessment is defined, developed, and specified by persons knowledgeable in the subject area. This is one of the key tenets, and perhaps the greatest value of Automotive Service Excellence (ASE) certification; the test specifications, task lists, and questions are all developed by technicians and other subject matter experts with experience gained working in the field on a daily basis. These subject matter experts also establish the passing score for a given certification area. Certification by an independent, third-party entity is a recognized and accepted means of validating knowledge gained through training.
• The NATEF evaluates secondary and post-secondary medium/heavy (M/H) truck technician training programs against standards developed by the automotive industry and recommends qualifying programs for certification (accreditation) by ASE. The current Instructional Standards for M/H Truck Brake Systems include 105 hours of instruction broken down into 66 tasks that incorporate the brake inspection requirements in Appendix G to Subchapter B of the FMCSRs. Substantially meeting these instructional tasks is mandatory to achieve certification (accreditation). Additionally, an optional certification area in the NATEF standards for M/H Truck programs is Preventive Maintenance, requiring another 105 hours of instruction, including brake inspection tasks that, again, substantially meet the requirements of Appendix G to Subchapter B of the FMCSRs.
• The NATEF process has resulted in certified automotive training programs in all fifty States at the secondary and post-secondary levels. NATEF also evaluates the providers of in-service technician training programs under a program called Continuing Automotive Service Education (CASE).
• The ASE offers eight certification specialties within the M/H Truck series. Two of those certifications (T4-Brakes and T8-Preventive Maintenance Inspection) seem to fulfill or exceed the brake inspection requirements outlined in Appendix G to Subchapter B of the FMCSRs. The cost of this certification is $57, including a $32 registration fee and $25 testing fee.

4.2.3 Safety and Economic Impacts on Brake-related Crashes

Almost all carriers estimated that brake system malfunction or failure was a factor in none of their DOT-reportable CMV crashes. The only carrier reporting a non-zero figure indicated that it was less than 5 percent. However, the insurance representative also reported that the motor carriers that they insure averaged around 5 percent brake-related DOT-reportable crashes, with an average of about 10 DOT-reportable crashes per year per motor carrier. A bus motor carrier indicated that they experience about five DOT-reportable crashes per year (and operate 700 buses). The median number of DOT-reportable crashes among all motor carriers that reported a value was 15, although one motor carrier reported 131 (1,550 power units) and two motor carriers reported 239 and 250, respectively (and 8,586 and 8,000 power units, respectively). The latter motor carrier, reporting 250 crashes, was the only motor carrier that indicated a non-zero brake-related crash percentage, as stated above. The testing and certification organization, however, estimated that 10 percent of all DOT reportable crashes involve brake system malfunction or failure.

The turnover rate for brake inspectors is generally fairly low, with 64.3 percent of carriers indicating rates less than 2 percent, 14.3 percent were less than 10 percent, and the remaining 21.4 percent were in the 20 to 25 percent range. Interestingly, the insurance representative estimated the turnover rate for brake inspectors to be 30 percent. In this analysis, the brake technician turnover rate is assumed to be 15 percent.

Interviewees were asked their opinions about the safety impact of implementing the NTSB recommendations—having drivers conduct pre-trip brake inspections and certifying brake inspectors—and 56 percent indicated that there would be no positive impact, 6 percent were unsure, and 38 percent predicted a decrease in crashes. The estimates of decreased crashes ranged from less than one percent all the way up to a 100 percent decrease. The average estimated decrease from these respondents was 28 percent. The insurance representative indicated a 0.5 percent decrease in all crashes as a result of implementing the recommended rule changes.

Most felt that such a program would be beneficial, even if they did not estimate a decrease in crashes. They cited better-educated drivers and brake technicians, improved awareness of proper maintenance procedures, and lower brake repair costs. Some indicated that they were already implementing some form of the recommendations, but that other companies could benefit. The testing organization felt that while having drivers conduct pre-trip inspections would produce a benefit in terms of reduced crashes, it would be significantly more beneficial to have certified brake technicians and inspectors perform that function. They believe that “the differences in existing brake systems used on medium/heavy commercial vehicles and the technical knowledge and familiarization of these systems extends beyond the reasonable expectation for drivers.” They also feel that new technology in brake systems will likely increase the amount of information necessary to perform proper brake inspections.