Final Report

Federal Motor Carrier Safety Administration
U.S. Department of Transportation

September 2006

Technical Report Documentation Page

Form DOT F 1700.7

Table of Contents

• LIST OF ABBREVIATIONS AND ACRONYMS
• EXECUTIVE SUMMARY

• 1. INTRODUCTION
  • 1.1 Project Description
  • 1.2 Project Methodology
    • 1.2.1 Literature Search and Data Gathering
    • 1.2.2 Stakeholder Interviews-Brake Condition and Maintenance as Crash Factors
    • 1.2.3 Stakeholder Interviews-Training, Testing, and Certification Programs
    • 1.2.4 Safety Analyses

• 2. LITERATURE SEARCH AND DATA GATHERING
  • 2.1 Overview
  • 2.2 Estimating Prevention and Mitigation of Crashes and OOS Violations
  • 2.3 Need for Better Driver/Brake Technician Training and Inspection
  • 2.4 Training and Certification Programs
  • 2.5 Economic Analysis

• 3. STAKEHOLDER INTERVIEWS-BRAKE CONDITION AND MAINTENANCE AS CRASH FACTORS
  • 3.1 Approach
  • 3.2 Stakeholder Input Regarding Brake-related CMV Crashes
    • 3.2.1 Brake-related Crashes
    • 3.2.2 Preventable Brake-related Crashes
    • 3.2.3 Additional Comments from Motor Carriers
    • 3.2.4 Values to be Used in Economic Analysis

• 4. STAKEHOLDER INTERVIEWS-TRAINING, TESTING, AND CERTIFICATION PROGRAMS
  • 4.1 Approach
  • 4.2 Stakeholder Input Regarding the Impact, Cost and Implementation Feasibility of the NTSB Recommendations
    • 4.2.1 Driver Inspection
    • 4.2.2 Training and Certification of Brake Inspectors
    • 4.2.3 Safety and Economic Impacts on Brake-related Crashes

• 5. SAFETY ANALYSES
  • 5.1 Background Crash Data for Benefits Assessment
  • 5.2 Benefits Assessment
    • 5.2.1 Safety Impacts
    • 5.2.2 Out-of-Service (OOS) Violation Impacts
    • 5.2.3 Impacts on Citations involving Monetary Penalties
  • 5.3 Costs Assessment
    • 5.3.1 Training, Testing, and Certification Costs
    • 5.3.2 Inspection Costs
  • 5.4 Benefit-cost Analysis

APPENDIX A. REFERENCES

APPENDIX B. ADDITIONAL ANNOTATED REFERENCES

List of Tables
Table ES-1. Benefit-cost Analysis Findings (Alternative Scenarios)
Table 3-1. Respondent Profile
Table 3-2. Estimates of the Percentage of Brake-related Crashes
Table 3-3. Estimates of the Percentage of Preventable Brake-related Crashes
Table 4-1. Respondent Profile
Table 4-2. Responses on Driver Training Class Time for Brake Inspection
Table 4-3. Responses on Driver Training Class Structure
Table 4-4. Responses on Brake Inspector Training Class Time
Table 4-5. Responses on Brake Inspector Training Class Structure
Table 5-1. Distribution of Crashes among Brake Problem Categories in the LTCCS
Table 5-2. Examination of Brake Safety
Table 5-3. Benefits Associated with Avoided Crash Costs
Table 5-4. Non-crash Vehicle Inspections and Number of OOS Brake Violations
Table 5-5. Training Cost Assumptions
Table 5-6. Driver and Technician Training Courses and Associated Fees
Table 5-7. Number of Axles on Single-unit and Combination Trucks
Table 5-8. VIUS Percentage of Trucks Based on Range of Operation
Table 5-9. Percentage of Trucks Based on Range of Operation
Table 5-10. Benefit-cost Analysis Findings (Average Trips by CMV Assumed to be 200 miles)
Table 5-11. Benefit-cost Analysis Findings (Average Trips by CMV Assumed to be 400 miles)
Table 5-12. Benefit-cost Analysis Findings (Alternative Scenarios)

List of Figures
Figure 5-1. Data Elements Combined to Determine Societal Benefit-cost Ratios

EXECUTIVE SUMMARY

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. The recommendations were to require (1) minimum pre-trip inspection procedures for determining brake adjustment and (2) certification after testing as a prerequisite for qualification and specify, at a minimum, formal training in brake maintenance and inspection.

This project was designed to address NTSB's concerns and to assist the FMCSA in:

1. Estimating the time and level of training required for commercial motor vehicle (CMV) drivers to conduct pre-trip inspections of sufficient depth to discover defects or deficiencies that were not corrected by a certified brake technician.
2. Estimating the potential benefits and costs of implementing the NTSB's recommendation to establish Federal testing and certification requirements for persons who inspect CMV brakes.

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 potential benefits and costs that could be expected from implementation of the NTSB recommendations.

The benefits associated with the NTSB recommendations are those related to safety as measured by the prevention of crashes involving CMVs, the avoidance of the monetary costs for these CMV crashes, the reduced number of out-of-service (OOS) brake violations, and reduced levels of fines associated with violations resulting from brakes being out of adjustment (OOA).

The NTSB recommendations would generate training costs, inspection costs, testing and certification costs, and administrative costs associated with recordkeeping and retention. Training would be required of bus and truck drivers responsible for performing pre-trip inspections. Brake inspectors would train in preparation for the testing and certification process called for in the NTSB recommendations. Training costs would include the costs associated with preparing training materials, compensating trainers, and labor replacement costs. The driver training and brake inspector certification requirements would also result in costs associated with registration and testing fees. Finally, pre-trip inspections would take drivers away from revenue-generating activities and thus would result in additional labor costs. In each case, these costs would be borne by the motor carrier industry.

The most significant costs are those incurred during pre-trip inspections, which total roughly $4.9 to $9.9 billion over the 10-year time horizon (2005 to 2014). Though each inspection would require only 2 minutes per axle, the costs of this requirement are significant because they would require billions of inspections to be performed over the next 10 years. The cost range is due to varying the assumption regarding the average distance per trip between 200 and 400 miles. Costs are higher if shorter trips are assumed because that would indicate a higher number of inspections. Training, testing, and certification collectively represent the next highest cost item, totaling $5.4 billion over the 10-year analysis timeframe. Administrative costs are relatively low, estimated at $316.7 million over 10 years. The costs associated with NTSB Recommendation 1 include driver training, pre-trip inspection costs and administrative/record-keeping costs, and were estimated at $10.1 - $15.1 billion over the 10-year analysis time horizon. NTSB Recommendation 2 costs include those tied to brake technician training, testing, certification, and related administrative/record-keeping costs. Over the 2005-2014 time period, these costs were projected to total $573.5 million. Thus, the costs associated with the first NTSB recommendation were estimated to comprise between 94.6 and 96.3 percent of the total costs of the two NTSB recommendations.

s when the program effectiveness drops below 76 percent (i.e., the BCR is below 1.0).

Benefits are allocated between the two NTSB recommendations, with a range of 70 to 90 percent of the benefits attributed to the brake inspector certification recommendation and only 10 to 30 percent attributed to the driver pre-trip inspection recommendation, based on input obtained during this study. In addition, a base assumption of program effectiveness of 70 percent was varied from 50 to 90 percent. Higher percentages of program effectiveness indicate that the NTSB recommendations would have a greater effect on either avoiding or mitigating brake-related CMV crashes.

The driver training and pre-trip inspection recommendation fails to produce net benefits under any of the scenarios considered in Table ES-1. The driver training and pre-trip inspection recommendation produced BCRs ranging from 0.07 (50 percent ratio of effectiveness, 200-mile average trip) to 0.55 (80 percent program effectiveness, 400-mile average trip).

The brake inspector and certification recommendation, on the other hand, produced large net benefits, with BCRs exceeding 12.65 in all scenarios considered in this study. The BCRs range from a low of 12.65 (50 percent program effectiveness, 200-mile average trip) to 29.27 (90 percent program effectiveness, 400-mile average trip).

From this analysis, it appears that implementing the NTSB recommendation on certification of brake inspectors would create net benefits (benefits exceeding costs) and should be pursued. However, the NTSB recommendation on pre-trip brake inspections performed by drivers does not appear to be worthy of implementation.