Federal Motor Carrier Safety Administration

[Docket No. FMCSA-2007-27748)

Entry-Level Driver Training

Public Listening Session

January 7, 2013 Charlotte, NC

The mission of CDTF is as follows:

  • Promote, aid and support the academic and educational programs, and other areas of operations, offered by the commercial driver training and related industries;
  • Supporting excellence in instruction, research, scholastics and facilitating communications which are pertinent to the commercial driver training and related industries and their instructional programs;
  • Supporting students and faculty of institutions involved in the commercial driver training and related industries, and other interested parties, by developing and conducting research, and educational activities; and
  • Supporting public service activities on behalf of the commercial driver training and related industries by enhancing the overall quality of supportive services available to those organizations.

We have worked closely with the FMCSA, Commercial Driver Training Schools of all types, the Trucking Industry and Safety Professionals dedicated to increasing driver capability and increasing safety through participating in the development of meaningful public policy.

As Chairman of the Foundation, I have entered comments and supplemental comments representing the development of a performance based assessment for individuals learning to drive commercial vehicles.

As stated in the original comments of the Foundation, The “Model Curriculum for Training Tractor-Trailer Drivers” created by the Federal Highway Administration in 1985 (while never adopted formally as a rule) has become the de facto standard curriculum for training tractor trailer drivers.  The major texts used by public, private and employer-based training programs follow the proposed curriculum, and include all of the basic subject areas for training entry-level commercial drivers.  The Proposed Rule acknowledges that fact.

The Focus of the assessment tool is what should be the overall goal of any training requirement for entry-level commercial drivers – increased highway safety.  Prior to the creation of the validated assessment tool by CDTF, there was no scientifically proven way to assess the knowledge and skills required to prove a mastery of the subjects contained in the Model Curriculum.  The Foundation undertook development of the assessment tool in order to fill that void.

The question is:  How should the adequacy of training be measured?

The Commercial Driver Training Foundation, Inc  recognized the need for a comprehensive assessment tool that could measure the knowledge and skills in all areas  contained in the “Model Curriculum.”  The Notice of Proposed Rulemaking specifically asked whether a performance-based alternative to the proposed hours-based approach was possible.  CDTF has created a validated assessment tool that addresses this issue, and the test was submitted to FMCSA as a response to this question.

  • The Performance Test developed by the CDTF represents, for the first time, a broad consensus on performance measures which has (to date) been lacking.
  • The test is based on 102 specific Performance Standards developed by a panel of 45 subject matter experts from training schools and trucking companies
  • These performance Standards were reduced to a comprehensive test based on the “Evidence Centered Design” approach developed by Educational Testing Services, Inc.
  • ETS administers the SAT, GRE and other recognized national tests
  • The Performance /test involves written and skills tests as appropriate
  • The test has been reviewed by subject matter experts from schools and motor carriers, and a pilot test has been conducted to ensure that it adequately relates testing to the subjects proposed in the Proposed Rule.

Upon completion of the development of the test and the pilot testing project, all materials were submitted to Prometric, Inc. for review.  Prometric is a subsidiary of Educational Testing Services, Inc.  Prometric actually administers tests to a wide range of government entities and private businesses worldwide.

“Prometric provides testing and assessment services in `135 countries to over 450 clients and is   the sole provider of exams for such high caliber clients such as Association of American Medical Colleges, the National Board of Medical Examiners, Johns Hopkins University, the College Board, the Financial Industry Regulatory Authority, the American Institute of Certified Public Accountants, and the National Association of State Boards of Accountancy.  The company has  government contracts in Ireland, England and Saudi Arabia, and federal and state contracts in the United States.  Exclusive clients in the technology market include IBM, Microsoft Learning, Oracle and Sun Microsystems.”

The review of the developmental procedures was conducted by Dr. Linda Waters of Prometric.  Dr. Waters was asked to review the process used to develop the performance measures that underpinned the test; the development of the specific test question; and the administration of the “pilot test” project.  She was asked to determine whether the methodology known as “Evidence Centered Design had been followed consistently, and thus whether the resulting test was a valid measure of the knowledge and skills standards developed by the subject matter experts.   Dr. Waters also commented on models for delivering knowledge assessments, preparing test examiners for test administrations, determining a passing point, reporting scores, maintaining test taker data files, ongoing analysis of results, and considerations for future development.

It is well established in academe that different students have different learning aptitudes (e.g. they do not all learn at the same pace.)  The whole premise of the performance based approach advocated by CDTF is that the student can demonstrate that he or she has actually learned the material and is capable of performing the requisite skills necessary to safely operate a commercial motor vehicle on the highways.

By definition, students seeking a Commercial Driver’s License to enable them to operate in interstate commerce are adult learners.  It is well recognized in the academic community that adult learners learn material in ways that differ from younger learners.  The learning experience for adult learners allows them to draw on previous life experiences; thus they generally respond better to being shown “how to” rather than a survey-type course.  Unlike younger students being exposed to material for the first time, adult learners learn at a pace that is unique to the individual.

There is a strong temptation to count the number of hours that a student spends in school and equate those hours to the acquisition of knowledge and skills; however that temptation should be resisted because it is a flawed approach.  Counting the inputs does not take into account the quality of the teaching materials or instructors, the aptitude of the individual student or an assessment of the outcome of the educational effort.

CDTF appreciates the opportunity to present its material and respectfully requests that FMCSA adopt the comprehensive, content validated written and performance objectives and assessment that were submitted as an attachment to its initial comments as a means of assessing entry-level drivers.  The Foundation would be pleased to have the opportunity to work with FMCSA on resolving any remaining issues.