Comments submitted by the Owner-Operator Independent Drivers Association regarding a pilot plan to allow drivers between 18 and 20 years old to drive interstate raise a significant issue: Will anybody insure these drivers?
OOIDA doesn’t declare it is unalterably opposed to the proposal, though the comments filed by President and CEO Todd Spencer are unrelentingly negative. But the question of insurance is one that the Federal Motor Carrier Safety Administration, if it implements the pilot program, would have little ability to influence.
“We expect it will be difficult for many motor carriers to afford insurance coverage for younger drivers,” OOIDA President and CEO Todd Spencer wrote in the letter submitted to the comments section of the proposal last Wednesday.
“Small-business motor carriers are especially unlikely to take the risk of insuring under-21 drivers without evaluating the costs and benefits to their operations,” Spencer said in the letter. “In all likelihood, only self-insured carriers will be willing to provide coverage for under-21 interstate drivers.”
Drivers under the age of 21 can drive intrastate under laws in most states, where presumably they are covered by insurance.
The FMCSA’s proposed Apprenticeship Pilot Program (APP) calls for the apprentices — who must have a CDL — to perform two probationary periods. One is for 120 hours of on-duty time, including 80 in a truck, and must be completed with a veteran truck driver riding along as a passenger. The second is 280 hours, including at least 160 in a truck, and no accompanying driver is needed.
At the root of most of OOIDA’s comments is a concern that the APP will not be generating adequate data to make an informed decision about the safety issues raised by drivers operating interstate who are between the ages of 18 and 20.
“FMCA must incorporate more specific data collection methods that will better determine whether under-21 drivers can safely operate an interstate commerce,” Spencer wrote in the letter.
Among the data-related issues raised by OOIDA:
- The proposed information collection request doesn’t supply an adequate definition for what drivers will be in the control group. “We would like to see more details about how the safety data collected will be compared with other drivers, including how the control group will be selected,” Spencer wrote.
- The specific length of the APP is called into question. “How will the agency decide whether APP should be extended, expanded or discontinued in the final data analysis?” Spencer wrote. “If crashes and fatalities occur during the program, will those be made public?”
- One of the key arguments in favor of allowing under 21 drivers to be behind the wheel interstate is that they already can do so intrastate. OOIDA says the study must include crash and safety data on those intrastate drivers.
- OOIDA sees the program as an opportunity to push some of its favored issues. For example, the APP “is another opportunity to examine the cause of excessively high driver turnover rates,” Spencer wrote, adding that FMCSA should also use the study to investigate issues of lengthy detention.
- If the pilot program leads to allowing those under-21 drivers to take to the interstate highway, OOIDA wants continued data collection on the performance of those drivers. “We strongly believe the APP must monitor and analyze apprentice performance after they have completed the required probationary periods,” Spencer wrote.
A spot check of the comments submitted so far indicates they are running overwhelmingly against the proposal.
“As a 42 year veteran trucker/owner with a 5 million mile no accident safety record, I feel that younger drivers do not have the patience and ability to control [their] emotions,” Marc Edleston wrote in a comment that was typical. “Driving is more than operating a large vehicle. You encounter bad weather conditions, bad road conditions, and most of all other bad drivers. One must always be extremely patient.”