Read this, then go to youtube.com and see Oak Harbors
newest recruits in action.
Organization: Oak Harbor Freight Lines
--------------------------------------------------------------------------------
General Comment
March 7, 2008
Docket #FMCSA-2007-27748
Docket Management Facility
U.S. Department of Transportation
Room W12-140
1200 New Jersey Avenue, S.E.
Washington, DC 20590-0001
Re: Notice of Proposed Rulemaking: Minimum Training Requirements for
Entry-Level Commercial Vehicle Operators
Dear Sir/Madam:
Oak Harbor Freight Lines is writing to express a number of serious concerns with
the Federal Motor Carrier Administration?s notice of proposed rulemaking
(NPRM): ?Minimum Training Requirements for Entry-Level Commercial Vehicle
Operators.? Although our company supports an enhanced driver training rule, the
provisions of this proposed rule are untenable and would seriously hamper my
company?s ability to recruit new drivers.
Oak Harbor Freight Lines is a regional LTL company operating in five western
states. We operate nearly 550 power units and employee more than 750 drivers.
Each year we develop approximately 20 ? 25 entry level drivers through an in-
house training program that allows dock workers to further their career with Oak
Harbor. This program has been highly successful in developing safe and motivated
new drivers. The company incurs the associated expenses in training time,
equipment and fuel with no cost to the employee. The long-term benefit to the
company has proven to be realized in the development of our best employees.
The accreditation and the hours-based training requirements in the proposed rule
are arbitrary and capricious. The accreditation requirements, as proposed, are
onerous, costly and would undermine the ability of my company to train entry-level
drivers. Further, the proposed rule fails to link any safety benefit to its 120 hours-
based training standard. The appropriate amount of time necessary for driver
training cannot be determined unless or until truck driver training hours have been
properly validated. FMCSA has not done this.
The proposed rule also would impose qualification requirements on classroom and
skills driver training instructors which do not align with industry practice and would
severely limit the number of individuals available to train new drivers. The Agency?s
proposal establishes that trainers be state certified and requires skill instructors to
have at least two years of experience rather than one. In this regard as well,
FMCSA has set forth a provision without any empirical evidence to support its
position. The proposed requirements exceed industry practice and, if adopted,
would limit type and availability of individuals to train entry-level drivers.
Oak Harbor has developed specific training focusing on the challenges of city
traffic and the LTL industry to include freight handling. We utilize experienced
company drivers trained to provide the specific skills for our industry. Additionally,
entry level drivers receive additional training from driver-mentors. Operations is
directed to limit the scope of their duties as they continue to develop skills during
the first year as a driver. Costs related to certification of training and trainers
would negatively impact our ability to continue the driver development program.
Clearly driver development is not a ?one size fits all? process. It is unique to each
aspect of the trucking community. It would be difficult, if not impossible for us to
continue developing what for us has become our primary means of recruitment and
driver development.
We are concerned by the Agency?s lack of specificity in regards to the proposed
rule?s CDL licensing process for new-entrants. The integrity of the ?driver?s training
certificate? (DTC), under the NPRM, is vulnerable to fraud due to the proposed
rule?s lack of recommendations for standardized and tamper-proof driver training
certificates. Further, the proposed rule makes no provisions for my company and
others to view/obtain a copy of the DTC of a prospective new driver candidate. We
have no way of verifying whether or not an individual has been properly trained.
Oak Harbor Freight Lines believes that the proposed entry-level driver training rule
is fundamentally flawed and needs to be reconsidered. At a minimum FMCSA
should: develop a performance-based rule for training and testing of entry-level
drivers; allow motor carriers and training schools to self-certify; and, revise the
process through which state drivers licensing agencies license, retain and share
driver training certificates.
Thank you for the opportunity to comment on this important issue.
Sincerely,
Robert L. Hansen
Recruitment and Safety Manager
Oak Harbor Freight Lines
