April 13, 2018

The Honorable Bill Shuster, Chairman

The Honorable Peter DeFazio, Ranking Member

Committee on Transportation and Infrastructure

U.S. House of Representatives

Washington, D.C.  20515

Dear Chairman Shuster and Ranking Member DeFazio:

We write to inform you of our strong opposition to legislative proposals which would allow teenagers to drive commercial motor vehicles (CMVs).  Of major concern are two bills that have been referred to your Committee — H.R. 5358, the Developing Responsible Individuals for a Vibrant Economy (DRIVE-Safe) Act and H.R. 3889, the Waiving Hindrances to Economic Enterprise and Labor (WHEEL) Act.  As the nation’s leading organizations and associations representing public health, consumers, safety and American truckers, we are certain these efforts would not only be detrimental to road safety, but also to those seeking to enter the trucking industry as professional drivers.

Younger drivers both lack overall experience and are less safe behind the wheel than their older counterparts. In fact, CMV drivers under the age of 19 are four times more likely to be involved in fatal crashes, and CMV drivers who are 19-20 years of age are six times more likely to be involved in fatal crashes. Research has shown that most drivers under the age of 21 lack the general maturity, skill and judgment that is necessary in handling CMVs, while other studies have shown that the prefrontal cortex — the portion of the brain responsible for complex cognitive behavior and decision making — does not fully develop until a person is in their mid20s. The current federal age requirement of 21 for the interstate operation of a CMV reflects these realities.  However, under these proposals, teenagers entering an apprenticeship and/or participating in a pilot program may have only recently received a full driver’s license from their state to operate an automobile, let alone a CMV.  Some may not have even gone through a graduated driver licensing (GDL) program, which allows novice drivers to gradually gain driving experience under more complex conditions.

While we appreciate the inclusion of minimum training standards in H.R. 5358, such as mandatory behind-the-wheel requirements, they are woefully inadequate.  For example, the first probationary period only consists of 80 hours of behind-the-wheel training which can be completed in a little over one work week. Moreover, the 160 hours of driving time in the second probationary period can be covered in just an additional two weeks. We also have serious concerns about who will be permitted to train new entrants. The experience requirements for those training apprentices in the bill are seriously insufficient and, if enacted, could allow even young apprentice drivers to qualify as trainers the moment they turn 21.

Both bills also exacerbate a foundational safety problem in the trucking industry.  Rather than proposing dangerous initiatives to get teenagers behind the wheel of 80,000 pound trucks, Congress should instead be focusing on the causes of the staggering driver turnover rate, which remains above 90% among large truckload carriers, and its impact on safety. This perilously high rate decreases safety, as drivers who leave the workforce are immediately replaced with less experienced individuals in an effort to keep labor costs as low as possible and avoid improving working conditions.

We have significant concerns about corporate proponents of these proposals using the guise of a national driver shortage to use less expensive and less experienced labor. In 2001, a petition was filed with the Federal Motor Carrier Safety Administration (FMCSA) to lower the federal Commercial Driver’s License (CDL) age requirement to 18, citing a driver shortage as the primary reason for the effort.  FMCSA declined to lower the minimum age for an unrestricted CDL because the agency could not conclude that the safety performance of younger drivers was on par with, or even close to, that of older CMV drivers.  The public overwhelmingly rejected the idea with 96 percent of individuals who responded opposing the proposal along with 88 percent of the truck drivers and 86 percent of the motor carriers after FMCSA posted the petition in the Federal Register.

In the nearly 20 years since the petition, there has never been a significant disruption in the delivery of goods by truck due to a lack of drivers and hundreds of thousands of new CDLs have been issued each year. Over this time, driver compensation has remained relatively stagnant, failing to increase at a rate that even reflects inflation. While we would prefer to assume most motor carriers participating in the apprentice and/or pilot program would do so with the best of intentions, experience tells us many will unfortunately use the initiative to take advantage of teenagers, whom they view as cheaper labor.

Because younger drivers are subjected to increasingly poor working conditions, unknowingly sign predatory lease-to-own schemes and regularly receive inadequate compensation, they rarely stay in the job long enough to accumulate the experience necessary to operate a heavy vehicle in safe and responsible manner. Ignoring these basic facts and promoting policies to get even younger drivers in the cab of a truck will only compound today’s turnover crisis and make our roads less safe. We urge you to oppose H.R. 5358 and H.R. 3889.


Catherine Chase, President

Advocates for Highway and Auto Safety

Todd Spencer, Acting President & CEO

Owner Operator Independent Drivers Association

Joan Claybrook, Chair

Citizens for Reliable and Safe Highways (CRASH)

Former Administrator, National Highway Traffic Safety Administration

Georges C. Benjamin, MD, Executive Director

American Public Health Association

Steve Owings, Co-Founder and President

Road Safe America

Dawn King, President

Truck Safety Coalition

Jack Gillis, Director of Public Affairs

Consumer Federation of America

Jennifer Tierney, Board Member

The CRASH Foundation

Daphne Izer, Co-Chair

Parents Against Tired Truckers

Stephen W. Hargarten, M.D., MPH

Society for the Advancement of Violence and Injury Research

Sally Greenberg, Executive Director

National Consumers League

Rosemary Shahan, President

Consumers for Auto Reliability and Safety

Andrew McGuire, Executive Director

Trauma Foundation

Janette Fennell, Founder and President


cc: Members of the House Committee on Transportation & Infrastructure

Letter of Opposition to HR 5358 and HR 3889