Commercial Driver’s License; Pilot to Allow Drivers Under 21 to Operate Commercial Motor Vehicles in Interstate Commerce Notice and Request for Comments 84 Federal Register 21895, May 15, 2019
These comments are filed jointly by the Truck Safety Coalition (TSC), Citizens for Reliable and Safe Highways (CRASH), Parents Against Tired Truckers (PATT) and our volunteers, who are the family and friends of truck crash victims and survivors seeking truck safety advances. We write these comments in response to the Federal Motor Carrier Safety Administration’s (FMCSA, Agency) notice requesting comments on a pilot program to allow drivers under the age of 21 to operate commercial motor vehicles in interstate commerce. We strongly oppose the pilot program for several reasons:
- Truck crashes, injuries, and deaths continue to increase;
- The available data shows that 18-20-year-old drivers are more likely to crash;
- The impetus for this change – a shortage of truck drivers – is a myth perpetuated by those with a pecuniary interest in lowering the legal age for interstate truck operations
- The FMCSA has not analyzed data from the 48 states that could provide data on the safety records of 18-20 year old drivers who currently operate in intrastate commerce.
Truck Crashes, Injuries, and Deaths Continue to Increase
Lowering the age required to operate a large truck across state lines will do nothing to reverse the worsening death toll from truck-related crashes, which are up 41 percent since 2009. Nor will it bring down the number of truck occupant deaths, which are at their highest levels since 1989. Nor will it reduce the number of truck crashes, which occur more than 1,200 times each day. Allowing 18 to 20 year olds to drive 80,000-lbs vehicles that are more difficult to operate than passenger vehicles will likely make our roads less safe.
The Available Data Shows that 18-20 Year-Old Drivers are More Likely to Crash
One study that specifically looked at the effect of age on the operation of a large truck found that commercial motor vehicle (CMV) drivers under the age of 19 are four times more likely to be involved in fatal crashes, and that CMV drivers between the ages of 19-20 are six times more likely to be involved in fatal crashes. These statistics alone should stop the agency from moving forward with this corporate handout to those entities who stand to profit from this proposed change.
However, there is even more data that shows all drivers ages 18-20 are less safe and more likely to crash than older driver. Based on 2017 federal crash data analyzed by the Insurance Institute for Highway Safety, teen drivers ages 18 to 19 are 2.3 times more likely than drivers aged 20 and older (up to age 84) to be in a fatal crash and nearly 3.5 times more likely to be involved in any police reported crash. Moreover, a recent report analyzing 10 years of fatal crash data involving teen drivers from the Governors Highway Safety Association revealed two other disconcerting data points about 18 to 20 year old drivers: 1) 19-year-olds accounted for the greatest number of teen drivers killed during this 10-year period, followed by 20- and 18-year olds; and, 2) older teens (18- 20-years-old) were twice as likely as their younger counterparts to be involved in a fatal crash between midnight and 6 a.m.
The Impetus for This Change – A Shortage of Truck Drivers – is a Myth Perpetuated by Those with a Pecuniary Interest in Lowering the Legal Age for Interstate Truck Operations
There is no truck driver shortage. According to the Bureau of Labor Statistics Report, “Is the U.S. labor market for truck drivers broken?” from September 2018: “The occupation of truck driving is often portrayed by the industry and in the popular press as beset by high levels of turnover and persistent “labor shortages”… [But] a deeper look does not find evidence of a secular shortage.”
Additionally, an investigative report by Barron’s, “Busting the ‘Truck Shortage’ Myth,” found that the Truck Driver Shortage Analysis from which this myth derives was “vague about its methodology, simply asserting that a shortage exists and will get worse over time as demand rises and existing truck drivers retire.”
Upon reading the Barron’s expose, the Truck Safety Coalition reviewed the American Trucking Associations’ (ATA) Truck Driver Shortage Analysis from 2015, 2017, and 2019 as well as The U.S. Truck Driver Shortage: Analysis and Forecasts prepared for the ATA by Global Insight, Inc. in May of 2005. While the latter report has formed the basis on which the shortage myth is predicated, there are several assumptions the 2005 report makes that did not come to fruition and should thus call into question any report or study that references it; this includes all three of the aforementioned Truck Driver Shortage Analyses produced by the ATA. Several incorrect assumptions made by Global Insights are:
- Their forecast showing 3.4% average annual growth of trucking output from 2004-14,
- Their forecast showing a 3.2% GDP annual growth from 2004-14,
- Their establishing a baseline figure for the number of truck driver jobs in 2004 based on “widespread anecdotal evidence,” and
- Their arbitrary boosting of the 1.31 million employment figure (which Global Insights previously noted is a “hard number to pin down” because of various ways to measure trucking employment) by 1.5%, which is how they ultimately arrived at a shortage of 20,000 drivers in the year 2004.
The FMCSA Has Not Analyzed Data from the 48 states that Could Provide Statistics on the Safety Records of 18-20 Year Old Drivers who Currently Operate in Intrastate Commerce
Collecting safety data from the 48 states where truck drivers ages 18 to 20 can operate within state lines should be the agency’s first step before moving forward with this potentially risky pilot program. Doing so would help the agency determine:
- If there are a sufficient number of 18-20 year old truck drivers operating in intrastate commerce to yield a statistically significant study on the crash rates of these drivers, and
- If these 18-20 year old drivers are, in fact, as safe or safer than the average truck driver who operates in interstate commerce.
With regards to the first point, the agency could find that amongst the 48 states that allow teen truckers, there are too few teen truckers to yield meaningful data for the FMCSA to compare them to older, interstate truck drivers. If this is the case, there would be no need for the agency to continue with a pilot to allow teen truck drivers to go from Albany, NY to Los Angeles, CA if there are not even enough teen truckers who carry freight from Albany, NY to New York, NY.
With regards to the second point, all but two states allow teen truck drivers to operate in intrastate commerce so there should be data on the relative crash risks of teen truckers that operate within state lines. For example, the Truck Safety Coalition requested data on truck driver by age from the state of New York. Their data revealed that from 2009 to 2017, there was a 12.6 percent increase in the total number of truck drivers involved in crashes within New York, but for truck drivers age 18-20 involved in crashes in NY that figure jumped 17.8 percent in that same time. Clearly, figures like this undercut the argument younger truck drivers will be as safe as or safer than older drivers. We urge the agency to solicit crash data from the states that allow teen truckers to operate in intrastate commerce, and then analyze it before moving forward with a pilot. Doing this may not just save money for the agency but also lives on our roads.
TSC strongly opposes the pilot program to allow teen truckers to operate in interstate commerce. In the face of ample research showing that teen drivers are much less safe and more likely to crash than their older cohorts, the FMCSA has furnished no proof that introducing this demographic of truck drivers to interstate operations will improve safety. Add to this fact that long haul trucking, including traveling to states that a teenager has never been to before, only complicates the environment for young, inexperienced drivers.
We will not offer recommendations to the agency as part of these comments on how they should craft the pilot. Instead, we urge the FMCSA to not spend any money on this until they have first collected data from the states and produced an analysis on that data showing that permitting these younger truck drivers will not adversely affect safety.
 National Highway Traffic Safety Administration (NHTSA). Trends Table 4. Large Truck Fatal Crash Statistics, 1975-2017. Large Truck and Bus Crash Facts 2017. https://cms.fmcsa.dot.gov/safety/data-and-statistics/large-truck-and-bus-crash-facts-2017
 Ibid. See Page 45.
 Campbell, K. L., Fatal Accident Involvement Rates by Driver Age For Large Trucks, Accid. Anal. & Prev. Vol 23, No. 4, pp. 287-295 (1991).
 2017 FARS Data analyzed by the Insurance Institute for Highway Safety. See data analysis at https://www.iihs.org/topics/teenagers
 Governors Highway Safety Association. 2017. Mission Not Accomplished: Teen Safe Driving, the Next Chapter https://www.ghsa.org/sites/default/files/2016-12/FINAL_TeenReport16.pdf
 Stephen V. Burks and Kristen Monaco, “Is the U.S. labor market for truck drivers broken?,” Monthly Labor Review, U.S. Bureau of Labor Statistics, March 2019, https://doi.org/10.21916/mlr.2019.5.
 Klein, Matthew C. “Busting the ‘Trucker Shortage’ Myth.” Barron’s, Barrons, 14 Mar. 2019, www.barrons.com/articles/busting-the-trucker-shortage-myth-51552589481.
 The U.S. Truck Driver Shortage: Analysis and Forecast http://www.iitr.edu/pdf/ATADriverShortageStudy05.pdf
 Data retrieved from Institute for Traffic Safety Management & Research