GHSA Policy on Truck Safety

Excerpted from GHSA Policies & Priorities

GHSA supports Commercial Drivers Licenses (CDLs). Through the CDL program, many unsafe commercial motor vehicle drivers have been removed from the roadways. The program has proven to be an important safety tool for promoting safe commercial vehicle traffic.

GHSA recommends that the Federal Motor Carrier Safety Administration (FMCSA) consider further improvements in the CDL record-keeping system to eliminate the problem of multiple license issuances and to establish minimum standards for state driver history records of commercial motor vehicle drivers.

FMCSA should work with governors and state legislatures to develop standards that would restrict CDL holders from traffic violation “bypass or diversion” programs that prevent driving offenses from appearing on their driving records.

Additionally, FMCSA should examine the merits of a graduated licensing system for CDL applicants. Issuing an interim or probationary license with restrictions on activities and violations before attaining a full CDL may have safety benefits.

GHSA believes that the Motor Carrier Safety Assistance Program (MCSAP) has been a catalyst for improving motor carrier safety in our states. The Association supports the program and urges that it be funded at the authorized levels. While GHSA supports the restructuring of MCSAP into a more performance-based program, we strongly oppose any effort to create performance-based disincentives within MCSAP.

GHSA members are encouraged to work closely with their MCSAP partners and to coordinate data and highway safety plans as required by federal statute. This collaboration will enhance states’ ability to address safety comprehensively.

GHSA also supports the use of MCSAP funds for enforcement of traffic laws relating to commercial motor vehicles. The Association encourages law enforcement agencies to enforce aggressively laws involving commercial motor vehicles, particularly at high crash locations. Under the federal surface transportation legislation, MCSAP funds can be used to enforce traffic laws with any vehicle in the vicinity of a commercial motor vehicle. GHSA supports this expansion of MCSAP enforcement and encourages coordination of MCSAP enforcement efforts with enforcement efforts funded by federal behavioral grant programs.

GHSA encourages FMCSA to establish a more accurate annual census of motor carriers, increase the percentage of truck crashes that are reported and link safety compliance, rating and inspection data to crash data in order to identify high risk carriers. FMCSA should also encourage states to improve the collection of truck crash data by motivating them to adopt the Model Minimum Uniform Crash Criteria (MMUCC) — the federal guidelines that incorporate the uniform data elements recommended by the National Governors’ Association— when states revise their crash reporting forms and by providing incentives for the timely reporting of crash data. Additionally, FMCSA should undertake a comprehensive study to identify the factors that contribute to truck crashes. This would allow the Administration to prioritize its policies and programs concerning those factors that make the highest contributions to such crashes.

GHSA supports FMCSA’s Entry-Level Driver Training rule for novice commercial motor vehicle drivers. Comprehensive training for new truck drivers will improve the ability and expertise of commercial drivers on the road and ensure that they are thoroughly familiar with federal motor carrier safety regulations and safe driving behavior.

FMCSA should continue to place a high priority on the enforcement of federal commercial motor vehicle safety regulations, increase the number of compliance reviews that are conducted each year with a special emphasis on high-risk carriers and increase the fines, particularly for repeat offenders. FMCSA should periodically evaluate the fines that are assessed of non-compliant carriers to ensure that they have the appropriate deterrent effect and increase the fines as necessary.

Fatigue has been identified as a major factor in single truck crashes and it may be a significant factor in all truck crashes. The current hours-of-service requirements may be one of the variables contributing to driver fatigue. Federal limits on hours-of-service are governed by regulations that do not reflect current research on fatigue and circadian rhythms. FMCSA should revise the existing hours-of-service regulations so that, at a minimum, they allow 12 off-duty hours (including eight hours of uninterrupted rest time) in any 24-hour period and do not allow any increase from the driving time currently permitted.

On-board recorders that track the hours of operation of heavy trucks can help to enforce hours-of-service regulations and eliminate falsification of logbooks in which drivers track hours driven. GHSA encourages the use of on-board recorders or other electronic monitoring systems to keep automatic records of truck hours-of-service.

The lack of adequate rest areas also contributes to commercial motor vehicle driver fatigue. FMCSA should continue to assess the adequacy of both public and private sector rest areas. Further, Congress should consider allowing joint public-private partnerships to finance rest areas on roadways with an identified need.

Federal minimum insurance requirements for motor carriers help protect the consumer and determine the carrier’s fitness for service. FMCSA should frequently examine liability insurance minimums, determine if they are adequate and revise as appropriate.

Additionally, states should be encouraged to adopt mandatory minimum liability insurance coverage levels for intrastate commercial vehicles that are equivalent to the federal minimum levels for commercial vehicles being operated in interstate commerce.

GHSA is concerned with the potential effect that increased truck size and weight could have on highway safety. Many states have increased speed limits, increasing the speed differential between large trucks and other motor vehicles. This raises concern regarding any increases in truck size or weight.

GHSA encourages the enforcement of current truck size and weight regulations. The Association opposes increases in the current federal truck size and weight limits unless and until it can be shown that such increases will not compromise safety. GHSA supports the use of truck underride guards to prevent underride crash injuries and fatalities.

GHSA also encourages jurisdictions to install commercial vehicle weigh-in-motion and electronic screening technology that, in addition to identifying overweight problem vehicles, can aid in reducing the potential hazards of slower moving commercial vehicles exiting and entering the roadways.

GHSA recognizes that hazardous materials traveling throughout our country are a necessity, but also increase the potential for serious problems. It is critical that response teams are well trained and equipped to ensure appropriate response in the event of an incident. Enforcement of hazardous materials regulations on the roadways is also critical to minimizing the potential threat of serious hazardous materials incidents. 

GHSA supports the continuation of quality federal training for hazardous materials inspectors and the provision of technical assistance to states so that they may be able to develop their own high-level training programs that are consistent with federal standards. 

GHSA also encourages federal hazardous materials inspectors to work with states to investigate the safety of hazardous materials shippers as well as carriers. Expansion of safety inspections is necessary in order to address all aspects of the hazardous materials transportation problem.

GHSA supports the ban of all speed detection devices (e.g., radar detectors, laser detectors, etc.) in commercial motor vehicles. GHSA supports the use of speed governors in commercial motor vehicles over 25,000 GVW.

FMCSA has a public information campaign to educate other road users on the physical limitations of large trucks and how to share the road with them. GHSA supports this campaign and encourages its members to participate actively in and promote the campaign in order to reduce the number of crashes involving large trucks.

GHSA supports federal regulations which would require all new and previously marked commercial motor vehicles over 26,000 lbs. to have specific reflective markings on the sides and rear of truck trailers. The required reflective markings will reduce the number of truck-passenger car crashes, injuries and fatalities by allowing motorists to detect commercial motor vehicles better at night and under conditions of reduced visibility.

GHSA supports federal rules and regulations for legal level of impairment for commercial motor vehicle (CMV) operators at .04 BAC. GHSA urges states to strictly enforce these requirements by providing on-going impaired driver training detection for commercial vehicle enforcement officers.

GHSA supports the federal ban on texting by drivers of commercial motor vehicles. The Association encourages the coordination of distracted driving educational and enforcement campaigns funded under MCSAP with those funded by federal behavioral grant programs.

GHSA recommends that state enforcement of mandatory safety belt laws focus on all drivers, including drivers of commercial motor vehicles. GHSA also urges commercial motor vehicle shippers and carriers to adopt and enforce mandatory safety belt use policies.

Although GHSA understands the driver shortage problem in trucking, the Association is opposed to licensing drivers under the age of 21 for CMVs. Motor vehicle crashes are the leading cause of death for 15-20 year olds. Any expansion for younger drivers, therefore, will put the riskiest drivers on the road, regardless of the level and intensity of training.

GHSA supports the use of speed limiters in CMVs and urges the FMCSA to issue rules to leverage the safety benefits of this technology.