Monday, July 06, 2015

Proof They Have All The Training They Need

June 6, 2014: According to Dalhart, TX police reports, the C.R. England driver failed to control his speed, lost control of the vehicle, ran off the road, and ran straight into the grain bin.
Because I'm an owner-operator and not being force-dispatched anywhere, I have a lot of time to sit around and surf the internet.  And since I got a little involved with this C.R. England thing a few weeks ago, I decided to dedicate some of my free time to writing another post about it. It's just sorta bugging me.

I'm no Erin Brockovich - although Julia Roberts should feel free to play me in the movie version should that happen - but I am an information hound.  I can't read an article, blog post, magazine, book, or sometimes even a sentence without stopping mid-stream to Google something I don't know or want more information on. And this C.R. England exemption had me Googling. 

For a company that professes dedication to good training and safety, I don't see how they think their exemption request reinforces that dedication.  And I still can't get over the fact that the FMCSA actually granted them the exemption.  What's the point of having rules if you're just going to allow people to circumvent them? W
hen I mentioned this exemption to our safety guy at the Million Miler event last week, his first words were, "I wonder who they paid off?"  

Here's the actual letter C.R. England sent to the FMCSA requesting the exemption.  It's only four pages, so a quick read.  I'm going to excerpt the parts I have comments on. There are many. Keep in mind as you're reading this, that C.R. England owns and runs the trucking school they're talking about.  Here we go:


C.R. England seeks an exemption from the requirement that those accompanying a Commercial Learner's Permit ("CLP") holder must be physically present at all times in the front seat of a Class 8 truck on the condition that they have successfully passed an approved CDL skills test.

That's the condition? That they passed a test? I would think they have a vested interest in passing their own students.  It's their school. And they'd never pass a student who wasn't fully qualified to get them on the road, working and making money for them as quickly as possible, would they?

As the FMCSA is well aware, the trucking industry is desperately in need of qualified and well-trained drivers to meet the ever-growing demand for shipping needs. However, subpart 383.25(a)(1) limits C.R. England's ability to effectively and efficiently recruit, train, and employ new entrants to the industry. The exemption is requested due to the significant burden that this rule may create on the driver supply for C.R. England.

The rule doesn't affect how many people are available for trucking jobs. What it affects is the amount of people C.R. England can get from training to pulling freight. The quicker that happens, the sooner the company can start making money.

Under 383.25(a)(1), however, a CLP holder must be accompanied at all times by a CDL holder who, in turn, must be physically present in the front seat of the vehicle next to the CLP holder and in on-duty status during this time. This requirement appears to apply even after the CLP holder successfully passes the CDL skills test.

Yes, that's right.  A CDL holder must be physically present in the front seat while the person with the LEARNER'S PERMIT is driving.  Is this a difficult concept to grasp?  Passing the CDL skills test means nothing.  Especially when the test is given by the school owned and run by C.R. England. It seems to me they'd do whatever they can to get the student driver to pass that test.

I went to an independent trucking school that offered 13 days of training.  I paid $6,200 out of my own pocket to go to that school and chose it specifically for the short program because I wanted to get in the truck with Ed and be trained by him as soon as possible. In that school, I saw them pass students that didn't seem to "get it", so I know there's a pretty good chance the students C.R. England wants to put behind the wheel, aren't fully qualified.  That's just how trucking schools work. There's a reason they call them "CDL mills". The limited practical portion of the driving school testing isn't indicative of real-life scenarios, so in my opinion, it means very little in the way of indicating someone's driving skill. There's not a lot of time behind the wheel and you often don't have one-on-one training.

In fact, while I was in trucking school and driving during the "practical" portion of my training, I was hit by a dump truck that sheared the driver's side mirror off the 18-wheeler I was driving. That could have been bad news bears for me and the three other people in the truck with me.  Two of them weren't even wearing seatbelts.  Yet, guess what?  I still passed the practical portion of my training program and was granted a CDL.  Because I had 13 days total schooling consisting of a "CDL skills test and practical driving time".  

Trucking schools teach just enough to put a CDL in someone's hand. But the difference between me and the C.R. England students, is that I was not put behind the wheel of my own truck after I left training.  I wasn't going to be driving alone, without a trainer in the passenger seat, for a company who'd be using me on team runs so they could make money.

In fact, I didn't go work for a company at all.  I was going to be driving team with Ed, who was a leased owner-operator. I spent over 315 hours training with Ed, being evaluated, and then had to do a driving test with the safety instructor at the company we're leased to before I could be cleared to drive without someone in the passenger seat. Still, even after solo driving was approved, I didn't drive alone for months and months and months after that.

And before I started driving I had been in the truck with Ed, as a passenger, for two years prior to taking my class. I had an understanding about what life on the road and in a truck was like. I observed Ed driving on a daily basis. I saw how he maneuvered on the highway, I saw how he wrangled his truck into tight spaces while backing up, I watched him load freight, and I observed him dealing with customers. I learned how to be safe without even realizing I was learning.

C.R. England isn't the only trucking company whose school doesn't provide adequate training but they are the only one who's requested and received an exemption to Part 383.25 of Title 49 of the Code of Federal Regulations.   

This rule places C.R. England in an untenable position. Either we send the driver to their home state by bus or airplane, at C.R. England's expense, and hope that the CLP holder obtains the final CDL and returns to C.R. England, or C.R. England must incur double the cost for about half of the production by sending them to their home state on one of our trucks.

At C.R. England's expense?  So?  These are their students.  And they will eventually be C.R. England drivers, since they had to make a 9-month commitment to work for them in order to get the free schooling.  Which isn't really free by the way, if you're obligated to work for them for 9 months. That's more like bartering or indentured servitude. Training costs for any industry are a risk, because you can never be sure the money, time, and effort put into training will turn out to be worth it. That's just the cost of doing business.

And it's really hard to take their cry of losing money seriously when we know they reported revenue of $3 billion in 2014. Also -- and I don't know if this is the case since they run their own school -- but it's possible the school (depending on which state it's in) is eligible for funds from the Commercial Drivers License Program Implementation Grant, which is funded by the annual appropriations act. In 2014, that fund amounted to $30 million dollars and the minimum federal award amount was $50,000.  This may not apply to C.R. England, but even if they don't get federal money, they can still fall back on that $3 billion.

It is inefficient for C.R. England because it will incur the added expense of bus fare or airfare and C.R. England will also give up any influence over whether the driver actually obtains a formal CDL and returns to work. In this competitive job market, carriers will be hard pressed to send new drivers, for whom they have invested significant recruiting and training resources, to a different state with little influence over whether they actually begin working for the carrier or immediately leave for a competing carrier or industry.

Wait...they're afraid their students aren't going to come back??  But C.R. England is offering them such a great opportunity. Why wouldn't they come back? Hmm. I've trained for jobs in the past and it never occurred to me to take my training and go elsewhere when I was done. So because they don't want to incur expense to send their students home, and they aren't confident they've provided enough reason for the students to come back, they want to compromise the safety of the student, the driver trainer, and the motoring public to get the student driving as soon as possible. That's a bit self-serving, dontcha think?

Furthermore, drivers will not be able to utilize the training they just received and they may see some attrition in their skill set due to the days or weeks spent without driving as they travel home to obtain a formal CDL. This attrition of driver skills will have a negative impact on safety.

So they're telling the FMCSA outright that the students -- the ones who went to C.R. England's very own Premier Trucking School, the ones they speak so highly about in regard to the education they provide, the ones they're asking for an exemption for -- are, in a matter of days or weeks, going to forget what they've learned?  Really??  They are actually admitting, to the Federal Motor Carrier Safety Administration, that their very own training isn't comprehensive enough to be remembered between the time the student leaves the school and gets behind the wheel of an 80,000 pound vehicle?  Wow.

The exemption sought would apply only to those who have passed the CDL skills test and hold a CLP.

I had a CLP within my first week of class. As a group we crammed for the written test, went to the DMV, regurgitated our answers into the computers we took the multiple choice tests on, and left the building with our learner's permits in hand.  It's bad enough C.R. England is asking for this exemption, but man, what the hell was the FMCSA thinking?? 

The number of drivers that would operate under the terms of this waiver would likely be several thousand per year.
Several thousand??  That's oh, I don't know...several thousand more than I'm comfortable with.

The exemption will result in a level of safety that is greater than the level of safety of the rule without the exemption. The only difference between a CLP holder who has passed the CDL skills test and a CDL holder is that the latter has waited in line at the DMV and has received the hard copy CDL. The practical result of the exemption is that a CLP holder who has passed a CDL skills test would be able to drive without the requirements of subpart 385.25(a)(1) and begin immediate and productive on-the-job training. This will allow them to hone their recently acquired driving skills and put them to work (in addition to immediately earning an income).

I know everyone has to start somewhere but I don't think putting a new student behind the wheel of an 80,000 pound vehicle immediately after schooling, without constant and immediate supervision, will result in a greater level of safety. They run their trucks during the 30-day training period as a team truck, with a trainer that may have only had six-months' experience themselves.  That's scary. 

THIS is their training timeline.

Truth be told, I don't have much faith in these driver trainers to begin with.  I can't tell you how many drivers I've met that have bragged about being made a driver trainer within a year or even months of them completing trucking school themselves.  At C.R. England, all trainers must have a minimum of six months' safe driving experience before they can become a trainer. Six months??  They're letting someone become a trainer because they haven't hit anything in six months? That's literally putting someone who doesn't know what they hell they're doing, in charge of observing and teaching someone else who doesn't know what the hell they're doing.  

My instructor at trucking school had been driving for over 40 years. The guy who took us out on the road to do our exam had been driving for over 25 years.  And when Ed taught me how to drive, he'd already been driving for 10 years, four of them as an owner-operator. 

C.R. England and the people who support them are saying that for all intents and purposes, the students have adequately proven that they have passed their skills tests (written and practical), and all that's left for them to do before they are set loose, is to "stand in line at the DMV". That the last step to being the recipient of a shiny new CDL is just a formality.

Well, it's a formality we've all had to abide by.  

First, if the exemption is not granted, carriers will need to cover the cost for drivers returning to their home states to receive their CDLs. This will necessitate an increase in school tuition costs. As tuition goes up school becomes less affordable. Most drivers arriving at our schools are in immediate need of a steady income. They understand it will be delayed because of the time they spend in school. Nevertheless, they are stretched to the limit when they receive their first pay check. To delay the first pay check by another week or two, or more, will have a devastating effect on people who are doing their best to provide for their families.

Since when do billion dollar corporations give a shit about the people who work for them? Since almost never, that's when. They don't care about the price of trucking school, and if they cared so much about their students having immediate steady income, they'd provide it to them.

Finally, an unintended outcome of the new rule will be that carriers making a significant investment in driver education and training will lose their incentive to continue because a large percentage of their graduates will be lost to competitors.

C.R. England (and other companies) are making a helluva lot of money with the students they train to be drivers. Their ROI is more than adequate. I'd be willing to bet that C.R. England makes in 1-2 runs what it costs them to train that driver. And once that debt is satisfied, everything else that truck makes, goes to the company. And the driver, working for the first 30 days/15K miles with the driver trainer and the next 60 days as team driver making 13 cents per mile, gets to gross maybe $400 to $600 per week, which is crap.  The company likely makes more than 10 times that amount on each load they pull. 

So can you see why people have some doubts about this exemption? Can you see why
I have doubts about the skill set these students are leaving the school with? They just don't have enough training to be allowed to drive without someone sitting next to them.

At the same time the FMCSA is working to implement minimum driver training standards for entry-level drivers of commercial motor vehicles, they're granting an exemption to a trucking company whose training for those very same entry-level drivers is severely lacking. Not to mention that company's already abysmal safety record.

On C.R. England's website, they have a page detailing 
what the students should expect when they're trained at C.R. England. Are you seeing the same thing I'm seeing?  Because this is what I'm seeing:

Of the 17 days they attend the school, they will spend the first seven days in the classroom. Let's keep in mind some of these people have never even seen a truck up close. Never been in one, never knew anyone who drove one, didn't even consider it as a job until the idea somehow presented itself.

17 days.  It's just not enough time.  They can't possibly learn enough.  They're not possibly safe enough.  And they absolutely don't know how to operate that vehicle in all seasons and all situations. 
C.R. England has been putting unqualified, unsafe drivers on the road for years.  They are pushed beyond their limits, with inadequate training, so the company can continue to make billions of dollars.

They want you to think they offer great training, which is why another page on their site contains reviews they've received on their training program and their company in general. There are nine cherry-picked reviews dating back to September 2014.  So in 10 months, they were able to pick out only nine good reviews.  If you were to go to the place where they got those reviews, you'll find a different story.  At, you'll see that C.R. England has over 270 reviews and lists 145 reviews.  Not all of them are glowing.

Since this post is primarily about inadequate training, let's go back for a minute to what the C.R. England Twitter author said just a little over two weeks ago:
To that I will say this: 

How much training, exactly, does someone need to NOT hit a building?

That's right. One of the C.R. England drivers who has proven they don't need any more training, HIT A BUILDING a little over a month ago.

Makes me wonder if the FMCSA knows how to Google.

~ ~ ~ ~ ~ ~ ~ ~ ~ ~
2014: The Value Of This Place Continues To Increase
2013: Bursts Of Light And A Bean
2012: Cool As A Cucumber
2011: I Think We Have A Winner
2010: Progressively Yours,
2009: Spill It
2008: I’ve NEVER Colored Inside The Lines. Why The Surprise?
2007: I Didn’t Make It, But I Ate It
2006: Sorry, no post for this day.
2005: Slim Or None! I’ll Take None.


Anonymous said...

LOVE glad you are pointing this issue out! well done and keep after 'em.

As the blog, keep up the great work, it is appreciated!

Best wishes from NY's Finger Lakes Region!

Belledog said...

You go, grrrrl!