Emergency PRA_ ApprenticeshipPilot_Supporting Statement A_01-06-22 wmb

Department of Transportation

Federal Motor Carrier Safety Administration

SUPPORTING STATEMENT – Part A

Safe Driver Apprenticeship Pilot Program

OMB Number 2126-TBD

SUMMARY

• The Federal Motor Carrier Administration (FMCSA) is seeking an emergency authorization for the following information collection request (ICR). Emergency authorization is necessary to establish a program within the deadline specified by law.

• This is a new ICR required by section 23022 of the Infrastructure Investment and Jobs Act (IIJA) that passed into law on November 15, 2021. Under section 23022, FMCSA must establish an apprenticeship pilot program for commercial motor vehicle (CMV) drivers no later than 60 days after the enactment of the IIJA; that is, no later than January 14, 2022.

• The agency is required to collect (1) data relating to any safety incident involving an apprentice participating in the Apprentice Pilot Program; (2) data relating to any safety incident involving a driver under the age of 21 operating a commercial motor vehicle in intrastate commerce; and (3) such other data relating to the safety of Apprentice Pilot Program participants aged 18 to 20 years operating in interstate commerce as the Secretary determines to be necessary.

• Information collection tools consist of (1) applications from motor carriers interested in participating in the apprentice pilot program, (2) driver information and consent forms for apprentice drivers, (3) driver information and consent forms for experienced drivers, (4) safety benchmark certifications participating carriers complete for each apprentice, and (5) monthly data submissions from participating motor carriers.

• The estimated annual burden for all respondents is 190,349 hours at a cost of $7,937,109.09.

INTRODUCTION

In accordance with the Paperwork Reduction Act (PRA) of 1995, the Federal Motor Carrier Safety Administration (FMCSA) is requesting the Office of Management and Budget (OMB) grant a 1-year emergency clearance for the new information collection entitled Safe Driver Apprenticeship Pilot Program. The collection of information is associated with the Infrastructure Investment and Jobs Act (IIJA) Section 23022 requirement to provide Congress a recommendation regarding whether the level of safety achieved by the pilot program is equivalent to, or greater than, the level of safety for equivalent commercial motor vehicle drivers aged 21 years or older. Once emergency approval is granted, FMCSA will seek OMB approval for the full 3-year period using the usual PRA approval process.

Part A. Justification

1. CIRCUMSTANCES THAT MAKE THE COLLECTION OF INFORMATION NECESSARY

Current regulations on driver qualifications (49 CFR part 391.11(b)(1)) (Attachment A) state that a driver must be 21 years of age or older to operate a CMV in interstate commerce. Currently, drivers under the age of 21 may operate CMVs only in intrastate commerce subject to State laws and regulations.

Section 23022 of the IIJA (Attachment B), requires the Secretary of Transportation to conduct a commercial driver apprenticeship pilot program. An “apprentice” is defined as a person under the age of 21 who holds a commercial driver’s license (CDL). Under this program, these apprentices will complete two probationary periods, during which they may operate in interstate commerce only under the supervision of an experienced driver in the passenger seat. An experienced driver is defined in Section 23022 as a driver who is not younger than 26 years old, who has held a CDL and been employed for at least the past 2 years, and who has at least 5 years of interstate CMV experience and meets the other safety criteria defined in the IIJA.

The first probationary period must include at least 120 hours of on-duty time, of which at least 80 hours are driving time in a CMV. To complete this probationary period, the employer must determine competency in:

1. Interstate, city traffic, rural 2-lane, and evening driving;

2. Safety awareness;

3. Speed and space management;

4. Lane control;

5. Mirror Scanning;

6. Right and left turns; and

7. Logging and complying with rules relating to hours of service.

The second probationary period must include at least 280 hours of on-duty time, including not less than 160 hours driving time in a CMV. To complete this probationary period, the employer must determine competency in:

1. Backing and maneuvering in close quarters;

2. Pre-trip inspections;

3. Fueling procedures;

4. Weighing loads, weight distribution, and sliding tandems;

5. Coupling and uncoupling procedures; and

6. Trip planning, truck routes, map reading, navigation, and permits.

After completion of the second probationary period the apprentice may begin operating CMVs in interstate commerce unaccompanied by an experienced driver.

In addition to data regarding successful completion of the probationary periods, the IIJA requires data collection for data relating to any incident in which a participating apprentice is involved as well as other data relating to the safety of apprentices. Additional data will include crash data (incident reports, police reports, insurance reports), inspection data, citation data, safety event data (as recorded by all safety systems installed on vehicles, to include advanced driver assistance systems, automatic emergency braking systems, onboard monitoring systems, and forward-facing and in-cab video systems) as well as exposure data (record of duty status logs, on-duty time, driving time, and time spent away from home terminal). These data will be submitted on a monthly basis through participating motor carriers.

The data collected will be used to report on the following items, as required by section 23022:

1. The findings and conclusions on the ability of technologies or training provided to apprentices as part of the pilot program to successfully improve safety;

2. An analysis of the safety record of participating apprentices as compared to other CMV drivers;

3. The number of drivers that discontinued participation in the apprenticeship program before completion;

4. A comparison of the safety records of participating drivers before, during, and after each probationary period; and

5. A comparison of each participating driver’s average on-duty time, driving time, and time spent away from home terminal before, during, and after each probationary period.

FMCSA will monitor the monthly data being reported by the motor carriers and will identify drivers or carriers that may pose a risk to public safety. While removing unsafe drivers or carriers may bias the dataset, it is a necessary feature for FMCSA to comply with 49 CFR 381.505 (Attachment C), which requires development of a monitoring plan to ensure adequate safeguards to protect the health and safety of pilot program participants and the general public. Knowing that a driver or carrier was removed from the pilot program for safety reasons will help FMCSA minimize bias in the final data analysis.

FMCSA and the Department of Labor’s Employment and Training Agency (DOL/ETA) will be partnering in the implementation of the Safe Driver Apprenticeship Pilot Program. All motor carriers who are approved for the program by FMCSA will also be required to become Registered Apprentices (RAs) under 29 CFR Part 29 (Attachment D) before they can submit information on their experienced drivers and apprentices. The information collection burden for the DOL/ETA RA Program can be found in approved ICR 1205-0223.

The statutory mandate for this pilot program is contained in Section 23022 of the Infrastructure Investment and Jobs Act (Attachment B). FMCSA’s regulatory authority for initiation of a pilot program is 49 CFR 381.400 (Attachment E). The Apprentice Pilot Program supports the USDOT strategic goal of economic strength while maintaining USDOT and FMCSA’s commitment to safety.

2. HOW, BY WHOM, AND FOR WHAT PURPOSE IS THE INFORMATION USED

   1. HOW INFORMATION WILL BE COLLECTED

Data will be collected from participating motor carriers and drivers via the following tools:

1. Each carrier will complete a one-time application form.

2. Each apprentice driver will complete a one-time application and informed consent form.

3. Each experienced driver will complete a one-time application and informed consent form.

4. Each carrier will submit a pair of one-time certifications for each of its apprentice drivers—one certification for each successfully completed probationary period.

5. Each carrier will submit monthly driving and safety data for each of its apprentice drivers.

All information collection will be electronic. The information or data to be collected via each tool is outlined in detail in the following sections.

1. Motor Carrier Application

In the application, motor carriers will be asked to provide company contact information, which includes the motor carrier name, U.S. Department of Transportation (USDOT) number, place of business address, and phone number. Additionally, motor carriers will be asked to provide the name and email address of a representative who will serve as the primary point of contact for the pilot program. This information will also be used to examine the safety records of the motor carrier applicants.

Motor carriers will then be asked to provide information on the scope and scale of their operations. This includes whether they are an interstate and/or intrastate carrier, their fleet size, the number of drivers they employ, how many apprentice drivers could be hired, how many intrastate drivers could be provided if they currently conduct intrastate operations, whether their trucks use onboard monitoring systems (OBMSs), how many apprentice drivers could be provided for the control group, and how many experienced drivers they have available. While the ideal pilot program would contain a variety of carrier sizes and operation types, there may be limitations on the carriers that are able to participate due to insurance costs for hiring young drivers, the ability of the motor carrier to gain recognition as an RA program, or other business decisions. FMCSA will be conducting outreach with various carrier types and sizes, but the final sample population will depend largely on which qualifying carriers choose to volunteer.

Carriers will also be asked to identify any safety technologies being used by their drivers, including Onboard Monitoring Systems (OBMS) or Advanced Driver Assistance Systems (ADAS). This will ensure compliance with technology and vehicle requirements during the probationary periods and streamline monthly data collection. The research team will require participating carriers to provide ELD logs and OBMS and/or ADAS recorded safety events on participating drivers. Carriers will be required to certify that they understand the requirements for drivers participating in the pilot program.

FMCSA will evaluate the motor carrier applications and approve participation based on safety records and, as applications permit, securing a diverse set of carriers. While participation in the study is voluntary, FMCSA will aim to have adequate representation from Large, Medium, and Small carriers. While FMCSA anticipates an estimated 3,000 carriers will be needed to supply the driver population necessary, in the event that an abundance of carrier applications are received, FMCSA may use additional data points, such as carrier size, to select which carriers to approve. It will be necessary to limit the number of participating carriers to logistically achieve data collection and ensure compliance with the program can be adequately monitored.

Once approved by FMCSA for participation in the pilot program, motor carriers then must become a RA in accordance with 29 CFR Part 29¹ and submit their RA number to FMCSA. The research team will work with those carriers to identify drivers who will be participating in the pilot program and ensure the necessary information and consent forms are received prior to beginning monthly data collection. To minimize burden on motor carriers, the research team will allow them to submit data in any file format that can be converted into a .csv file (e.g., Microsoft Excel, SQL) and any file format (.pdf, .doc, etc.) for text-based records, such as investigation reports or insurance reports. This may vary depending on what records the carrier already collects and the size of the carrier. All carriers will submit data electronically via a secure file-transfer site hosted by the performing contractor.

2. Driver Information Form

To ensure eligibility, motor carriers will be required to submit information on experienced drivers. The experienced driver information form will collect the following information:

• Driver’s name

• Driver’s CDL number

• Driver’s CDL State of issuance

• Driver’s date of birth (to calculate age)

• Driver’s gender

• Driver’s qualifications (e.g., manual or automatic transmission)

• Driver’s experience (years working as a CMV driver)

• Driver’s start date with the motor carrier and, if necessary, proof of employment at a previous motor carrier to cover the prior two-year period.

To ensure eligibility, motor carriers will be required to submit information on apprentice drivers. The apprentice driver information form will collect the following information:

• Driver’s name

• Driver’s CDL number

• Driver’s CDL State of issuance

• Driver’s date of birth (to calculate age)

• Driver’s gender

• Driver’s qualifications (e.g., manual or automatic transmission)

• Driver’s experience operating intrastate (if applicable)

• Driver’s prior training experience

• Driver’s hire date

• Driver’s current weekly averages, if applicable, for:

  1. On-duty time

  2. Driving time

  3. Time spent away from home terminal

As part of every application, both experienced and apprentice drivers must sign an informed consent form, approved by an Institutional Review Board (IRB), to participate in the pilot program. Personally identifiable information (PII) will be kept confidential and will not be included in the final analysis, final report, or any published document.

3. Probation Period Certification

Carriers must submit logs demonstrating each apprentice has met the on-duty and driving hour requirements for each probationary period, as well as certification that apprentices have met the required benchmarks. Carriers must report on a monthly basis each driver’s progress towards completing their set of probationary periods.

4. Driver Activity and Safety Data

As part of the apprentice pilot program, motor carriers will be asked to submit information on participating driver’s safety and exposure data on a monthly basis. This data will be collected from the point a driver enrolls in the pilot program until the driver turns 21 or chooses to leave the pilot program. These data will include, for each driver, miles and hours driven, time on duty, time away from home terminal, along with any safety critical events or other relevant information captured by the ELD and/or OBMS.

Carriers will also report USDOT-reportable crashes, moving violations, motorist incident reports, total number of inspections, inspection violations (e.g., hours-of-service violations, unsecured load violations), and, when possible, near-crashes and safety critical events (SCEs) that occurred during the reporting period.

In the event of a crash, motor carriers will be asked to include in their submittal the findings of their post-crash investigations and post-crash drug and alcohol tests, as required by the Title 49 U.S.C. Section 382.303, and the police accident report. The carrier will submit these documents in addition to the monthly data upload when applicable.

2. WHO WILL COLLECT THE INFORMATION

A qualified research team contracted by FMCSA will collect the motor carrier applications, driver information and informed consent forms, and monthly data submissions throughout the 3-year pilot program. The contractor will host and maintain a secure file-transfer site to receive data, as well as all any necessary databases to store files containing received data, analyses, and other items pertaining to the pilot program. Access to this data will be given to the authorized research team members and FMCSA research team members. The research team will work with a designated point of contact at each participating motor carrier to ensure all data are delivered in a timely manner throughout the study period.

3. PURPOSE OF THE INFORMATION COLLECTION EFFORT

The purpose of the data collection and the overall pilot program is to determine the potential impact of age, specialized apprentice training, safety technologies, and experience on driver safety. In particular, this program will provide insight into whether or not apprentice training can compensate for age-related influences on safety. It will also provide insight into whether 18- to 20-year-old individuals can operate CMVs at acceptable levels of safety after participating in supervised probationary periods. The information collected will be used to compare the safety outcomes of apprentices before, during, and after their probationary periods as well as a comparison of apprentices to carrier safety records prior to participating in the pilot program and the national crash and safety rates as calculated by existing FMCSA data, such as the Motor Carrier Management Information System (MCMIS).

As mandated by the IIJA, the information collected during this pilot program and the results will be submitted in a report to Congress. The program will also publish a report documenting the study and its findings.

In addition, the data collected may influence recommendations on what training and other requirements should be considered prior to any possible regulatory changes to driver qualifications, such as entry-level driver training or minimum age. This could have important implications for the motor carrier industry, as a driver shortage is often cited as a limiting factor in the ability of the motor carrier industry to meet demand.

3. EXTENT OF AUTOMATED INFORMATION COLLECTION

All data will be collected using a secure online file-transfer site. The carrier application, driver information form, and driver consent form will be one-time submissions. The probation period certification and monthly activity and safety data items will require the carrier to upload files every time they are submitted but will involve data already being collected via carriers’ OBMSs and ELDs.

4. EFFORTS TO IDENTIFY DUPLICATION

FMCSA conducted a review of previously conducted studies, related studies and surveys, and reports of Federal and non-Federal sources to minimize duplication of efforts, identify best practices of completed projects, identify statistical information that can be reused for the current pilot program, and minimize cost to the Government and taxpayers. None of the reviewed studies collected data on the safety performance of apprentice drivers as part of a pilot program, as is mandated by section 23022 the IIJA.

Some of the information a motor carrier will need to include in their initial application is duplicative of information collected as part of the DOL/ETA RA application. The duplication is limited to basic information such as the carrier’s name, address, and a POC, and to a list of apprentices included in an approved program. This duplication is a small fraction of the information included in either the FMCSA or DOL/ETA application and is limited to basic carrier information. FMCSA and DOL/ETA will be working together to share carrier reports to the extent feasible and thereby limit any additional duplication.

5. EFFORTS TO MINIMIZE THE BURDEN ON SMALL BUSINESSES

Participation in the pilot program by carriers is voluntary. Thus, only those carriers (large or small) that can safely and reasonably employ apprentice drivers in their operations will apply. The data collection plan is designed to minimize the level of data processing on behalf of carriers, which benefits smaller carriers that lack staff resources to support these tasks. By making OBMS and ELD data mandatory for participation, the program will use infrastructure and tools that qualifying carriers already possess. The burden for both large and small carriers has been minimized by requiring data that carriers already collect. The program has made an effort to minimize burden on small businesses by not requiring carriers to submit a minimum number of apprentices to participate in the pilot program and has not imposed requirements for safety technology above and beyond what is required by IIJA.

6. IMPACT OF LESS FREQUENT COLLECTION OF INFORMATION

Not collecting the requested data would result in the failure of FMCSA to fulfill the congressional mandate to conduct the Safe Driver Apprenticeship Pilot Program as required in Section 23022 of the IIJA.

Less frequent data collection throughout the pilot program would increase the opportunity for errors in data collection and hinder the ability of FMCSA to monitor and manage the operations of the participating motor carriers and drivers. FMCSA must specifically monitor the apprentice driver group over the course of the pilot program to determine whether their safety performance is significantly inferior to the control group and whether they pose a risk to public safety. If specific drivers pose a danger to public safety, FMCSA will remove them from the pilot program. Additionally, FMCSA will monitor carriers to determine if they are not submitting data or have a higher safety risk than other participating carriers. If that occurs with specific carriers, FMCSA will remove them from the pilot program. Reducing the frequency of data collection would degrade FMCSA’s ability to take these correction actions to protect the public.

7. SPECIAL CIRCUMSTANCES

None.

8. COMPLIANCE WITH 5 CFR 1320.8:

After OMB grants emergency approval, FMCSA will publish a 60-day notice for public comment and a 30-day notice in the Federal Register prior to requesting OMB’s full approval of this ICR, in accordance with 5 CFR 1320.8.

9. PAYMENTS OR GIFTS TO RESPONDENTS

No payments or gifts will be made to respondents.

10. ASSURANCE OF CONFIDENTIALITY

Consent forms provided to drivers will explain the ways in which their data will be used and which data will be anonymized. PII will be kept private to the extent possible under law. Data will be treated in a secure manner and will not be disclosed unless FMCSA is compelled by law. The contractor(s) that support the pilot program will sign nondisclosure agreements to ensure confidentiality. Participants’ PII will not be included in pilot program documents. All analysis will be conducted using de-identified data sets and no PII will be contained in the final report.

In accordance with USDOT’s policy on research involving human subjects, this pilot program will be reviewed and approved by an IRB prior to beginning data collection. This document will be updated with the date of approval once IRB review has been completed. The designated points of contact for the approved motor carriers who will recruit control group and apprentice drivers will receive IRB ethics training to ensure that the rights of the research subjects are protected.

11. JUSTIFICATION FOR THE COLLECTION OF SENSITIVE INFORMATION

Sensitive information is required to maintain safety throughout the Apprentice Pilot Program. One of the requirements of a pilot program is to ensure measures for maintaining safety throughout the program. This will be done by identifying participating drivers (using PII, such as a driver’s name and address) and recording information related to safety-related incidents. Participating drivers whose performance benchmarks poses a risk to public safety will be removed from the program. Furthermore, these sensitive data are required for analysis to enable FMCSA to identify and control possible confounding variables, ensuring the analysis is meaningful and the program’s results useful to promoting public safety.

12. ESTIMATE OF BURDEN HOURS FOR INFORMATION REQUESTED

The burden hours associated with this information collection are incurred by three groups: motor carriers, apprentice drivers, and experienced drivers. Motor carriers will incur the largest burden while submitting data monthly. Apprentice and experienced drivers will only need to submit the application forms. Subsequent data on participating apprentice drivers will be submitted by the motor carrier on their behalf.

FMCSA estimates that up to 3,000 motor carriers will be participating in the pilot program at any given time. The motor carrier burden is associated with completing the application to participate in the pilot program (IC-1), certifying safety benchmark performance for apprentice drivers (IC-4), and submitting the monthly driver activity and safety data information (IC-5), including OBMS and ELD logs, ADAS data, and post-crash investigations when applicable (IC-5a). Motor carriers will also need to interact with the research team to notify them within 24 hours of any injury or fatality crashes, if a driver chooses to leave the pilot program (or has left the carrier), if a participant receives an alcohol-related citation (such as driving under the influence or driving while intoxicated), or if a participating driver fails a random or post-crash drug/alcohol test (IC-5b).

It is assumed that for motor carriers, first line supervisors of drivers, or an equivalent position, will be submitting data. The mean hourly wage of first-line supervisors of transportation and material-moving workers for the truck transportation industry (North American Industry Classification System [NAICS] code 484000), $29.79, is taken from the Bureau of Labor and Statistics (BLS) May 2021 National Industry-Specific Occupational Employment and Wage Estimates.²

To arrive at a loaded wage, we first calculate the load factor by dividing the total cost of compensation for private industry workers of the trade, transportation, and utilities industry by the average cost of hourly wages and salaries as reported by the BLS in its Employer Costs for Employee Compensation for June 2021 ($31.32 total compensation cost / $22.24 wage and salary = 1.408).⁽³⁾ Multiplying median hourly wage for first-line supervisors of transportation and material-moving workers by the load factor results in a loaded wage hourly cost of $41.94 ($29.79 x 1.408 = $41.94), as shown in Table 1.

Table 1. Estimated wage and compensation of first-line supervisors.

Occupation	BLS Occupation Code	NAICS Occupational Designation	Mean Hourly Wage	Load Factor	Hourly Compensation Cost
First Line Supervisors of Transportation and Material-Moving Workers	53-1040	Truck Transportation (484000)	$29.79	1.408	$41.94

It is assumed that both apprentice and experienced drivers correspond to heavy and tractor-trailer truck drivers from the BLS Occupational Employment Statistics. This occupation has a mean hourly wage of $23.42 for the truck transportation industry (NAICS code 484000) according to the June 2021 National Industry-Specific Occupational Employment and Wage Estimates.(⁴) Multiplying mean hourly wage for heavy and tractor-trailer truck drivers in the truck transportation industry by the previously calculated load factor results in a loaded hourly wage of $31.91, as shown in Table 2.

Table 2. Estimated wage and compensation of participating truck drivers.

Occupation	BLS Occupation Code	NAICS Occupational Designation	Mean Hourly Wage	Load Factor	Hourly Compensation Cost
Heavy and Tractor-Trailer Truck Drivers	53-3032	Truck Transportation (484000)	$22.66	1.408	$31.91

The estimated number of respondents varies by the individual Information Collection (IC) piece, as carriers and drivers will apply for participation (IC-1, IC-2, and IC-3) but will ultimately not be accepted into the program. IC-4 and IC-5 will only be collected on those accepted into the pilot program. The number of anticipated respondents per IC are shown in Table 3.

Table 3. Number of respondents by type of IC and year of collection.

IC Item	Respondent Type	Year 1	Year 2	Year 3	Total	Annual Average
IC-1: Motor Carrier Application	Motor Carriers	3,500	500	500	4,500	1,500
IC-2: Apprentice Driver Application	Apprentice Drivers	12,200	12,000	9,000	33,200	11,067
IC-3: Experienced Driver Application	Experienced Drivers	6,300	945	945	8,190	2,730
IC-4: Safety Performance Benchmarks	Motor Carriers	3,000	3,000	3,000	9,000	3,000
IC-5a: Recurring Monthly Data Submissions	Motor Carriers	3,000	3,000	3,000	9,000	3,000
IC-5b: Miscellaneous Monthly Data Submissions	Motor Carriers	3,000	3,000	3,000	9,000	3,000

The burden hours associated with each IC are shown in Table 4.

Table 4. Burden hours associated with each IC by respondent type.

IC Item	Motor Carriers	Apprentice Drivers	Experienced Drivers	Total	Annual Average
IC-1: Motor Carrier Application	1,500 hours	n/a	n/a	1,500 hours	500 hours
IC-2: Apprentice Driver Application	n/a	11,067 hours	n/a	11,067 hours	3,689 hours
IC-3: Experienced Driver Application	n/a	n/a	2,730 hours	2,730 hours	910 hours
IC-4: Safety Performance Benchmarks	15,750 hours	n/a	n/a	15,750 hours	5,250 hours
IC-5a: Recurring Monthly Data Submissions	378,000 hours	n/a	n/a	378,000 hours	126,000 hours
IC-5b: Miscellaneous Monthly Data Submissions	162,000 hours	n/a	n/a	162,000 hours	54,000 hours
Total	557,250 hours	11,067 hours	2,730 hours	571,047 hours	190,349 hours
Annual Average	185,750 hours	3,689 hours	910 hours	190,349 hours

Utilizing the loaded wage rates show in Table 1 and Table 2, the calculated costs to respondents are shown in Table 5.

Table 5. Costs to respondents associated with each IC in the pilot program.

IC Item	Motor Carrier	Apprentice Drivers	Experienced Drivers	Total Burden	Average Annual Burden
IC-1: Motor Carrier Application	$ 62,910.00	n/a	n/a	$ 62,910.00	$ 20,970.00
IC-2: Apprentice Driver Application	n/a	$ 353,147.97	n/a	$ 353,147.97	$ 117,715.99
IC-3: Experienced Driver Application	n/a	n/a	$ 87,114.30	$ 87,114.30	$ 29,038.10
IC-4: Safety Performance Benchmarks	$ 660,555.00	n/a	n/a	$ 660,555.00	$ 220,185.00
IC-5a: Recurring Monthly Data Submissions	$ 15,853,320.00	n/a	n/a	$ 15,853,320.00	$ 5,284,440.00
IC-5b: Miscellaneous Monthly Data Submissions	$ 6,794,280.00	n/a	n/a	$ 6,794,280.00	$ 2,264,760.00
Total	$ 23,371,065.00	$ 353,147.97	$ 87,114.30	$ 23,811,327.30	$ 7,937,109.09
Annual Average	$ 7,790,355.00	$ 117,715.99	$ 29,038.10	$ 7,937,109.09

Estimated Total Annual Burden by Respondent:

• Carriers: The average annual burden for all participating motor carriers is 185,750 hours, or 61.9 hours per carrier.

• Apprentice Drivers: The average annual burden for all apprentice drivers is 3,689 hours, or 0.33 hours per driver.

• Experienced Drivers: The average annual burden for all experienced drivers is 910 hours, or 0.33 hours per driver.

Estimated Annualized Cost of Burden Hours by Respondent:

• Carriers: The average annual cost for all participating motor carriers is $7,790,355.00, or $2,596.79 per carrier.

• Apprentice Drivers: The average annual cost for all apprentice drivers is $117,715.99, or $10.64 per driver.

• Experienced Drivers: The average annual cost for all experienced drivers is $29,038.10, or $22.66 per driver.

The average annual burden for all respondents is 190,349 hours at a cost of $7,937,109.09.

1. IC-1: Motor Carrier Application

It is anticipated that not all motor carriers who apply for the program will be accepted into the program. Furthermore, it is expected that the majority of carriers will apply during year 1, however, additional carriers may be added during years 2 and 3 due to carriers leaving the pilot program or being removed. Therefore, during the first year, FMCSA expects 3,500 motor carriers to spend approximately 20 minutes completing the one-time motor carrier application, resulting in a total of 3,000 carriers being accepted into the program. FMCSA is estimated that an additional 500 carriers will apply in year two and in year three. No more than 3,000 carriers are expected to participate at any given time during the program due to considerations with monitoring and data collection.

The burden for a motor carrier to complete the application is a one-time response of 20 minutes per respondent. Every motor carrier that applies will incur this one-time cost, estimated to be $13.97 ($41.94 hourly compensation x 20 minutes to complete application = $13.97). The total cost for 4,500 carriers to apply is estimated to be $62,910.00, or $20,970.00 annually over the 3-year pilot program, as shown in Table 3.

Table 6. IC-1: Motor carrier burden hours and cost for motor carrier application; one response per respondent, 20 minutes per response, with an average loaded hourly wage rate of $41.94.

Year	Number of Respondents (a)	Total Number of Responses (b) = (a) x 1	Total Burden Hours (0.33 hours per response) (c) = (b) x 0.33 hours	Total Respondent Labor Cost (average loaded hourly rate of $41.94) (d) = (c) x $41.94
Year 1	3,500	3,500	1,000	$41,940.00
Year 2	500	500	200	$8,388.00
Year 3	500	500	200	$8,388.00
Total	4,500	4,500	1,500	$62,910.00
Annual Average	1,500	1,500	500	$20,970.00

2. IC-2: Apprentice Driver Application and Informed Consent Form

FMCSA anticipates 3,200 apprentice drivers will apply for the pilot program in the first three months, with 3,000 being approved to participate. As drivers turn 21, drop out of the program, or are removed f, additional drivers will be added to the programconcerns the program due to safety rom, such that no more than 3,000 apprentices are participating in the pilot program at any given time. For purposes of this emergency approval request, FMCSA is using larger numbers of apprentices; the agency will update these numbers in its subsequent PRA request for the full 3-year approval period.

FMCSA is estimating a 15% turnover rate in drivers choosing to leave the program, and assuming that 5% of drivers will age out of the program every month and an additional 5% of drivers need more than 3 months to graduate their apprentice program, leading to a gradual increase of drivers as shown in Table 4. Additionally, FMCSA is estimated 5% of drivers will apply and not be accepted into the program, and that applications for apprentice drivers will slow down and gradually end as the pilot program comes to a close in the third year. It is estimated that a total of 33,200 drivers will apply to participate as apprentices over the 3-year program, or 11,067 annually.

Table 7. Number of apprentices expected to participate and apply throughout the pilot program, by year.

Year	Number of apprentices at onset (a)	Number of new apprentices throughout year (b)	Number of apprentices leaving or aging out of program throughout year (c)	Number of apprentices at completion (d) = (a) + (b) – (c)	Total number of applications (e) = (b)*1.05
Year 1	0	11,550	2,400	9,150	12,200
Year 2	8,500	11,400	2,400	17,500	12,000
Year 3	12,000	8,550	2,400	18,150	9,000
Total	n/a	33,200	7,200	n/a	33,200
Annual Average	n/a	11,067	2,400	n/a	11,067

The burden for a participating apprentice driver to complete the application and sign an informed consent form is a one-time response of 20 minutes per respondent. Every apprentice driver that applies will incur this one-time cost, estimated to be $10.64 ($31.91 hourly compensation x 20 minutes to complete application = $10.64). The total cost for 33,200 apprentice drivers to apply is estimated to be $353,147.97, or $117,715.99 annually over the 3-year pilot program, as shown in Table 5.

Table 8. IC-2: Apprentice drivers’ burden hours and cost for driver application and informed consent form; one response per respondent, 20 minutes per response, with an average loaded hourly wage rate of $31.91.

Year	Number of Respondents (a)	Total Number of Responses (b) = (a) x 1	Total Burden Hours (0.33 hours per response) (c) = (b) x 0.33 hours	Total Respondent Labor Cost (average loaded hourly rate of $31.91) (d) = (c) x $31.91
Year 1	12,200	12,200	4,067	$129,777.97
Year 2	12,000	12,000	4,000	$127,640.00
Year 3	9,000	9,000	3,000	$95,730.00
Total	33,200	33,200	11,067	$353,147.97
Annual Average	11,067	11,067	3,689	$117,715.99

3. IC-3: Apprentice Driver Application and Informed Consent Form

FMCSA will need an experienced driver enrolled for every apprentice operating under a probationary period. These drivers will accompany apprentice drivers from the passenger seat until an apprentice has satisfactorily demonstrated their second set of performance benchmarks. FMCSA anticipates needing 6,000 experienced drivers to participate throughout each year, as not all experienced drivers will be participating at the same time due to their own schedule limitations. FMCSA is anticipating a turnover rate of 15% for experienced drivers who may leave the company or become ineligible to participate. Additionally, FMCSA anticipates 5% of experienced drivers who apply may not be qualified to serve as an experienced driver. Therefore, FMCSA expects 6,300 experienced drivers to apply in year 1, and 945 experienced drivers to apply in years 2 and 3.

The burden for an experienced driver to complete the application is a one-time response of 20 minutes per respondent. Every experienced driver that applies will incur this one-time cost, estimated to be $10.64 ($31.91 hourly compensation x 20 minutes to complete application = $10.64). The total cost for 2,730 experienced drivers to apply is estimated to be $87,114.30, or $29,038.10 annually over the 3-year pilot program, as shown in Table 6.

Table 9. IC-3: Experienced drivers’ burden hours and cost for experienced driver application; one response per respondent, 20 minutes per response, with an average loaded hourly wage rate of $31.91.

Year	Number of Respondents (a)	Total Number of Responses (b) = (a) x 1	Total Burden Hours (0.33 hours per response) (c) = (b) x 0.33 hours	Total Respondent Labor Cost (average loaded hourly rate of $31.91) (d) = (c) x $31.91
Year 1	6,300	6,300	2,100	$67,011.00
Year 2	945	945	315	$10,051.65
Year 3	945	945	315	$10,051.65
Total	8,190	8,190	2,730	$87,114.30
Annual Average	2,730	2,730	910	$29,038.10

4. IC-4: Performance Benchmark Certifications

Participating motor carriers will need to submit a performance benchmark certification twice for each participating apprentice drivers. These forms will certify that an apprentice has successfully demonstrated the performance benchmarks required by the IIJA after each probationary period. It is anticipated that each form will take no more than 15 minutes to complete.

Every motor carrier will experience a different cost depending upon the number of apprentices employed by each driver. Two responses must be submitted per driver, for an estimated cost of $20.97 per driver ($41.94 hourly compensation x 15 minutes x 2 = $20.97). The cost across all participating motor carriers is estimated to be $660,555.00 or $220,185.00 annually over the 3-year pilot program, as shown in Table 7.

Table 10. IC-4: Motor carriers’ burden hours and cost for submitting performance benchmark certifications; two responses per driver, 15 minutes per response, with an average loaded hourly wage rate of $41.94.

Year	Number of Respondents (all participating motor carriers) (a)	Total Number of Responses (2x per driver) (b)	Total Burden Hours (0.25 hours per response) (c) = (b) x 0.25 hours	Total Respondent Labor Cost (average loaded hourly rate of $41.94) (d) = (c) x $41.94
Year 1	3,000	23,100	5,775	$242,203.50
Year 2	3,000	22,800	5,700	$239,058.00
Year 3	3,000	17,100	4,275	$179,293.50
Total	9,000	63,000	15,750	$660,555.00
Annual Average	3,000	21,000	5,250	$220,185.00

5. IC-5: Monthly Driving and Safety Data

Participating motor carriers will need to submit monthly data on all apprentice drivers throughout their participation in the pilot program. Carriers will submit monthly data on apprentice drivers until they turn 21 years of age, leave the carrier, are removed from, or choose to leave the pilot program (in which case they can no longer operate in interstate commerce).

There are two components to IC-5, which are IC-5a: recurring monthly data and IC-5b: miscellaneous monthly data submissions. For both of these submissions, motor carriers will need to compile data from their existing records and submit the data via a secure upload to the research team.

IC-5a, recurring monthly data, will contain the required driver activity and safety data, as described in Section 2(a)(iv). It is expected that the regular, recurring monthly data will take 60 hours per participating apprentice driver. Every motor carrier will experience a different cost depending upon the number of apprentices employed by each driver. Monthly data must be submitted per driver, for an estimated cost of $41.94 per driver ($41.94 hourly compensation x 1 hour = $41.94). The cost across all participating motor carriers is estimated to be $15,853,320.00 or $5,284,440.00 annually over the 3-year pilot program, as shown in Table 8.

Table 11. IC-5a: Motor carriers’ burden hours and cost for submitting monthly driver activity and safety data on apprentices; one response per apprentice per month, 1 hour per response, with an average loaded hourly wage rate of $41.94.

Year	Number of Respondents (all participating motor carriers) (a)	Total Number of Responses (12x per driver) (b)	Total Burden Hours (0.25 hours per response) (c) = (b) x 1 hours	Total Respondent Labor Cost (average loaded hourly rate of $41.94) (d) = (c) x $41.94
Year 1	3,000	138,600	138,600	$ 5,812,884.00
Year 2	3,000	136,800	136,800	$ 5,737,392.00
Year 3	3,000	102,600	102,600	$ 4,303,044.00
Total	9,000	378,000	378,000	$ 15,853,320.00
Annual Average	3,000	126,000	126,000	$ 5,284,440.00

IC-5b, miscellaneous monthly submissions will cover the need for carriers to report certain items to the research team within 24 hours of being made aware of the event, which may include events such as an apprentice being involved in an injury or fatality crash, an apprentice leaving the carrier or the program, or an apprentice receiving a drug or alcohol related citation (among others). Additionally, carriers may be asked to provide supplemental or clarifying data on the previous month’s activities if there are gaps or missing data. It is expected that each carrier will incur no more than 1.5 additional hours per month on these miscellaneous items. Every motor carrier is expected to incur this maximum additional cost once per month, estimated at $62.91 per carrier ($41.94 hourly compensation x 1.5 hours = $62.91). The cost across all participating motor carriers is estimated to be $754,920.00 or $251,640.00 annually over the 3-year pilot program, as shown in Table 9.

Table 12. IC-5b: Motor carriers’ burden hours and cost for submitting additional miscellaneous monthly data; one response per carrier, per month, 1.5 hours per response, with an average loaded hourly wage rate of $41.94.

Year	Number of Respondents (all participating motor carriers) (a)	Total Number of Responses (b) = (a) x 12	Total Burden Hours (1 hour per response) (c) = (b) x 1.5 hours	Total Respondent Labor Cost (average loaded hourly rate of $41.94) (d) = (c) x $41.94
Year 1	3,000	36,000	54,000	$ 2,264,760.00
Year 2	3,000	36,000	54,000	$ 2,264,760.00
Year 3	3,000	36,000	54,000	$ 2,264,760.00
Total	9,000	108,000	162,000	$ 6,794,280.00
Annual Average	3,000	36,000	54,000	$ 2,264,760.00

Estimated Number of Respondents:

IC-1: 4,200 motor carriers over the course of the study

IC-2: 30,000 apprentice drivers over the course of the study

IC-3: 4,200 motor carriers over the course of the study

IC-4: 4,200 motor carriers over the course of the study

IC-5: 12,000 experienced drivers over the course of the study

Estimated Total Annual Burden by Respondent:

Carriers: The average annual burden for all participating motor carriers is 238,467 hours per year, or 79.5 hours per carrier per year.

Apprentice Drivers: The average annual burden for all participating apprentice drivers is 10,000 hours per year, or 0.33 hours per apprentice total (apprentices complete their paperwork only once).

Experienced Drivers: The average annual burden for all participating experienced drivers is 10,000 hours per year, or 0.33 hours per experienced driver total (experienced drivers complete their paperwork only once).

Estimated Annualized Cost of Burden Hours by Respondent:

Carriers: The average annual cost for all participating motor carriers is $10,001,292.00 per year, or $3,333.76 per carrier per year.

Apprentice Drivers: The average annual cost for all participating apprentice drivers is $106,355.67 per year, or $10.64 per apprentice total (apprentices complete their paperwork only once).

Experienced Drivers: The average annual burden for all participating experienced drivers is 1,333 hours or 0.33 hours per experienced driver total (experienced drivers complete their paperwork only once).

13. ESTIMATE OF TOTAL ANNUAL COSTS TO RESPONDENTS

Participating motor carriers will incur additional burden under the approved information collection for the Department of Labor’s RA program.

14. ESTIMATE OF COST TO THE FEDERAL GOVERNMENT

The Government will need to procure a research contract for this effort to collect and analyze the data, as the Government lacks the personnel resources and expertise required to complete this study without contract support. It is estimated that this contract effort will cost between $6M and $7.5M. The exact costs will be updated when full OMB approval is sought.

Staff costs to the Government will include 15 percent of full-time hours for two GS-14s and one GS-13. Assuming mid-level steps within grade and the Washington, D.C. adjustments, this represents a yearly cost of $59,287.20 [15 percent x ($117,516 + $138,866 + $138,866) = $59,287.20].

As Government staff support will be required for 4 years, this adds up to a total program cost to the Government of $237,148.80.

There are no additional costs to the Government, as all employees working on this program are within their normal position duties and there is no anticipated travel or overtime associated with this program.

15. EXPLANATION OF PROGRAM CHANGES OR ADJUSTMENTS

This is a new information collection.

16. PUBLICATION OF RESULTS OF DATA COLLECTION

Safety performance data (and the limited demographic data required for context) will be analyzed and integrated into the apprentice pilot program report. Data collection will be completed within 120 days of the end of the apprentice pilot program period, followed by a statistical analysis and a final report detailing the analysis. Both descriptive and analytical methods will be employed during the data analysis. Statistical methods, such as regression and hypothesis testing, will be adopted when appropriate. The results of the pilot program will be documented in a technical report that will be delivered to and maintained by FMCSA. This report will be made available to the public on the FMCSA Web site, at www.fmcsa.dot.gov. The contents of the technical report will contribute to the report that FMCSA is required to provide to Congress pursuant to Section 23022 of the IIJA.

17. APPROVAL FOR NOT DISPLAYING THE EXPIRATION DATE OF OMB APPROVAL

FMCSA is not seeking an exemption from displaying the expiration date on the information collection forms.

18. EXCEPTIONS TO CERTIFICATION STATEMENT

None.

19. Attachments

1. 49 CFR part 391.11(b)(1)

2. IIJA, Section 23022

3. 49 CFR 381.505

4. 29 CFR Part 29

5. 49 CFR 381.400

6. Draft Motor Carrier Application.

7. Draft Experienced Driver Information Form.

8. Draft Apprentice Driver Application.

9. Safety Benchmark Certification – Probation Period 1.

10. Safety Benchmark Certification – Probation Period 2.

11. Federal Register Notice.

20. References

Costello, B., and Suarez, R. (2020). Truck Driver Shortage Analysis. American Trucking Associations.

Massie, D. et al. 1995. Traffic Accident Involvement Rates by Driver Age and Gender. Accident Analysis and Prevention 27(1), pp. 73-87.

Knipling, R. et al. 2004. Individual Differences and the “High-Risk” Commercial Driver Transportation Research Board, Washington, DC.

Federal Motor Carrier Safety Administration. (1975). Minimum Age Requirements of the Federal Motor Carrier Safety Regulations.

National Transportation Safety Board. (2002). Safety Report: Analysis of Intrastate Trucking Operations.

Blower, D.F. (1996). The Accident Experience of Younger Truck Drivers. University of Michigan Transportation Research Institute.

Campbell, K.L. (1991). Fatal Accident Involvement Rates by Driver Age for Large Trucks. Accident Analysis and Prevention 23 (4), pp. 287-295.

1 Some motor carriers may already be approved as having Registered Apprenticeship programs. These carriers will be able to skip this step and proceed directly to identifying drivers, as discussed below.

2 Bureau of Labor Statistics. Occupational Employment Statistics, May 2021 National Industry-Specific Occupational Employment and Wage Estimates: NAICS 484000 – Truck Transportation, https://www.bls.gov/oes/2020/may/naics3_484000.htm , Accessed December 13, 2021.

3 Bureau of Labor Statistics. “Employer costs per hour worked for employee compensation of private industry workers, by industry, June 2021.” https://www.bls.gov/news.release/pdf/ecec.pdf . Accessed December 13, 20201.

4 Bureau of Labor Statistics. Occupational Employment Statistics, Occupational Employment and Wages – May 2019, 53-3032 Heavy and Tractor-Trailer Truck Drivers, https://www.bls.gov/oes/current/oes533032.htm, Accessed August 28, 2020.

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