Assessment of Potential Benefits and 

Costs of Revising Brake Inspection 

Procedures and Certifying Brake 

Technicians 

Final Report 

SEPTEMBER 2006
Technical Report Documentation Page 

1. Report No. 

FMCSA-PSV-07-001 

2. Government Accession No. 3. Recipient's Catalog No. 

4. Title and Subtitle: 

Assessment of Potential Benefits and Costs of Revising Brake Inspection Procedures and 

Certifying Brake Technicians 

5. Report Date: 

 September 2006 

7. Author(s): 6. Performing Organization Code 

Mark Lepofsky, Patrick Balducci, Arthur Greenberg, Steven Shaffer 

Contributors: Amy Stewart (Battelle); Daniel Murray (American Transportation Research 

Institute); Carl Kirk and Robert Braswell (American Trucking Associations’ Technology and 

Maintenance Council); Steven Keppler and Collin Mooney (Commercial Vehicle Safety 

Alliance) 

8. Performing Organization Report No.

9. Performing Organization Name and Address: 10. Work Unit No. 

Battelle Memorial Institute 

505 King Avenue 

Columbus, OH 43201

11. Contract or Grant No. 

DTMC75-04-P-00071 Task Order #1 and DTMC75-

06-P-00012 

13. Type of Report and Period Covered 

Final Report 

February 2005 – July 2006

12. Sponsoring Agency Name and Address: 

Department of Transportation 

Federal Motor Carrier Safety Administration 

400 Seventh Street, SW 

Washington, DC 20590 

14. Sponsoring Agency Code 

FMCSA 

15. Supplementary Notes: Contracting Officer’s Technical Representative: Deborah M. Freund

16. Abstract: 

As a result of a fatal truck-bus accident in May 2001, the National Transportation Safety Board (NTSB) issued recommendations to the U.S. Department 

of Transportation’s Federal Motor Carrier Safety Administration (FMCSA). 

 

This project was designed to address NTSB’s concerns and to assist the FMCSA in: (1) estimating the time and level of training required for commercial 

motor vehicle (CMV) drivers to conduct pre-trip inspections of sufficient depth to discover defects or deficiencies that were not corrected by a certified 

brake technician, and (2) estimating the potential benefits and costs of implementing the NTSB’s recommendation to establish Federal testing and 

certification requirements for persons who inspect CMV brakes. 

The work performed for the study involved conducting a literature review, collecting data, and interviewing and collecting information and data from 

stakeholders. All information obtained was examined and fed into safety and economic models to determine the potential benefits and costs that could 

be expected from implementation of the NTSB recommendations. 

An assessment of the driver training and pre-trip inspection recommendation failed to produce net benefits under any of the scenarios considered. The 

driver training and pre-trip inspection recommendation produced benefit-cost ratios ranging from 0.07 (50 percent ratio of effectiveness, 200-mile 

average trip) to 0.55 (80 percent program effectiveness, 400-mile average trip). 

The brake inspector and certification recommendation, on the other hand, produced large net benefits, with benefit-cost ratios exceeding 12.65 in all 

scenarios considered in this study. The BCRs ranged from a low of 12.65 (50 percent program effectiveness, 200-mile average trip) to 29.27 (90 percent 

program effectiveness, 400-mile average trip). 

From this analysis, it appears that implementing the NTSB recommendation on certification of brake inspectors would create net benefits (benefits 

exceeding costs) and should be pursued. However, the NTSB recommendation on pre-trip brake inspections performed by drivers does not appear to be 

worthy of implementation.

17. Key Words: 

Air Brakes, Brake Inspection, Brake Maintenance, Brake Technician Training and 

Certification, Commercial Motor Vehicle 

18. Distribution Statement

19. Security Classif. (of this report) 

 Unclassified 

20. Security Classif. (of this page) 

 Unclassified 

21. No. of Pages: 

 76 

22. Price 

 N/A 

Form DOT F 1700.7
Assessment of Potential Benefits and Costs of i Final Report 

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Certifying Brake Technicians 

Table of Contents 

Page

LIST OF ABBREVIATIONS AND ACRONYMS ...................................................................iii

EXECUTIVE SUMMARY .................................................................................................... ES-1

1. INTRODUCTION ............................................................................................................ 1-1

1.1 Project Description..................................................................................................... 1-1 

1.2 Project Methodology.................................................................................................. 1-1 

1.2.1 Literature Search and Data Gathering............................................................ 1-2 

1.2.2 Stakeholder Interviews–Brake Condition and Maintenance as 

Crash Factors ................................................................................................. 1-2 

1.2.3 Stakeholder Interviews–Training, Testing, and Certification Programs ....... 1-2 

1.2.4 Safety Analyses.............................................................................................. 1-2 

2. LITERATURE SEARCH AND DATA GATHERING ................................................ 2-1

2.1 Overview.................................................................................................................... 2-1 

2.2 Estimating Prevention and Mitigation of Crashes and OOS Violations.................... 2-2 

2.3 Need for Better Driver/Brake Technician Training and Inspection........................... 2-6 

2.4 Training and Certification Programs ......................................................................... 2-7 

2.5 Economic Analysis .................................................................................................... 2-8 

3. STAKEHOLDER INTERVIEWS–BRAKE CONDITION AND 

MAINTENANCE AS CRASH FACTORS .................................................................... 3-1

3.1 Approach.................................................................................................................... 3-1 

3.2 Stakeholder Input Regarding Brake-related CMV Crashes....................................... 3-2 

3.2.1 Brake-related Crashes .................................................................................... 3-2 

3.2.2 Preventable Brake-related Crashes ................................................................ 3-4 

3.2.3 Additional Comments from Motor Carriers .................................................. 3-5 

3.2.4 Values to be Used in Economic Analysis...................................................... 3-5 

4. STAKEHOLDER INTERVIEWS–TRAINING, TESTING, AND 

CERTIFICATION PROGRAMS ................................................................................... 4-1

4.1 Approach.................................................................................................................... 4-1 

4.2 Stakeholder Input Regarding the Impact, Cost and Implementation Feasibility 

of the NTSB Recommendations ................................................................................4-3 

4.2.1 Driver Inspection ........................................................................................... 4-3 

4.2.2 Training and Certification of Brake Inspectors .............................................4-8 

4.2.3 Safety and Economic Impacts on Brake-related Crashes ............................ 4-12 

5. SAFETY ANALYSES ...................................................................................................... 5-1

5.1 Background Crash Data for Benefits Assessment ..................................................... 5-1 
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Table of Contents (Continued) 

Page

5.2 Benefits Assessment .................................................................................................. 5-2 

5.2.1 Safety Impacts................................................................................................ 5-3 

5.2.2 Out-of-Service (OOS) Violation Impacts .................................................... 5-10 

5.2.3 Impacts on Citations involving Monetary Penalties .................................... 5-13 

5.3 Costs Assessment..................................................................................................... 5-14 

5.3.1 Training, Testing, and Certification Costs................................................... 5-15 

5.3.2 Inspection Costs........................................................................................... 5-19 

5.4 Benefit-cost Analysis............................................................................................... 5-22 

APPENDIX A. REFERENCES 

APPENDIX B. ADDITIONAL ANNOTATED REFERENCES 

List of Tables

Table ES-1. Benefit-cost Analysis Findings (Alternative Scenarios)....................................... ES-3 

Table 3-1. Respondent Profile................................................................................................... 3-2 

Table 3-2. Estimates of the Percentage of Brake-related Crashes ............................................ 3-3 

Table 3-3. Estimates of the Percentage of Preventable Brake-related Crashes......................... 3-4 

Table 4-1. Respondent Profile................................................................................................... 4-2 

Table 4-2. Responses on Driver Training Class Time for Brake Inspection ............................ 4-7 

Table 4-3. Responses on Driver Training Class Structure ........................................................ 4-7 

Table 4-4. Responses on Brake Inspector Training Class Time ............................................... 4-9 

Table 4-5. Responses on Brake Inspector Training Class Structure ....................................... 4-10 

Table 5-1. Distribution of Crashes among Brake Problem Categories in the LTCCS.............. 5-5 

Table 5-2. Examination of Brake Safety ................................................................................... 5-6 

Table 5-3. Benefits Associated with Avoided Crash Costs..................................................... 5-11 

Table 5-4. Non-crash Vehicle Inspections and Number of OOS Brake Violations................5-12 

Table 5-5. Training Cost Assumptions.................................................................................... 5-17 

Table 5-6. Driver and Technician Training Courses and Associated Fees ............................. 5-18 

Table 5-7. Number of Axles on Single-unit and Combination Trucks ................................... 5-19 

Table 5-8. VIUS Percentage of Trucks Based on Range of Operation...................................5-20 

Table 5-9. Percentage of Trucks Based on Range of Operation ............................................. 5-20 

Table 5-10. Benefit-cost Analysis Findings 

(Average Trips by CMV Assumed to be 200 miles) ............................................. 5-23 

Table 5-11. Benefit-cost Analysis Findings 

(Average Trips by CMV Assumed to be 400 miles) ............................................. 5-23 

Table 5-12. Benefit-cost Analysis Findings 

(Alternative Scenarios) .......................................................................................... 5-24 

List of Figures

Figure 5-1. Data Elements Combined to Determine Societal Benefit-cost Ratios..................... 5-2 
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LIST OF ABBREVIATIONS AND ACRONYMS

ASE (National Institute for) Automotive Service Excellence 

ATA American Trucking Associations 

ATRI American Transportation Research Institute 

BCA benefit-cost analysis 

BCR benefit-cost ratio 

BLS Bureau of Labor Statistics 

BTS Bureau of Transportation Statistics 

CASE Continuing Automotive Service Education 

CFR Code of Federal Regulations 

CMV commercial motor vehicle 

CVSA Commercial Vehicle Safety Alliance 

DOT Department of Transportation 

FACT Fatal Accident Complaint Team 

FARS Fatality Analysis Reporting System 

FHWA Federal Highway Administration 

FMCSA Federal Motor Carrier Safety Administration 

FMCSR Federal Motor Carrier Safety Regulation 

FTA Federal Transit Administration 

GES General Estimation System 

IVBSS Integrated Vehicle Based Safety System 

NHTSA National Highway Traffic Safety Administration 

LTCCS Large Truck Crash Causation Study 

MCMIS Motor Carrier Management Information System 

MCSAP Motor Carrier Safety Assistance Program 

M/H medium/heavy (duty vehicles) 

NAS North American Standard 

NASS National Automotive Sampling System 

NATEF National Automotive Technicians Education Foundation 

NTS National Transportation Statistics 

NTSB National Transportation Safety Board 

OES Occupational Employment Services 

OMB Office of Management and Budget 

OOA out of adjustment 

OOS out of service 

TIFA Trucks Involved in Fatal Accidents 

TMC Technology and Maintenance Council 

UMTRI University of Michigan Transportation Research Institute 

VIUS Vehicle Inventory and Use Survey 
Assessment of Potential Benefits and Costs of ES-1 Final Report 

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Certifying Brake Technicians 

EXECUTIVE SUMMARY

As a result of a fatal truck-bus accident in May 2001, the National Transportation Safety Board 

(NTSB) issued several recommendations to the U.S. Department of Transportation’s (DOT’s) 

Federal Motor Carrier Safety Administration (FMCSA) based on their findings that the probable 

cause of the accident was the truck driver’s inability to stop the tractor semitrailer due to the 

reduced braking efficiency of the truck’s brakes, which had been poorly maintained and 

inadequately inspected. 

Two of the NTSB’s recommendations to FMCSA concerned brake maintenance and inspection. 

The recommendations were to require (1) minimum pre-trip inspection procedures for 

determining brake adjustment and (2) certification after testing as a prerequisite for qualification 

and specify, at a minimum, formal training in brake maintenance and inspection. 

 

This project was designed to address NTSB’s concerns and to assist the FMCSA in: 

1. Estimating the time and level of training required for commercial motor vehicle (CMV) 

drivers to conduct pre-trip inspections of sufficient depth to discover defects or 

deficiencies that were not corrected by a certified brake technician. 

2. Estimating the potential benefits and costs of implementing the NTSB’s recommendation 

to establish Federal testing and certification requirements for persons who inspect CMV 

brakes. 

Battelle assembled and led a project team that included the American Transportation Research 

Institute (ATRI), the Commercial Vehicle Safety Alliance (CVSA), and the Technology and 

Maintenance Council (TMC) of the American Trucking Associations. The work performed for 

the study involved conducting a literature review, collecting data, and interviewing and 

collecting information and data from stakeholders. All information obtained was examined and 

fed into safety and economic models to determine the potential benefits and costs that could be 

expected from implementation of the NTSB recommendations. 

. 

The benefits associated with the NTSB recommendations are those related to safety as measured 

by the prevention of crashes involving CMVs, the avoidance of the monetary costs for these 

CMV crashes, the reduced number of out-of-service (OOS) brake violations, and reduced levels 

of fines associated with violations resulting from brakes being out of adjustment (OOA). 

The NTSB recommendations would generate training costs, inspection costs, testing and 

certification costs, and administrative costs associated with recordkeeping and retention. 

Training would be required of bus and truck drivers responsible for performing pre-trip 

inspections. Brake inspectors would train in preparation for the testing and certification process 

called for in the NTSB recommendations. Training costs would include the costs associated with 

preparing training materials, compensating trainers, and labor replacement costs. The driver 

training and brake inspector certification requirements would also result in costs associated with 

registration and testing fees. Finally, pre-trip inspections would take drivers away from revenue-
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generating activities and thus would result in additional labor costs. In each case, these costs 

would be borne by the motor carrier industry. 

The most significant costs are those incurred during pre-trip inspections, which total roughly 

$4.9 to $9.9 billion over the 10-year time horizon (2005 to 2014). Though each inspection 

would require only 2 minutes per axle, the costs of this requirement are significant because they 

would require billions of inspections to be performed over the next 10 years. The cost range is 

due to varying the assumption regarding the average distance per trip between 200 and 

400 miles. Costs are higher if shorter trips are assumed because that would indicate a higher 

number of inspections. Training, testing, and certification collectively represent the next highest 

cost item, totaling $5.4 billion over the 10-year analysis timeframe. Administrative costs are 

relatively low, estimated at $316.7 million over 10 years. The costs associated with NTSB 

Recommendation 1 include driver training, pre-trip inspection costs and administrative/recordkeeping costs, and were estimated at $10.1 – $15.1 billion over the 10-year analysis time 

horizon. NTSB Recommendation 2 costs include those tied to brake technician training, testing, 

certification, and related administrative/record-keeping costs. Over the 2005-2014 time period, 

these costs were projected to total $573.5 million. Thus, the costs associated with the first NTSB 

recommendation were estimated to comprise between 94.6 and 96.3 percent of the total costs of 

the two NTSB recommendations. 

The benefits associated with the NTSB recommendations are those related to safety as measured 

by the prevention of crashes involving CMVs, the avoidance of the monetary costs for these 

CMV crashes, the reduced number of OOS brake violations, and reduced levels of fines 

associated with violations resulting from brakes being out of adjustment (OOA). Overall, 

estimated benefits are higher than projected costs over the 10-year time horizon in the base case 

analysis when low-end cost assumptions are used, with discounted benefits (using a 

7 percent discount rate) totaling $14.5 billion ($19.6 billion in nominal benefits), compared to 

$10.7 billion in costs. When the high-end assumption regarding the number of inspections is 

used, estimated costs grow to $15.6 billion and exceed estimated benefits by $1.1 billion. Thus, 

net benefits are estimated at ($1.1) to $3.8 billion. These numbers correspond with benefit-cost 

ratios (BCRs) of 0.93 and 1.36. These results demonstrated nearly no sensitivity to variations in 

discount rates. At a 10 percent discount rate, the BCR ranges between 0.92 and 1.35 and varies 

from 0.93 and 1.37 when a 4 percent discount rate is applied. The lack of discount rate 

sensitivity occurs because benefits and costs are realized relatively evenly over the 10-year time 

horizon, with the exception of relatively higher training costs in Year 1. These figures are 

summarized in Table ES-1. A BCR is equal to the present value of benefits divided by the 

present value of costs. Thus, a BCR in excess of 1.0 demonstrates positive economic returns to 

society. When BCRs exceed 1.0, society experiences net benefits from the regulation (net 

present value of benefits = present value of benefits – present value of costs). Under the highend estimate concerning the costs associated with pre-trip inspections (200-mile average trip), 

the NTSB recommendations produce net benefits with BCRs in excess of 1.0. Under the lowend estimate (400-mile average trip), the recommendations fail to produce net benefits when the 

program effectiveness drops below 76 percent (i.e., the BCR is below 1.0). 

Benefits are allocated between the two NTSB recommendations, with a range of 70 to 90 percent 

of the benefits attributed to the brake inspector certification recommendation and only 10 to 30 
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percent attributed to the driver pre-trip inspection recommendation, based on input obtained 

during this study. In addition, a base assumption of program effectiveness of 70 percent was 

varied from 50 to 90 percent. Higher percentages of program effectiveness indicate that the 

NTSB recommendations would have a greater effect on either avoiding or mitigating brakerelated CMV crashes. 

The driver training and pre-trip inspection recommendation fails to produce net benefits under 

any of the scenarios considered in Table ES-1. The driver training and pre-trip inspection 

recommendation produced BCRs ranging from 0.07 (50 percent ratio of effectiveness, 200-mile 

average trip) to 0.55 (80 percent program effectiveness, 400-mile average trip). 

The brake inspector and certification recommendation, on the other hand, produced large net 

benefits, with BCRs exceeding 12.65 in all scenarios considered in this study. The BCRs 

range from a low of 12.65 (50 percent program effectiveness, 200-mile average trip) to 29.27 

(90 percent program effectiveness, 400-mile average trip). 

Table ES-1. Benefit-cost Analysis Findings (Alternative Scenarios) 

Benefit-cost Ratios 

Program 

Effectiveness 

Driver Training/ 

Pre-trip 

Inspections 

Brake Inspector 

Training and 

Certification 

Both Driver and Brake 

Inspector NTSB 

Recommendations 

50% 0.07-0.31 12.65-16.26 0.66-0.97 

60% 0.08-0.37 15.18-19.51 0.80-1.17 

70% 0.10-0.43 17.71-22.77 0.93-1.36 

80% 0.11-0.49 20.24-26.02 1.06-1.56 

90% 0.12-0.55 22.77-29.27 1.19-1.75 

From this analysis, it appears that implementing the NTSB recommendation on certification of 

brake inspectors would create net benefits (benefits exceeding costs) and should be pursued. 

However, the NTSB recommendation on pre-trip brake inspections performed by drivers does 

not appear to be worthy of implementation.
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Certifying Brake Technicians 

1. INTRODUCTION

1.1 Project Description 

As a result of a fatal truck-bus accident in May 2001, the National Transportation Safety Board 

(NTSB) issued several recommendations to the U.S. Department of Transportation’s (DOT’s) 

Federal Motor Carrier Safety Administration (FMCSA) based on their findings that the probable 

cause of the accident was the truck driver’s inability to stop the tractor semitrailer due to the 

reduced braking efficiency of the truck’s brakes, which had been poorly maintained and 

inadequately inspected. 

Two of the NTSB’s recommendations to FMCSA concerned brake maintenance and inspection. 

They are: 

Safety Recommendation H-02-15: Revise 49 Code of Federal Regulations 396.13, 

Driver Inspection, to require minimum pre-trip inspection procedures for determining 

brake adjustment. 

Safety Recommendation H-02-18: Revise 49 Code of Federal Regulations 396.25, 

Qualifications of Brake Inspectors, to require certification after testing as a prerequisite 

for qualification and specify, at a minimum, formal training in brake maintenance and 

inspection. 

 

This project, Assessment of Potential Benefits and Costs of Revising Brake Inspection 

Procedures and Certifying Brake Technicians, was designed to address NTSB’s concerns and to 

assist FMCSA in: 

1. Estimating the potential benefits and costs of implementing the NTSB’s recommendation 

to establish Federal testing and certification requirements for persons who maintain or 

repair commercial motor vehicle (CMV) brakes. 

2. Estimating the time and level of training required for CMV drivers to conduct pre-trip 

inspections of sufficient depth to discover defects or deficiencies that were not corrected 

by a certified brake technician. 

1.2 Project Methodology 

Battelle assembled and led a project team that included the American Transportation Research 

Institute (ATRI), the Commercial Vehicle Safety Alliance (CVSA), and the Technology and 

Maintenance Council (TMC) of the American Trucking Associations. The work performed for 

the study involved conducting a literature review, collecting data, and interviewing and 

collecting information and data from stakeholders. All information obtained was examined and 

fed into safety and economic models to determine the benefits and costs that could be expected 

from implementation of the NTSB recommendations. 
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Certifying Brake Technicians 

1.2.1 Literature Search and Data Gathering 

The literature search for this project focused on gathering data and sources related to brake 

condition, maintenance, training and certification of technicians and inspection of brake systems 

by both technicians and drivers as contributing factors related to CMV brake problems including 

crashes and out-of-service (OOS) conditions. The literature search was also designed to review 

books, documents, and data on the need for brake training for drivers and technicians, specific 

training programs, and techniques for economic analysis. 

1.2.2 Stakeholder Interviews–Brake Condition and Maintenance as Crash Factors 

In an attempt to corroborate and/or gather information not available in the literature quantifying 

the extent to which brake condition and maintenance could be related to CMV crashes, 

survey/interview questions were developed. It was expected that individuals responsible for 

preventing losses, reducing or assessing the risks of motor carriers, or involved in determining 

the cause of crashes might be in possession of such unpublished information, and willing to share 

it with the project research team. A list of questions was e-mailed in advance to a previously 

developed list of potential respondents, and the subsequent surveys were administered by phone 

or by return of the e-mail questionnaire. Follow-up phone calls were required in some cases to 

clarify any ambiguities. In addition, the TMC was able to compile data from its membership to 

augment the external surveys. The results of the surveys were compiled and fed into the benefits 

analysis portion of this study. 

1.2.3 Stakeholder Interviews–Training, Testing, and Certification Programs 

A similar activity sought to corroborate and/or gather additional information on current training, 

testing, and certification programs as well as the recommended structure for future training, 

should the NTSB recommendations be implemented. The targeted groups for this effort were 

motor carriers, training schools, certification entities, association member companies, and 

insurance companies. As with the first round of stakeholder interviews, these interviews were 

conducted with the help of e-mailed questions to the respondents that facilitated their responses. 

The collected information was augmented with data obtained internally from the project team 

members that represented large groups of stakeholders. 

1.2.4 Safety Analyses 

The data and information obtained in the earlier stages of the project were used to develop the 

safety and economic models needed to determine the potential benefit-cost ratio (BCR) for 

implementing the NTSB recommendations. The primary benefits are the safety impacts of crash 

prevention, avoidance of high crash costs, and avoidance of costs resulting from OOS brake 

violations due to the improved manner in which brakes are tested and maintained on commercial 

motor vehicles. The primary costs include the costs of driver and brake technician training, per 

trip driver inspection costs, and the costs associated with brake inspector testing and 

certification.
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2. LITERATURE SEARCH AND DATA GATHERING 

2.1 Overview 

The literature search for this project focused on gathering data and sources related to brake 

condition, maintenance, training, and certification of technicians and inspection of brake systems 

by both technicians and drivers, as contributing factors related to CMV brake problems including 

crashes and OOS conditions. The literature search was also designed to review books, 

documents, and data on the need for driver/technician brake training, specific training programs, 

and techniques for economic analysis. The information provided in this report has been 

organized into four sections, based on each information source’s primary focus. Topical areas 

covered in the literature search included the following: 

• Data and studies on crashes and OOS violations that could be prevented or mitigated, 

• The need for better driver/brake technician training and inspection, 

• Existing brake training and certification programs, and 

• Economic analysis techniques. 

Each topical area was examined to uncover those sources that were directly applicable to the 

brake project. These references were then summarized and analyzed to evaluate their usefulness 

in assessing the status of brake-related crashes; OOS violation rates; training programs for 

drivers performing brake inspections, repair, and maintenance; and their suitability for use in the 

benefit-cost analysis. Finally, the references were examined for those most applicable for 

benefit-cost analysis of the brake project related cost data. 

Two key uses of the material surveyed in the literature review were to: 

1. Form the basis for estimating the number of crashes that could potentially be prevented 

through improved brake maintenance and inspection practices reflecting the 

implementation of the NTSB recommendations described in Section 1.1 of this report. 

2. Estimate the number of OOS violations that could be prevented by implementation of the 

enhanced maintenance and inspection practices 

The most important references used in the preparation of the project analyses are described in 

this section. Other sources of data and information are summarized and included in the 

annotated bibliography found in Appendix B. 

The project’s methodology to identify the percentage of truck crashes that could be prevented or 

mitigated by improved brake inspection practices was to examine each of the relevant sources 

and select the most effective CMV crash and inspection data for determining which crashes 

could be prevented or mitigated and which negative brake inspection results could be avoided 

from (1) improved inspection practices and training for CMV drivers and (2) improved training 

and a certification system for those maintaining CMV brake systems. Some of these data would 

also feed into the calculation of the fraction of vehicles that experienced a certain type of brake-
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related crash that could be prevented or mitigated through the implementation of an enhanced 

brake system. Not only were the type of brake problems associated with a crash valuable, 

information concerning the likelihood that the crash was caused by the brake problem was vital. 

That is, where the crash type involving a CMV could identify the crash as having been brake 

related or not brake related. For example, if a CMV that was experiencing brake problems were 

hit by another vehicle from behind, it is unlikely that the brake problems would have contributed 

to the crash. 

2.2 Estimating Prevention and Mitigation of Crashes and OOS Violations 

During the literature review, several databases were examined in detail to estimate the number of 

CMVs where crashes would potentially be caused by brake-related problems. These included 

the Trucks Involved in Fatal Accidents (TIFA), Hazmat Accident, Fatal Accident Complaint 

Team (FACT), and LTCC databases. 

The TIFA data were received from UMTRI for 1993 through 2000 and covered more than 

30,000 fatal truck crashes (University of Michigan, 2005). TIFA uses the Fatality Analysis 

Reporting System (FARS) as the source for identifying the fatal crashes. TIFA reports data 

included in FARS but then supplements FARS with their own data that are gathered from police 

accident reports and telephone calls to carriers, police, and other involved parties such as tow 

truck drivers. In most cases, these data provide additional detail for the user. For example, 

FARS provides data on collision type and although “rear-end crash” is one type of collision, 

there is no means to differentiate between a crash where the truck crashed into another vehicle or 

another vehicle crashed into the truck. In the TIFA data, the inclusion of “crash type” variables 

enables the identification of those trucks that struck the rear of another vehicle. 

These data can be used to help determine the type of truck crashes that could have been avoided 

if brakes were functioning properly. Clearly, these data must be used in conjunction with other 

data such as FMCSA’s Motor Carrier Management Information System (MCMIS) inspection 

data that show the percentage of trucks on the road with serious brake-malfunction problems. 

TIFA data also include an identification of truck crashes known to be associated with various 

mechanical defects. These include brakes but unfortunately due to sporadic and inconsistent 

inspections at crash scenes, the data were not very thorough. For the purposes of this brake 

project, the utility of the TIFA data demonstrated that brake problems as a contributor to fatal 

truck crashes were strongly linked to accident type. That is, if the truck crashed into the rear of 

another vehicle, identified brake problems were more likely to be a causative factor in the crash 

than if another vehicle crashed into the back of the truck. However, the utility of these data for 

the brake project was somewhat limited because the post-crash inspections lacked the 

consistency required. 

Another source of crash data is the FACT file. The FACT file was analyzed by UMTRI and 

investigated by the project team as a possible source of data (Blower, 2002). The program 

investigated every fatal accident in Michigan since 1996 that involved a commercial motor 

vehicle and at least one death. The investigation includes analysis of the driver, motor carrier, 
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accident scene, sequence of events, role of the truck, and an inspection to determine the 

compliance of the driver and vehicle with motor vehicle regulations. 

At the time of Blower’s analysis of the FACT data, 442 trucks were included in the analysis 

representing crashes from 1996 to February 2001. Of these, data from a North American 

Standard (NAS) Level 1 inspection were available for 354 of them. A violation was found for 

either the truck or the driver in 65.8 percent of these inspections. Over 34 percent (121) of the 

vehicles had at least one brake violation. Mechanical defects including those related to brakes 

and other vehicle components were common. Fifty-five percent of the trucks had at least one 

mechanical violation and 28.5 percent had at least one OOS condition. 

This rate of violations and OOS for all causes is consistent with trucks routinely inspected 

under Michigan’s Motor Carrier Safety Assistance Program (MCSAP) program. In the threeyear period ending in June 2001, 21,322 trucks were subject to a Level 1 inspection. Of these, 

31.8 percent were placed out of service. 

The FACT data show that accident type (i.e., crash type) combined with the presence of brake 

problems can indicate the likelihood that a particular crash was caused by brake problems. For 

example, in a rear-end accident in which a CMV crashes into the rear or side of another vehicle 

and a brake problem already exists in the CMV, there is a good chance that the brake problem 

contributed to the crash. On the other hand, when another vehicle crashes into the rear of a 

CMV, even if the truck’s brakes have an identified mechanical flaw, there is little likelihood that 

the CMV brake problem contributed to the crash since even brakes in perfect condition would 

not have helped to avoid the crash. Fifty-nine of the trucks were involved in rear-end collisions. 

Of these, 22 (37.3 percent) had a brake-related violation. This analysis indicates that 5.0 percent 

(22 of 442) of trucks involved in fatal crashes had brake-related problems that may have 

contributed to the crash. Note that this is close to the violation rate for brakes for all FACT 

trucks. For those trucks that struck another vehicle, the overall brake violation rate was 

50 percent. Only 27.3 percent of the trucks struck in the rear had a brake-related violation. As 

expected, a far higher percentage of trucks that struck another vehicle from behind had brake 

problems when compared with those trucks that were struck from behind. Those truck crashes 

with demonstrated truck brake problems and where the truck struck another vehicle from behind 

have a high likelihood that faulty brakes were a contributing factor. Attempts to obtain raw 

FACT data from the Michigan State Police were unsuccessful. However, even if the data could 

have been obtained, their applicability for this project was limited because of the small 

population size, only involving fatal accidents within one State. 

The project team also investigated utilizing Battelle’s Hazmat Accident Database that was 

created by a Battelle team under a project for FMCSA (Battelle, 2005). The project’s purpose 

was to obtain additional data and information on hazardous materials (hazmat) crashes that could 

be used to provide added information for safety analyses. The database uses the MCMIS crash 

file for 2002 and selects all trucks involved in hazmat crashes. From the approximately 2,000 

crashes, half were selected to be enhanced through use of Police Accident Reports (PAR) and 

contact with motor carriers. The data for each of the approximately 1,000 hazmat crashes for 

which additional data were collected provide such information as accident type and cause. These 
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data could be used to help identify those hazmat trucks that could have crashed because of a 

brake malfunction. In-depth data analysis showed that the identification of brake-related 

problems, although providing some valuable information, was insufficient for the brake project 

because inspections were often not thorough enough. Furthermore, the population surveyed 

included only hazardous material trucks and the project team believed that they would not be 

representative of all CMVs. 

The literature survey data also included two very important sources of data that produced 

estimates used to feed into the benefit-cost analysis. These were the FMCSA’s Large Truck 

Crash Causation Study (LTCCS) and the MCMIS OOS inspection data. The LTCCS is a 

compilation of inspection data gathered through intensive field inspection and data collection at 

post-accident scenes (FMCSA, 2005). There are currently data for 1,070 truck crashes (includes 

some data collected for trucks during a pilot study). This study has produced a considerable 

quantity of valuable data for people interested in large truck crashes. The LTCCS is a three-year 

study conducted by the National Highway Traffic Safety Administration (NHTSA) and FMCSA. 

The study was conducted within the National Automotive Sampling System (NASS), a 

nationally representative sample involving the General Estimation System (GES). GES is an 

annual representation of crashes from 60 sites – called Primary Sampling Units (PSUs) –

throughout the United States. NASS was chosen because it provides nationally representative 

data chosen from police accident reports. The data were collected through response by NASS 

truck researchers and CVSA Level 1-certified State truck inspectors. Inspections were 

conducted on large trucks involved in the selected crashes. 

The LTCCS data files include data for four types of truck brake problems related to a particular 

crash. These four types are brake failure, brake inoperable, brakes OOA, and brakes deficient. 

 The LTCCS show that brake problems exist in about 30 percent (321 out of 1,070) of the 

inspections conducted for the study. The brake problems are described in more detail in Section 

5.2. 

The LTCCS includes detailed descriptions of accident type. These data enabled the project team 

to correlate those CMVs with identified brake problems with the accident types that could 

potentially be caused by brake problems. Therefore, the data facilitated the estimation of the 

percentage of crashes that could have been avoided or mitigated if brake malfunctions were 

prevented through more efficient inspection and preventive maintenance programs. The Battelle 

Team concluded that the percentage of trucks with brake violations would best be determined 

from LTCCS data. Similarly, the accident types that had associated brake problems and would 

have been avoided or mitigated with an improved brake program were also derived from the 

LTCCS data. Analysis of the data indicated that approximately seven percent of all CMV 

crashes could either be avoided or mitigated if the enhanced brake program recommended by 

NTSB (see Section 1.1) were in place. Section 5 of this report explains how the estimated 

number of crashes that would be avoided or mitigated was calculated. 

The FMCSA Inspection File contains data from State and Federal inspection actions involving 

motor carriers, shippers of hazardous materials, and transporters of hazardous materials 

operating in the United States. State personnel under the Motor Carrier Safety Assistance 
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Program (MCSAP) conducted the majority of the inspections at the roadside. Federal and State 

field enforcement staff perform inspections on interstate and intrastate motor carriers and 

shippers and transporters of hazardous materials. Violations of the Federal Motor Carrier Safety 

Regulations may result in a vehicle and/or driver being placed OOS. Inspectors use CVSAdeveloped criteria and CMVs are placed OOS if a defect or deficiency is so severe that it 

presents an imminent hazard. The data collected from inspection activity are collected and 

stored in the FMCSA MCMIS Inspection Data File. The file also contains a limited quantity of 

“post-crash” inspection data derived from selective inspections at crash scenes. The roadside 

inspection data also include the type of OOS violation attributed to a particular CMV, including 

brake problems. Therefore, the data could be used as an effective baseline for estimating the 

number of brake problems that could be prevented if the enhanced brake training, certification, 

and inspection programs were implemented. The OOS data for brake violations in the FMCSA 

Inspection File also provide a reliable baseline for estimating the number of OOS violations that 

would be avoided once a new program is implemented. Therefore, this data feeds directly into 

the benefit-cost analysis. 

The number of truck crashes was obtained from the 2002 data included in the 2004 edition of 

FMCSA’s Large Truck Crash Facts (FMCSA, 2004). The data in this reference have been 

derived from several data sources including FARS, GES, MCMIS Crash File, and Highway 

Statistics. These data were used to provide a baseline for estimating the percentage of annual 

CMV crashes that might have been prevented if more effective brake maintenance, training, 

certification, and inspection procedures were in place. The Large Truck Crash Facts shows that 

approximately 416,000 crashes occurred in 2002. 

OOS brake violation statistics were essential for the brake project in order to be able to estimate 

the number of OOS violations that could be avoided by the implementation of the more effective 

brake training, certification, and inspection program. Operation Air Brake provides a detailed 

summary of data for the years 1998 to 2004 that tabulates the number of OOS brake violations 

found in inspections of a sample of CMVs (CVSA, 2004). Both the CVSA and the Canadian 

Council of Motor Transport Administrators sponsor the annual Operation Air Brake campaign, 

which collects data in both countries. The program emphasizes reducing the number of brakerelated violations. During 1998 to 2004, Operation Air Brake checked 66,941 units. Of these, 

11,360 (16.97 percent) have had an OOS brake condition. Seventy-six motor coaches were 

checked in 2004. Of these, 20 (26 percent) had an OOS brake condition. These percentages of 

OOS brake violations were not utilized to estimate OOS violations that could potentially be 

avoided with improved training, certification, and inspection because the smaller, targeted and 

intensive sampling resulted in a violation rate considerably higher than that in the FMCSA 

Inspection File (FMCSA, 2005a), which shows a brake problem-related OOS rate of 9.8 percent. 

The purpose and implementation of the Operation Air Brake program differs systematically from 

the regular roadside inspection program, thus, the results of the two types of inspections are not 

directly comparable. Section 5 of this report includes additional analysis concerning OOS brake 

violations. 
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2.3 Need for Better Driver/Brake Technician Training and Inspection 

The following subsection describes data sources, papers, reports, and books that were consulted 

during Battelle’s analysis of driver/technician training protocols for the preparation of the brake 

project to describe the need for enhanced driver/technician training, certification, and inspection 

programs. 

A survey was conducted in 2003 as part of Operation Air Brake, which is intended to reduce the 

number of brake-related violations, and the results are described in Report of Driver Survey: Air 

Brake Adjustment Knowledge (VanderZwaag, 2003). The survey results emphasize the gap that 

exists between the amount of knowledge drivers should have about air brake adjustment and 

their actual knowledge. The 4,055 driver surveys collected indicated widespread 

misunderstanding of the importance of brake adjustment and the correct method of brake 

adjustment for their vehicles. The survey asked drivers to identify the four conditions necessary 

to properly inspect brake adjustment.*

 Fewer than five percent (192 of 4,055 drivers) were able 

to correctly identify all four of the conditions. The survey results indicate that professional 

drivers have a poor understanding of the fundamentals of brake adjustment and how to inspect 

brakes to ensure that brakes are in proper adjustment. Driver lack of knowledge concerning air 

brake adjustment concepts and inspection would seem to contribute to brake malfunctions during 

truck operation. While the VanderZwaag report cannot be used to estimate the number or 

percentage of crashes attributable to correctable brake defects, it does underscore the need for 

improved driver training in the area of brake inspection and maintenance. 

Research results have clearly demonstrated that improved safety practices result in reduced 

crashes for trucking companies. A 1992 paper investigated crash results for 233 trucking firms 

given a safety rating of ‘unsatisfactory’ in earlier Federal inspections (Moses and Savage, 1992). 

Faced with re-inspection, these 233 firms tended to improve their safety practices and 

consequently operated more safely. The estimated effect of the second inspection for these 

carriers was to reduce their overall crash rate by 10.4 percent. It is clear that enhanced brake 

inspections would likely result in measurable safety improvements. However, since the 

inspections only affected a small portion of the industry, the improvement in safety could not be 

quantified in terms of a lower number of crashes or lower crash rates for the total truck 

population. Furthermore, the research is somewhat dated because the compliance review process 

has changed. In addition, unfit carriers are shut down if they do not improve their safety 

performance within a limited time period (45 days for passenger and hazmat carriers; 60 days for 

non-hazmat property carriers). 

 

*

 The four conditions necessary to properly inspect brake adjustment are: 

(1) 90 to 100 psi (621 to 690 kPa) in the air reservoirs 

(2) engine shut off 

(3) spring brakes released 

(4) service brakes fully applied 
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The impact of two FMCSA safety programs on CMV safety reinforces the conventional wisdom 

that the implementation of vehicle inspection and safety compliance programs can result in 

safety improvements and prevent both fatalities and injuries. The report on FMCSA safety 

program effectiveness documents the methodology and results from an improved model to 

measure the effectiveness of two safety programs sponsored by FMCSA (Volpe, 2004). These 

programs, roadside inspections and on-site compliance reviews were evaluated with respect to 

their impact on reducing crashes, injuries, and fatalities. The improved model was applied to 

three years of inspections and reviews—2001, 2002, and 2003—and calculated the reduction in 

crashes, injuries, and fatalities by State for each year. Results indicated that the programs 

resulted in significant reductions in crashes, fatalities, and injuries. For example, in 2003, the 

State roadside inspection program alone resulted in reducing crashes by more than 12,600, and 

prevented more than 9,600 injuries and 530 fatalities. This report showed that, overall, increased 

inspections resulted in improved safety. These results are likely to apply to increased inspections 

that would be implemented if the NTSB brake-related recommendations were followed. 

2.4 Training and Certification Programs 

The following subsection describes references that were used during Battelle’s analysis of 

training programs and materials. 

One important source for training programs is the manual Practical Airbrakes (VanderZwaag 

2001). This is a comprehensive manual designed to give drivers the knowledge and 

understanding needed to operate airbrakes in a CMV. The manual includes overall descriptions 

of the braking system as well as details about the major subsystem components such as the 

supply subsystem, the service brake subsystem, and the trailer brake subsystem. Separate 

chapters are included on inspecting airbrake system components and testing the airbrake system. 

A highly valuable chapter describes inspecting airbrake adjustment. The project team used the 

manual as a useful reference when considering the cost and effort associated with developing 

brake training materials. 

The Technician Certification Program Guidelines was another source used to provide 

recommended practice for the maintenance shop manager, training manager, and/or human 

resources manager for use in planning, designing, and implementing a technician development 

program that encourages professional development through technical certification (TMC/ATA, 

2004). A certification program may be developed internally or may be based on existing 

national certification or local licensing programs. The paper recommends that the components 

described in the guideline should be considered during the development of such a program. The 

primary goal of a motor carrier technician certification program is professional development of 

the technical skills and knowledge required for competent performance of the motor carrier 

technician. 

If adopted by the industry, the Battelle Team believes the guidelines should result in improved 

preventive maintenance and repair programs that, because they include brakes, could help to 

reduce the number of crashes resulting from brake malfunctions. 
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The Air Brake Handbook proved to be another valuable source of information for developing 

brake-related training programs (Bendix, 2000). The handbook provides instruction and data 

sheets on most air brake system components. A valuable section of the handbook discusses the 

“fundamentals of brakes” and includes discussion of the physics of braking, how various 

components of air brakes operate, and a section on brake maintenance. The handbook would be 

a valuable resource for providing background information for inspectors and drivers and, for 

technicians, as a guide for troubleshooting problems. The brake maintenance section lists 

specific precautions designed to protect air brakes that should be followed when working around 

a vehicle. 

Finally, another valuable resource was a report* that documented the findings of a peer exchange 

team that examined best practices for CMV safety (U.S. DOT, 1998). The report reflects these 

best practices in seven States and several trucking companies. The report contains some 

recommendations that are relevant to the brake project. For example, in the section on 

handbooks and manuals, five major recommendations are made as to how these sources should 

be designed, prepared, and distributed. Some of these recommendations are including 

publications written in easily understood language focusing on the most relevant materials for 

the driver, ensuring the material’s design provides a well organized and useable format, 

providing for a mechanism that publications reach all who need them, and using the Internet as 

an alternate to supplying printed materials. A section on training provides descriptions of the 

diverse training programs available in the various States surveyed. Some of the information was 

found to be dated, and it would be valuable to update this peer-exchange reference guide. 

2.5 Economic Analysis 

The following subsection briefly describes the three references that were most important for the 

economic analysis of the cost and benefits of the proposed brake training, certification, and 

inspection program. These cost data were used to estimate the savings achieved from avoiding 

or mitigating crashes. Although the data provide a reliable overview of crash costs, they lack the 

specificity to differentiate costs related to certain crash types such as cases in which a truck 

strikes another vehicle or the truck is struck by a vehicle from behind. 

The report entitled Economic Cost of Motor Vehicle Crashes constitutes one of the major 

sources of crash cost information in the United States. The report estimated the economic cost of 

all motor vehicle crashes in the United States in 2000 at $230.6 billion (Blincoe, L. et al, 2000). 

This study monetized the costs associated with 41,821 fatalities, 5.3 million non-fatal injuries, 

and 28 million damaged vehicles. The study also included a number of cost elements: 

(a) productivity losses, (b) property damage, (c) medical costs, (d) rehabilitation costs, (e) travel 

delay, (f) legal and court costs, (g) emergency services, (h) insurance administration costs, and 

(i) costs to employers. The costs included those associated with both police-reported and 

unreported crashes. The crash costs are stratified by severity according to the Abbreviated Injury 

Scale. This study examines crash costs associated with all vehicles, including both automobiles 

 

* Educational and Technical Assistance to CMV Drivers and Motor Carriers: Peer Exchange by the Upper Great 

Plains Transportation Institute. 
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and heavy trucks. The average crash cost when all vehicles are included is $14,102 (2002 

dollars). 

The report entitled Revised Costs of Large Truck- and Bus-Involved Crashes, prepared by the 

Pacific Research Institute for FMCSA, documents the costs associated with large truck- and businvolved crashes and provides a good source for estimating the comprehensive costs of truck and 

bus crashes (FMCSA, 2002). More specifically, the report estimates the dollar value cost per 

crash, victim injured, or fatality incurred because of large truck- and bus-involved crashes. The 

cost elements examined in the study include the following: medical-related (e.g., hospital, 

rehabilitation), emergency services, property damage, lost productivity (e.g., crash investigation, 

lost wages, recruiting and training replacement workers), and lost quality of life (e.g., pain and 

suffering). The costs associated with crashes are differentiated based on crash severity, ranging 

from no injury to fatality, and by vehicle class, including straight trucks, truck-tractor 

combinations, and buses. The cost of police-reported crashes involving large trucks with a gross 

weight rating in excess of 10,000 pounds averaged $59,153 (2000 dollars). The cost of policereported crashes involving buses averaged $32,548. These costs are reported from a societal 

perspective. 

The report entitled Economic Burden of Traffic Crashes on Employers found that traffic crashes 

occurring on the job resulted in 2,100 fatalities and 353,000 injuries annually during the 1998-

2000 timeframe (NHTSA 2003). Further, job-related vehicle crashes accounted for nearly 

6.5 percent of all crash injuries. The study estimated the economic burden of traffic crashes on 

employers, including health-related fringe benefits costs, employer health care costs, sick leave, 

life and disability insurance for employees involved in crashes, and wage-risk premiums. These 

cost elements amounted to nearly $60 billion in annual costs to employers in the United States 

during the 1998-2000 time horizon. This study estimated costs to employers by State. The costs 

to employers in California and New York were highest, topping $3.5 billion in each State. It also 

examined the costs associated with crashes involving an alcohol-impaired driver and passengers 

that are not using restraining devices. Finally, the study broke down cost by industry, estimating 

the highest costs in the land transportation, construction, mining, and agriculture sectors. The 

average cost per crash to employers was estimated at $16,471 in direct costs (2000 dollars) and 

$24,536 in total costs, including the wage-risk premium (a premium paid in the workplace to 

compensate employees accepting risk due to potentially dangerous working conditions). 

From these reports, the Pacific Institute study was deemed most relevant because it 

comprehensively examines a broad range of costs associated with crashes involving buses and 

trucks weighing in excess of 10,000 pounds. The Pacific Institute report examines costs from a 

societal perspective. For example, this study includes costs associated with emergency response 

and the decline in quality of life experienced by drivers and their dependents following crashes 

involving serious injuries and fatalities. Both of these cost items are not borne directly by 

industry. Therefore, these costs can be used to examine the economic value of the brake 

inspection program on society but cannot be used to determine how the program would affect the 

industry’s bottom line. 
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3. STAKEHOLDER INTERVIEWS–BRAKE CONDITION AND

MAINTENANCE AS CRASH FACTORS

3.1 Approach 

As described in Section 2, published literature was sought concerning brake condition and brake 

maintenance as contributing factors in CMV crashes. Since availability of this type of 

information in the open literature was expected to be limited, a parallel effort involving 

interviewing of personal data sources was undertaken. The intent of these interviews was twofold: (1) to gather data unavailable from the literature search or database analysis and (2) to 

corroborate the limited information that was available. The information from the surveys was 

then used in the economic and safety analyses. 

Potential interviewees included individuals and organizations on or known to the project team, 

which included the CVSA, TMC, and FMCSA. Fleet and insurance contacts were provided by 

CVSA as well as through prior personal knowledge. Crash investigators were previously known 

to members of the research team. The final list of interviewees was reviewed and approved by 

FMCSA. Several potential interviewees indicated they were unable to respond, but referred the 

project team to other individuals. Survey questions were tailored to three groups of such 

individuals, consisting of (1) trucking or bus fleet safety representatives, (2) insurance industry 

representatives, and (3) crash investigators. Furthermore, during the course of the data 

collection, it became apparent that some of the initially proposed sources were unable to provide 

adequate answers to the questions. In some cases, this was because the interviewee did not have 

or could not obtain the requested data and in others the data could not be released due to 

corporate restrictions. Substitute sources were approached in these cases. 

The questions were sent via e-mail in advance to allow the respondent time to gather the data, 

and propose a time for the interview phone call. Due to scheduling conflicts, coordination of 

phone interviews within the desired time frame was sometimes difficult. Therefore, the 

respondents were sent follow-up e-mails and left voice messages asking them to fill in the 

answers and e-mail them back. This was to encourage completion of the survey questions with 

minimum burden on the respondents’ time. Once the responses were received, it was much 

easier for the project team to follow up with phone calls only when required for clarification. 

Ultimately, nine interviews were conducted, involving a range of commercial motor carrier (both 

truck and bus) and insurance industry representatives. Persons who conduct crash investigations 

(or supervise those that do) and professional accident investigators also contributed to the data, 

through e-mail reply to questionnaires. In these cases, for which the gathering of no new data 

was required, the respondent estimated a range of percentages of crashes in which brake system 

malfunction or failure were factors. General information on the respondents is summarized in 

Table 3-1. 
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Table 3-1. Respondent Profile 

Respondent Category Power Units Trailers Comments 

1 Motor Carrier 

(truck) >8,000 >32,000 Many drivers are union drivers. 

2 Motor Carrier 

(truck) 

>1,000 Tractors, 

>8,000 Single Units 10K-15K 

Trailers not domiciled. The 

number reported are those 

traveling through region for 

which respondent was 

responsible. 

3 Motor Carrier 

(truck) ~1,000 ~1,700 

Mostly carry hazmat, so 

probably better than average 

safety record. Prefer not to 

have drivers do brake 

adjustments. 

4 Motor Carrier 

(truck) 400-500 400-500 Drivers are owner-operators 

5 Motor Carrier 

(truck) >8,000 >13,000 Drivers are owner-operators 

6 Motor Carrier 

(motor coach) >1,900 Not Applicable 

7 Insurance 

Provider Not provided Not provided 

8 Insurance 

Provider Not provided Not provided 

9 Insurance 

Provider Not provided Not provided 

Number of vehicles unknown, 

but one of top 3 CMV insurers in 

North America. 

Estimates 

only 

Crash 

Investigators (3) Not applicable Not applicable 

3.2 Stakeholder Input Regarding Brake-related CMV Crashes 

The responses are presented according to topic, with a tabulated summary, followed by a 

discussion of each group’s response. 

3.2.1 Brake-related Crashes 

Respondents were asked about the percentage of crashes in which brake system malfunction or 

failure was a factor. This question was answered by the fleets based on their data from 2004, and 

as estimated values based over several years for the insurance industry respondents and crash 

investigators. A summary of their responses to this question is shown in Table 3-2. 
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Table 3-2. Estimates of the Percentage of Brake-related Crashes 

Motor Carrier Fleet Safety 

Representatives 

Insurance Industry 

Representatives 

Crash Investigators and 

Enforcement/Inspection Officers

0 to less than 1 percent Five to 10 percent 25 to 60 percent 

This range of responses was surprisingly broad, with the motor carriers attributing either zero or 

“less than one percent” of their DOT-reportable crashes to brakes. The very low motor carrier 

response likely reflects the fact that the responding fleets are safe fleets with good maintenance 

practices. Indeed, that they participate in CVSA and were willing to share their data is an 

indication of their confidence in their safety record and maintenance practices. Not that they had 

zero crashes, as the number of DOT-reportable crashes ranged from the low 20s to over 300, 

depending on the fleet. Rather, they indicated with some assurance that none of their crashes 

involved brake system malfunction or failure. In response to a specific question, the fleets all 

indicated that if brakes were a contributing factor, their investigation was sufficiently detailed 

that they would have identified this as such. 

In comparison, the insurance industry respondents estimated that the range of DOT-reportable 

crashes in which brake system malfunction or failure was a cause or factor was from 5 to 

10 percent. This somewhat higher range is likely due to the fact that the fleets this group of 

respondents insures covers a range of different maintenance and safety practices, and likely have 

a range of safety ratings. The project team’s sense is that the range reported by the insurance 

industry respondents is representative of the actual number, given that they deal with a wide 

variety of fleets, in size and maintenance. The specifics of their customers were not shared with 

the project team. 

In contrast to these relatively low ranges, the crash investigators indicated that from 25 up to 

60 percent of the crashes they had investigated could be attributed to brake system malfunction 

or failure. However, these numbers were admittedly high. These individuals investigate a large 

number of serious injury and fatal crashes annually, and are considered brake failure analysis 

specialists. As such, they may be called in to look at a non-representative group of crashes in 

which brake failure is suspected a priori. Nevertheless, their comments have provided additional 

insight into the question at hand. One respondent said: 

“We investigate over 50 CMV serious injury/fatal collisions per year and have done so for 

almost 20 years. As brake failure analysis is one of my specialties, my percentages of brake 

defects to accident cause may be higher than most. However, based on my experience, about 80 

percent of the time when I am called in, I find brake defects and improper brake equipment that 

was not recorded by the investigating law enforcement agency. In my opinion this is a 

combination of: 

 

1) Lack of training to examine CMV brake systems 

2) Lack of understanding of calculating brake force relative to CMV vehicle dynamics 
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3) Limited enforcement power related to FMCSR 

4) Limited resources – availability of DOT/CVSA inspectors 

5) Limited availability of specialized test equipment to examine damaged air brake systems 

(not usually available to typical law enforcement personnel)” 

For those crash investigators and testing specialists that have brake testing equipment, such as 

performance-based brake testers (PBBTs), at their disposal, assuming that the post-crash vehicle 

is capable of being tested on a PBBT, brake problems may be found at a higher rate than those 

from a visual inspection. Thus, the recommendations of the NTSB to certify inspectors and have 

drivers trained and perform pre-trip inspections of brake systems including but not limited to 

stroke measurements for s-cam type air brakes, without the use of similar brake force measuring 

equipment, would not likely provide the same benefit as if such equipment were used in 

maintenance and pre-trip inspections. It also should be noted that PBBTs used in the 

maintenance shop, or as a required part of an annual inspection, would be of increased benefit for 

brake types where stroke cannot be measured, such as hydraulically actuated, electric, or air-disc 

brakes. 

One enforcement officer, while unable to provide numerical responses to our questions, did 

suggest that the NTSB recommendation regarding drivers’ pre-trip inspection should possibly 

have referenced 49 CFR 392.7, since 49 CFR 396.13 relates more to the driver duties for 

reviewing the last daily vehicle inspection report. This recommendation has no bearing on the 

benefit-cost analysis, although if driver training were recommended, it would likely be 

applicable to both these regulations. 

3.2.2 Preventable Brake-related Crashes 

Respondents were also asked about the percentage of crashes that brake system maintenance or 

inspection could have prevented or decreased their severity. For this question, the range of 

responses was narrower than the first, with the fleets’ estimates increasing and the investigators’ 

decreasing, as seen in Table 3-3. 

Table 3-3. Estimates of the Percentage of Preventable Brake-related Crashes 

Motor Carrier Fleet Safety 

Representatives 

Insurance Industry 

Representatives 

Crash Investigators and 

Enforcement/Inspection Officers 

Less than 1 to 16 percent Eight to 15 percent 15 to 40 percent 

Although the range is narrower for this question, the relative ranking of respondents’ answers 

was the same, with the fleets being the lowest and the crash investigators being the highest. 

There was overlap this time between the fleets and insurance companies, showing that at least 

some fleets felt improved brake maintenance and/or training would be beneficial in improving 
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braking, thus preventing or decreasing the severity of crashes, as compared with their view that 

few crashes were the result of brake malfunction or failure. 

The fact that the crash investigators’ estimate was lower for this question than the previous 

question dealing with malfunction or failure led to a follow-up question, to which they indicated 

their belief that, while inspection of brakes could help decrease the number of crashes, it would 

not be as effective as brake performance measurement, in which malfunctions or hidden defects 

would be identified. 

3.2.3 Additional Comments from Motor Carriers 

At the close of the phone interviews, motor carrier fleet safety representatives were also asked if 

they had any data concerning improvements in safety or OOS statistics that they could relate 

directly to a specific new or improved maintenance, inspection, or training program. Although 

no quantitative data were provided, one respondent indicated he noticed “an improvement” with 

changes in maintenance and training, and another indicated a reduction in OOS rates after 

consolidating safety and compliance functions for five subsidiary carriers. 

3.2.4 Values to be used in Economic Analysis 

Although a wide range of answers were obtained from the personnel interviews, the project team 

applied their engineering judgment to the responses in order to identify a range of values to be 

used in the economic analysis. First, for each of the three groups surveyed, the range of values 

was consistent within each group for the two different brake-related aspects of the surveys: 

(1) the percentages of crashes that could be attributed to brake system malfunction or failure and 

(2) the percentage of crashes for which brake maintenance or inspection could have prevented or 

decreased their severity. To obtain the range of values to be used in the economic analysis, the 

lowest estimates (from the fleets) were regarded as both coming from fleets with relatively good 

safety ratings and also likely to be conservative. Similarly, the highest estimates (from the crash 

investigators) were regarded as coming from a non-representative subset of vehicles, and likely 

to be overestimates. The CMV insurance industry representatives were felt to have the best 

overall data with no reason for bias, therefore more likely to encompass an accurate and 

appropriate range to be used. Given these factors, for the percentage of crashes that could have 

been prevented or had their severity decreased from better brake inspection, we recommend 

using from 5 to 10 percent for a conservative estimate and from 5 to 20 percent for a lessconservative estimate. These ranges cover the overlap range of the fleets and insurance industry 

representatives, and the less-conservative estimate also includes the low end from the crash 

investigators. 
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Certifying Brake Technicians 

4. STAKEHOLDER INTERVIEWS–TRAINING, TESTING, AND 

CERTIFICATION PROGRAMS 

4.1 Approach 

The next phase of the project involved conducting interviews with up to nine entities concerning 

(a) training and certification for drivers, brake inspectors, and technicians and (b) the 

management of the process, along with safety and economic analysis. The intent of these 

interviews was to gather data unavailable from the literature search or database analysis and to 

gather information that was available from a sampling of fleets, schools, certification entities, 

association member companies, and insurance companies. 

Nine interviews were conducted, involving commercial motor carriers (both truck and bus), 

a technician training school, a testing and certification organization, and insurance industry 

representation. This document summarizes the interviews and the information gathered. 

Potential interviewees included individuals known to the project team. Motor carrier and 

insurance contacts were provided by CVSA as well as through prior personal knowledge. 

The final list of interviewees was reviewed and approved by FMCSA. Several potential 

interviewees indicated they were unable to respond, but referred the project team to other 

individuals. Survey questions were tailored to three groups of such individuals, consisting of 

(1) trucking or bus motor carrier safety representatives, (2) insurance industry representatives, 

and (3) driver/technician schools and testing/certification organizations. Further, during the 

course of the data collection, it became apparent that some of the initially proposed sources were 

unable to provide adequate answers to the questions. Substitute sources were approached in 

these cases. 

The specific information sought from the respondents was forwarded to them in advance of the 

interview to allow the respondent time to gather the data. For some respondents, scheduling 

conflicts made it difficult to coordinate phone interviews within the desired period and they 

provided written responses. The project team then followed up with these individuals to clarify 

their responses or to obtain additional information. 

Ultimately, nine interviews were conducted, involving a range of commercial motor carriers 

(both truck and bus), insurance industry representatives, a school for brake technicians, and a 

testing and certification organization. General information on the respondents is summarized in 

Table 4-1. 
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Table 4-1. Respondent Profile 

Respondent Category Power Units Trailers Comments 

1 Motor carrier 

(truck) 8,586 13,606 

2 Motor carrier 

(truck) 289 Not provided 

3 Motor carrier 

(truck) 658 1,100 

4 Motor carrier 

(bus) 700 Not applicable 

5 Association 

(motor carrier) 12 to 10,000* Not provided Number of motor carriers in response is unknown 

6 Association 

(motor carrier) 

12 to 4,900* 

median: 166 

30 to 14,000*

median: 318 

Brake inspector data represents 

12 motor carriers; driver inspection 

data represents 45 motor carriers 

7 School for 

technicians Not applicable Not applicable 

8 

Testing and 

certification 

organization 

Not applicable Not applicable 

9 Insurance 

provider Not available 26,510 Represents 85 motor carriers 

 * These figures indicate the range of power units and trailers operated by the motor carriers members 

represented in each association’s response. 

Several of the respondents represented constituencies of many organizations and they were able 

to provide data for a cross-section of their membership, thereby increasing the effective number 

of entities for which data were obtained. Overall, the motor carriers represented included a wide 

range of operations, including tanker/hazardous materials, refrigerated, specialized, retail, and 

private. Both truckload (TL) and less-than-truckload (LTL) carriers were represented. 

To better understand the relevance of the data obtained from the respondents, a brief summary of 

the characteristics of the carriers represented in the collected data is presented. 

Brake inspectors have an average of 12.8 years of experience, according to the carriers. The 

insurance representative provided an estimate of 10 years of experience. Carriers reported that 

an average of 58 percent of their brake inspectors have completed a formal training program 

rather than on-the-job training or an apprentice program (with estimates ranging from 20 to 

100 percent). The insurance representative put that figure at only 20 percent. 

Carrier respondents varied among the number of power units they operated. Some had fewer 

than 20, while others had more than 5,000; the median number of power units was 200. Of 
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these, carriers estimated that 9.1 percent were older than October 20, 1994, when automatic 

brake adjusters and push stroke indicators were required on certain air brake systems. The 

absence of the devices may make it more difficult for certain brake inspections to be conducted 

by a driver. The insurance representative placed the average motor carrier size that they insure at 

85 power units, with only 3 percent older than October 20, 1994. 

Trailer fleets ranged from 30 to 14,000, with a median of 396. Of these, carriers estimated that 

22.2 percent of them were older than October 20, 1994, when automatic brake adjusters and 

brake adjustment indicators were required to be installed on certain air brake systems. As for 

power units, the absence of the devices may make it more difficult for certain brake inspections 

conducted by a driver. The insurance representative estimated his firm’s average insured fleet to 

include about 312 trailers, with about 9 percent older than October 20, 1994. 

Vehicle OOS rates for brake-related conditions were reported to be approximately 3.4 percent. 

This excludes one carrier that reported a rate of 39 percent but whose rate in FMCSA’s SafeStat 

system is approximately 11 percent. The insurance representative estimated the brake-related 

OOS rate to be 2.3 percent. These figures were considerably lower than the Operation Air Brake 

data presented in Section 2.2, indicating that the respondents may have better-than-average brake 

inspection, repair, and maintenance programs. 

Carrier annual maintenance expenditures averaged around $10,200 per power unit (ranging from 

$3,500 to $22,000) and $2,250 per trailer (ranging from $600 to $5,000). The total annual 

maintenance expenditures that were considered preventive (e.g., inspections, replacement of 

parts before failure) was estimated to be about 55 percent (ranging from 13 to 85 percent). The 

proportion of total maintenance expenditures that were brake-related was not available. The 

insurance representative’s estimate for preventive maintenance is 18 percent (and he would not 

disclose annual maintenance expenditures). 

4.2 Stakeholder Input Regarding the Impact, Cost and Implementation 

Feasibility of the NTSB Recommendations 

The data gathered from the interviews related to training, testing, and certification programs are 

presented in three subsections: (a) driver inspection, (b) training and certification of brake 

inspectors, and (c) safety and economic analysis. Each addresses the responses from motor 

carrier, insurance, and school representatives. 

4.2.1 Driver Inspection 

Impact of inspection on operations 

It is important to understand how stakeholders viewed the feasibility of drivers performing 

functional pre-trip brake inspections, and whether these inspections could be performed with the 

driver alone or whether a second individual was necessary. Respondents were asked to consider 

that a brake inspection with two people would add one minute per axle to a pre-trip inspection 

and that a driver conducting the inspection alone would require two additional minutes per axle 
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Certifying Brake Technicians 

for a pre-trip inspection. They were also asked to consider that one-person inspections would 

require the driver to use a device to apply the service brakes or to measure the free stroke. 

Respondents were not provided any additional details on what these inspections would entail and 

were provided per-axle time estimates to allow them to determine the impacts on their fleets 

based on the vehicle configurations that they operate. The per-axle time estimates were based on 

the NTSB recommendation, which focused on determining brake adjustment during pre-trip 

inspections. A more complete inspection might consider, in addition to brake adjustment, 

checking for other deficiencies, including air leaks, cracks in the linings, contaminated linings, 

chafed hoses, incorrect connections or splices, and holes in the chambers resulting from 

corrosion or other damage. Outside the cab, the driver could check the tractor protection valve. 

Then in the cab, he or she could check the air loss rate and low-pressure warning device. 

While some carrier respondents indicated that there would not be appreciable impacts on their 

operations if two-person inspections were required (and actually believed that safety would be 

improved), most reported significant negative impacts on their operations. Among motor 

carriers, 24.5 percent indicated that two-person inspections would have little or no negative 

impact or a net positive impact on their operations. Some common themes included: 

• Operational feasibility 

o Team drivers – in some cases, this would require the driver to come out of the 

sleeper, with significant implications due to hours of service rules. 

o Availability of second person – for many carriers, additional staff are not 

available during all operational periods (such as late night) when pre-trip 

inspections are conducted. This would require hiring additional staff just to serve 

this inspection function. Additional staff may not be available in remote 

locations. 

• Cost 

o One company with 1,500 3-axle vehicles indicated it would add 16,500 hours per 

year (based on 220 days of operation per year). 

o Another company estimated the additional effort would require two technicians 

for two hours each day, seven days a week (1,456 hours per year). 

o Companies that reported total annual costs cited estimates of 

− $152,000 (10 minutes per driver per day × 45 drivers × 5 days per week × 

52 weeks per year × 2 drivers per inspection ≈ 4000 hours × $38 per 

hour), 

− $175,200 (800 buses × 3-axles × 1 minute per axle × $12 per hour = $480 

per day × 365 days per year), 

− $750,000, 

− $3.72 million (10 minutes per driver per day × 1,431 drivers × $60 per 

hour × 5 days per week × 52 weeks per year), and 

− $13 million (based on a minimum cost of at least $50,000 per day). 
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Certifying Brake Technicians 

Another indicated annual costs of $3,250 per driver, but did not indicate the 

number of drivers. 

Most carrier respondents seemed much more comfortable with the idea of drivers performing the 

inspections alone; however, the added cost and reduction in available driving hours was still an 

issue for many. Several carrier respondents still thought that a two-person inspection would 

provide better results and that the approach was preferred. Overall, about one-third of motor 

carriers indicated that one-person inspections would have little or no negative impact or a net 

positive impact on their operations. Representative issues included: 

• Reductions in driving time due to the inspection and necessary clean-up (as the drivers 

would get very dirty doing the inspections) would limit available driving hours 

o One motor carrier indicated that their drivers might not be able to unload and get 

home at the end of their day; another stated that it would increase the likelihood 

that a driver could not reload or take on a second load. 

o For motor carriers that quantified the total additional time required per day, the 

estimates of reduced available driving time were 14, 15, 20, 25, and 30 minutes in 

a 14-hour period. 

• Operational feasibility 

o Several respondents indicated that they were concerned about having their drivers 

getting dirty from crawling under a truck, particularly in adverse weather 

conditions such as rain or snow. While not specifically identified by any 

respondents, this would also apply to motor coach operators whose drivers 

typically wear a coat and tie. This would require additional time to change 

clothes or the use of a protective coverall. 

• Cost 

o One company with 1,500 3-axle vehicles estimated the effort to require 33,000 

hours per year, but believes the time required to be closer to 5-minutes per axle 

rather than 2-minutes per axle; resulting in an annual increase of 82,500 hours. 

o One motor carrier with 150 mostly 8- or 9-axle semi trailer trucks with 2 to 3 

trailers estimated annual costs exceeding $300,000. Others that quoted specific 

costs estimated total annual increased expenditures of 

− $11,400 (15 minutes per driver per day × 45 drivers × 5 days per week × 

52 weeks per year × 1 driver per inspection ≈ 3000 hours × $38 per hour), 

− $1.5 million, and 

− $13 million (based on a minimum cost of at least $50,000 per day). 

Another estimated annual costs of $6,500 per driver. 

There were also some recurrent themes that apply to the overall idea of drivers examining brakes 

as part of their pre-trip inspections. 
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Certifying Brake Technicians 

• Some felt that drivers were only qualified to do visual inspections and that only certified 

brake technicians were appropriate for physical inspections.* They stated that drivers 

should not be “overriding” certified technicians.† One respondent indicated that current 

union rules preclude drivers from performing these types of inspections. 

• There was also a concern from an insurance representative that drivers, even if required 

to crawl under the vehicle to physically inspect brakes, would not actually do it every 

time, particularly during inclement weather. Driver safety concerns included the 

provision of protective eyewear and headgear and additional clothing for those crawling 

under vehicles. Increased driver injuries could be expected from this activity. 

• Others felt that these inspections would increase the drivers’ familiarity with brake 

systems, thereby improving safety. One indicated that having two-person inspections 

would increase safety because “two people will see more and be more aware.” One 

person indicated that brakes could not be inspected enough and that the overall impact 

would be positive on his company’s operations. 

• A couple of carrier respondents indicated that they believed the time estimates for added 

inspection per axle were too low. One, mentioned above, indicated that 5 minutes for a 

one-person inspection was needed and the other indicated that a two-person inspection 

would take more than one minute per axle, as it is difficult to get to the brake chamber on 

their 7-axle trailers. 

Training content 

Some individuals contacted expressed specific ideas on what the training should include, subject 

to their beliefs on exactly what the driver should be required to do during a pre-trip inspection; 

they were not provided a list of specific inspection activities to be required. 

For those that felt the driver should not be required to crawl under the vehicle, one suggestion 

was to have the driver view the angle of the pushrod, the thickness of the pads, and the gap 

between the pads and drum; however, this would apply only to certain types of brake systems. 

Driver training optimums 

Respondents were asked about the appropriate amount of initial and refresher training and the 

frequency for refresher training for drivers. This training would include conducting pre-trip 

inspections and being able to identify brake deficiencies that were not correctly repaired by a 

technician. Table 4-2 provides a summary of the carrier responses.‡

 

*

 The reader should note that CMV enforcement officers are not certified brake technicians but are sufficiently 

trained and certified to perform brake inspections. 

†

 The premise for the NTSB recommendation for brake inspections during a driver’s pre-trip inspection assumes that 

a well-trained or equipped driver would be able to report defects independently of a brake technician. 

‡

 Again, some data obtained from associations interviewed represented several of their constituents. 
Assessment of Potential Benefits and Costs of 4-7 Final Report 

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Certifying Brake Technicians 

Table 4-2. Responses on Driver Training Class Time for Brake Inspection 

Initial Training Refresher Training 

Length % Length % Frequency % 

1 hour 2 1 hour 7 < 1 year 8 

2 hours 25 2 hours 72 Annually 43 

1/2 day 41 1/2 day 21 Biennially 28 

1 day 30 1 day 0 3-5 years 23 

2 days 2 2 days 0 Never 0 

1 week 0 1 week 0 

Note that totals may not sum to 100 percent due to rounding. 

The insurance representative indicated that 1/2 day was appropriate for both initial and refresher 

training and that refresher training should be conducted biennially. The testing organization felt 

that more time is needed for initial training—2 days—and that refresher training should be 

1/2 day and offered every 3 to 5 years. 

Anecdotally, one individual from a motor carrier mentioned that today’s drivers are generally not 

mechanically inclined and extensive training would be necessary to impart the appropriate 

knowledge. This individual was not able to recommend a specific amount of training, however. 

Data were also collected from carriers on the recommended class size for driver pre-trip 

inspection training, as shown in Table 4-3. 

Table 4-3. Responses on Driver Training Class Structure 

Class Size and Format % 

Individual – driver learns on his/her own 10 

Individual – one-to-one instruction 31 

Team – experienced senior driver with less experienced drivers 14 

Groups of up to 4 drivers per instructor 17 

Groups of 5 to 10 drivers per instructor 12 

10 to 20 drivers per instructor 9 

More than 20 drivers per instructor 7 

One carrier indicated that classroom training can accommodate up to 20 students; whereas, 

hands-on instruction should be limited to only four or five students. The insurance 

representative would recommend training in groups of up to four drivers per instructor. The 
Assessment of Potential Benefits and Costs of 4-8 Final Report 

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Certifying Brake Technicians 

school indicated that training, in general, should be able to accommodate each individual’s 

requirements and learning style. 

When carriers were asked about the effort required to convert their current class size and format 

to the optimum (as they saw it), only 6 percent indicated that they were already using the 

optimum configuration. Forty-eight percent would require a little effort and 45 percent would 

require a considerable effort. 

Based on carrier responses, drivers learn best when there is a combination of hands-on training 

used in conjunction with classroom instruction. Some indicated that a video could suffice for 

classroom instruction, provided the drivers still had an opportunity for hands-on experience. The 

insurance representative felt that formal one-on-one instruction followed by hands-on experience 

was the preferred approach among the motor carriers he insured. 

Most carriers would develop additional required training for drivers in-house (79 percent). The 

insurance representative also indicated that in-house development was likely among his carriers. 

The average annual salary of driver trainers was reported to be $40,000 to $60,000 for salaried 

drivers and $10 to $20 per hour for drivers paid hourly. 

Driver training recordkeeping is done in-house (98 percent) and slightly more than half done inhouse is done manually (56 percent). Of the recordkeeping done electronically, listed systems 

included standard spreadsheet and database programs and custom systems. The one carrier that 

indicated their recordkeeping was handled by a third party cited monthly costs of $495 to cover 

eight drivers. 

4.2.2 Training and Certification of Brake Inspectors 

As highlighted by the testing and certification organization, “the scope of the technical [training] 

content is quite different for an individual performing brake inspections from that of the 

technician who must also have the requisite knowledge and skill to diagnose and repair 

deficiencies identified in the inspection process.” 

For those carriers who have technicians as employees (some do not), an average of 73 percent of 

the technicians were brake inspectors per 49 CFR 396.25(b). In 75 percent of motor carriers, 

drivers were not brake inspectors, but at least some drivers were brake inspectors in 25 percent 

of the motor carriers from which data were obtained. The insurance representative indicated 

that, for the motor carrier they insure, approximately 90 percent of the technicians are brake 

inspectors. 

Not a single carrier would alter the number of technicians from current levels if certification of 

brake inspectors were required. 
Assessment of Potential Benefits and Costs of 4-9 Final Report 

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Certifying Brake Technicians 

Brake inspector training optimums 

Respondents were asked about the appropriate amount of initial and refresher training and the 

frequency for refresher training for brake inspectors. This training would include conducting 

proper inspection, maintenance, service, and repair of CMV brake systems as well as appropriate 

testing and certification as recommended by the NTSB. Table 4-4 provides a summary of the 

carrier responses.*

Table 4-4. Responses on Brake Inspector Training Class Time 

Initial Training Refresher Training 

Length % Length % Frequency % 

1 hour 0 1 hour 0 < 1 year 7 

2 hours 7 2 hours 57 Annually 29 

1/2 day 21 1⁄2 day 29 Biennially 36 

1 day 50 1 day 7 3-5 years 29 

2 days 14 2 days 7 Never 0 

4 days 7 4 days 0 

Note that totals may not sum to 100 percent due to rounding. 

Carriers that recommended a longer initial training class also recommended longer periods 

between refresher training. The insurance representative indicated that two days was appropriate 

for initial training of brake inspectors and that refresher training should be offered biennially as a 

one-day class. The testing organization representative felt that 4 days was appropriate for initial 

training and that 1/2-day refresher training should be offered biennially. The school felt that 

more than one week was necessary for initial training and that a full day of refresher training 

should be completed annually. 

Data were also collected from carriers on the recommended class size for brake inspector 

training, as shown in Table 4-5. 

 

*

 Again, some data obtained from associations interviewed represented several of their constituents. 
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Certifying Brake Technicians 

Table 4-5. Responses on Brake Inspector Training Class Structure 

Class Size and Format % 

Individual – technician/inspector learns on his/her own 5 

Individual – one-to-one instruction 14 

Team – experienced senior technician/inspector with less 

experienced technician/inspector 

27 

Groups of up to 4 technicians/inspectors per instructor 2 

Groups of 5 to 10 technicians/inspectors per instructor 23 

10 to 20 technicians/inspectors per instructor 9 

More than 20 technicians/inspectors per instructor 0 

The insurance representative indicated that on-the-job training is the best approach for training 

brake inspectors. A school indicated that more than 20 technicians/inspectors per instructor was 

the optimal learning arrangement. Most of the carrier respondents indicated that hands-on 

training was the most effective, with some mentioning the added benefit of video or classroom 

training in addition to the hand-on learning. The school stated that it was best to evenly split the 

time between classroom and hands-on training. 

Employee training recordkeeping for brake inspectors was done primarily manually in-house 

(88 percent), with the remaining done electronically in-house (using either custom software or 

integrated commercial business applications, including those from PeopleSoft and TMW 

Systems Inc.). This is consistent with the response from the insurance representative indicating 

manual in-house recordkeeping. 

Training challenges 

According to the respondents, the challenges that carriers face with delivering effective training 

for brake inspectors include: 

• Not all employees are fluent in English. 

• Many brake inspectors have never familiarized themselves with the FMCSRs and the 

requirements in 49 CFR 393 and 396 and Appendix G to Subchapter B, Minimum 

Periodic Inspection Standards. 

• Employee turnover. 

• Fitting training into the normal work schedule, while maintaining the ability to continue 

operations. 

• Providing defects to diagnose (i.e., components with defects for use in hands-on training). 

• Wide variety of system designs. 
Assessment of Potential Benefits and Costs of 4-11 Final Report 

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Certifying Brake Technicians 

Accreditation 

Only one quarter of carriers contacted for this study indicated that they have developed a 

structured periodic brake inspection accreditation program for their company technicians, usually 

conducted annually (one respondent repeated the accreditation every three years). However, 

only one of these extended the program to their third-party vendors. 

Just over one third of carriers contacted for this study indicated that they have developed a 

structured periodic brake inspection training program for their company technicians, usually 

conducted annually (one respondent repeated the training every two years). Two of these 

carriers extended their programs to their third-party vendors. 

The testing and certifying organization provided some general comments that are illustrative of 

the key issues in the area of accreditation: 

• Independent, third-party certification is an objective method of validating training, 

provided the assessment is defined, developed, and specified by persons knowledgeable 

in the subject area. This is one of the key tenets, and perhaps the greatest value of 

Automotive Service Excellence (ASE) certification; the test specifications, task lists, and 

questions are all developed by technicians and other subject matter experts with 

experience gained working in the field on a daily basis. These subject matter experts also 

establish the passing score for a given certification area. Certification by an independent, 

third-party entity is a recognized and accepted means of validating knowledge gained 

through training. 

• The NATEF evaluates secondary and post-secondary medium/heavy (M/H) truck 

technician training programs against standards developed by the automotive industry and 

recommends qualifying programs for certification (accreditation) by ASE. The current 

Instructional Standards for M/H Truck Brake Systems include 105 hours of instruction 

broken down into 66 tasks that incorporate the brake inspection requirements in 

Appendix G to Subchapter B of the FMCSRs. Substantially meeting these instructional 

tasks is mandatory to achieve certification (accreditation). Additionally, an optional 

certification area in the NATEF standards for M/H Truck programs is Preventive 

Maintenance, requiring another 105 hours of instruction, including brake inspection tasks 

that, again, substantially meet the requirements of Appendix G to Subchapter B of the 

FMCSRs. 

• The NATEF process has resulted in certified automotive training programs in all fifty 

States at the secondary and post-secondary levels. NATEF also evaluates the providers 

of in-service technician training programs under a program called Continuing 

Automotive Service Education (CASE). 

• The ASE offers eight certification specialties within the M/H Truck series. Two of those 

certifications (T4–Brakes and T8–Preventive Maintenance Inspection) seem to fulfill or 

exceed the brake inspection requirements outlined in Appendix G to Subchapter B of the 

FMCSRs. The cost of this certification is $57, including a $32 registration fee and $25 

testing fee. 
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Certifying Brake Technicians 

4.2.3 Safety and Economic Impacts on Brake-related Crashes 

Almost all carriers estimated that brake system malfunction or failure was a factor in none of 

their DOT-reportable CMV crashes. The only carrier reporting a non-zero figure indicated that it 

was less than 5 percent. However, the insurance representative also reported that the motor 

carriers that they insure averaged around 5 percent brake-related DOT-reportable crashes, with 

an average of about 10 DOT-reportable crashes per year per motor carrier. A bus motor carrier 

indicated that they experience about five DOT-reportable crashes per year (and operate 700 

buses). The median number of DOT-reportable crashes among all motor carriers that reported a 

value was 15, although one motor carrier reported 131 (1,550 power units) and two motor 

carriers reported 239 and 250, respectively (and 8,586 and 8,000 power units, respectively). The 

latter motor carrier, reporting 250 crashes, was the only motor carrier that indicated a non-zero 

brake-related crash percentage, as stated above. The testing and certification organization, 

however, estimated that 10 percent of all DOT reportable crashes involve brake system 

malfunction or failure. 

The turnover rate for brake inspectors is generally fairly low, with 64.3 percent of carriers 

indicating rates less than 2 percent, 14.3 percent were less than 10 percent, and the remaining 

21.4 percent were in the 20 to 25 percent range. Interestingly, the insurance representative 

estimated the turnover rate for brake inspectors to be 30 percent. In this analysis, the brake 

technician turnover rate is assumed to be 15 percent. 

Interviewees were asked their opinions about the safety impact of implementing the NTSB 

recommendations—having drivers conduct pre-trip brake inspections and certifying brake 

inspectors—and 56 percent indicated that there would be no positive impact, 6 percent were 

unsure, and 38 percent predicted a decrease in crashes. The estimates of decreased crashes 

ranged from less than one percent all the way up to a 100 percent decrease. The average 

estimated decrease from these respondents was 28 percent. The insurance representative 

indicated a 0.5 percent decrease in all crashes as a result of implementing the recommended rule 

changes. 

Most felt that such a program would be beneficial, even if they did not estimate a decrease in 

crashes. They cited better-educated drivers and brake technicians, improved awareness of proper 

maintenance procedures, and lower brake repair costs. Some indicated that they were already 

implementing some form of the recommendations, but that other companies could benefit. The 

testing organization felt that while having drivers conduct pre-trip inspections would produce a 

benefit in terms of reduced crashes, it would be significantly more beneficial to have certified 

brake technicians and inspectors perform that function. They believe that “the differences in 

existing brake systems used on medium/heavy commercial vehicles and the technical knowledge 

and familiarization of these systems extends beyond the reasonable expectation for drivers.” 

They also feel that new technology in brake systems will likely increase the amount of 

information necessary to perform proper brake inspections. 
Assessment of Potential Benefits and Costs of 5-1 Final Report 

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Certifying Brake Technicians 

5. SAFETY ANALYSES

This section of the report details the findings of the economic analysis, which estimates the 

societal benefits and costs of implementing the NTSB recommendations. The primary benefits 

of the recommendations are the safety impacts of crash prevention, avoidance of high crash 

costs, avoidance of fines due to violations associated with brakes being OOA, and avoidance of 

costs resulting from OOS brake violations due to the improved manner in which brakes are 

tested and maintained on commercial motor vehicles. The primary costs of the recommendations 

include the following: the costs of driver and brake inspector training, per trip driver inspection 

costs, and the costs associated with brake inspector testing and certification. 

Analysis of these benefit and cost items above have been quantitatively estimated over a 10-year 

analysis period. Since most of the costs are expected to occur on an annual basis, given that the 

NTSB recommendations are for an ongoing program while only the initial training costs will be 

borne in the first year, the examination is based on a 10-year analysis time frame, from 2005 to 

2014. There are no capital costs (i.e., outlays for capital investment in equipment, buildings or 

property) associated with implementing the NTSB recommendation for certifying commercial 

motor vehicle brake technicians. A discount rate of 7 percent was used to construct the net 

present value estimate in the baseline scenario as prescribed in the OMB Circular A-94 (OMB, 

2002). In order to examine the sensitivity of the analysis to discount rates, scenarios using 

discount rates of 4 and 10 percent were also examined. All benefit and cost items were 

combined to compute benefit-cost ratios (BCRs) as depicted in Figure 5-1. To the extent that 

benefits exceed costs, the BCR exceeded 1.0. BCRs of less than 1.0 indicate negative economic 

returns to society. 

5.1 Background Crash Data for Benefits Assessment 

This subsection establishes CMV brake data estimates for use in benefit-cost analyses. Estimates 

are provided for crashes prevented and mitigated through the implementation of an enhanced 

brake maintenance, certification, and inspection program for technicians and an enhanced brake 

inspection program for drivers. Estimates of the number of crashes that potentially could either 

be mitigated or prevented with the new program are based on a direct analysis of the LTCCS 

data, as well as the values provided by the motor carrier, insurance, and crash investigator 

interviews. Developing the predicted effectiveness of the enhanced inspection program in 

preventing or mitigating brake related crashes relies on engineering judgment. The study team 

drew on its expertise in brake function, crash analysis, and familiarity with how brakes operate in 

a crash environment. 
Assessment of Potential Benefits and Costs of 5-2 Final Report 

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Figure 5-1. Data Elements Combined to Determine Societal Benefit-cost Ratios 

5.2 Benefits Assessment 

The benefits associated with the NTSB recommendations are those related to safety as measured 

by the prevention of crashes involving CMVs, the avoidance of the monetary costs for these 

CMV crashes, the reduced number of OOS brake violations, and reduced levels of fines 

associated with violations resulting from brakes being OOA. These benefits are explored 

individually in the following sections. 

10 Year Analysis 

Time Frame

Total Life-cycle 

$ Benefit

Initial Training 

Cost

Employee Hourly Salary 

and Fringe Benefits 

Time per Employee 

Required for Training

Annual National 

Training Cost 

Total Life-cycle 

$ Cost

Benefit-cost 

Ratio

Property and 

Equipment 

Damage

Medical Costs

Fringe Benefits

Fatalities

Personal Injuries

Avoided OOS 

brake violations

Numbers of Incidents 

Avoided Annually

Annual Benefits

Total Cost 

per Crash 

Lost 

Productivity 

Workers’

Compensation

Fines and 

Penalties 

Worker 

Recruitment 

and Training 

Crash 

Investigation / 

Litigation 

Initial Costs Annual Costs 

Driver and Brake 

Inspector Population

Annual National 

Brake Inspections 

Costs

Annual National 

Certification and 

Testing Cost 

Annual National 

Administrative Costs 

Number of per-trip Inspections

Average Time per Inspection

Payments made to 

Testing/Certification Organizations

Frequency of 

Renewal 

Class Size and Employee 

Turnover Rates

Time Required to 

be Tested 
Assessment of Potential Benefits and Costs of 5-3 Final Report 

Revising Brake Inspection Procedures and July 31, 2006 

Certifying Brake Technicians 

5.2.1 Safety Impacts 

This section examines the approach used to estimate the number of CMV crashes that would be 

prevented if improved brake maintenance and inspection procedures were implemented and the 

monetary benefits associated with avoiding CMV crashes. Data used in the study, along with 

sources, are also cited in this section of the report. 

5.2.1.1 Avoidable Truck Crashes 

Studies and databases surveyed for the project were examined to determine the most appropriate 

sources to use for estimating the number of truck crashes that may have been caused by brake 

problems. Databases describing the results of post crash inspections seemed to be most 

appropriate. The LTCCS and the MCMIS inspection file both include the results of post crash 

inspections. The LTCCS data files currently include data for 1,070 trucks (includes some data 

collected for trucks during a pilot study). The LTCCS shows that brake problems exist in about 

30 percent (321 out of 1,070) of the post-crash inspections conducted for the study. MCMIS 

post-crash inspection data show that brake defects or deficiencies existing prior to the crash were 

found in only about 8 percent of the post-crash inspections. 

An examination of data included in other studies in the project literature search indicates that the 

percentage for brake problems included in the LTCCS data analysis provides a reasonable 

estimate of brake problems that may cause a crash. For example, CVSA provides a detailed 

summary of data from Operation Air Brake for the years 1998 to 2004. During those years, 

Operation Air Brake checked 66,941 trucks during roadside inspections. Of these, 11,360 

(16.97 percent) have had an OOS brake condition. The percentage of brake problems found in 

inspections of trucks after a crash would be expected to be much higher than those found in 

inspections of operating vehicles. In another study, 667 crashes involving 734 large trucks 

(greater than 10,000 pounds) in Washington State were investigated over a two-year period. 

When the sample was then limited to tractor trailers (about 60 percent of the crash sample), 

trucks with brake defects were present in 56 percent of the crash sample. This study did not use 

as representative a sample as the LTCCS and, therefore, may have found a higher percentage of 

brake problems than the LTCCS. In other words, the Washington State study did not use a 

representative statistical sampling approach to selecting the crashes to include and may have 

over-sampled crashes involving brake defects. 

Due to the thoroughness of the LTCCS and the bounding results of other studies, the LTCCS 

was used for this study in order to estimate the number of brake-caused crashes that would be 

prevented or had their severity reduced if the brake training, certification, and maintenance 

program based on NTSB recommendations (described in Section 1.1) were introduced. The 

great majority of the crashes in the study involved trucks with air brakes. About 90.1 percent of 

the trucks inspected in the post-crash investigations had air brakes, about 7.6 percent had 

hydraulic brakes and the remainder, about 2.3 percent, had unknown brake types. 
Assessment of Potential Benefits and Costs of 5-4 Final Report 

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Certifying Brake Technicians 

The LTCCS includes data for four types of truck brake problems related to a particular crash: 

brake failure, brake inoperable, brakes OOA, and brakes deficient. The problems are defined as 

follows: 

• Out of adjustment: If any of the brakes were measured as OOA, then this variable 

would be recorded as present. 

• Brakes inoperative: This problem is present if the brakes are not working for any 

reason. If the brakes are inoperative because they are severely OOA, they might be 

recorded in the OOA category. 

• Brake system malfunction (failure): This variable establishes whether or not the 

vehicle experiences a braking system malfunction (total failure such as pedal to the floor) 

during the pre-crash phase (may not include a malfunction due to OOA). 

• Brake system deficiency: Braking system deficiency records any problem other than 

brake OOA. It includes the following: worn pads, unmatched brakes, hose connection, 

air pressure, brake fade, etc. 

In order to assess the contribution of each of the brake problems, the data were grouped in 

categories because, in some cases, more than one brake problem was identified for a particular 

vehicle. The brake problem types were grouped in a hierarchy according to the problem 

considered most important, or most likely to contribute to a crash: brake failure, brake 

inoperative, brake system deficiency, and brakes OOA. 

Brake failure accounted for 12 crashes, although an additional brake problem also existed in two 

of the crashes. Similarly, the 23 “brakes inoperative” problems identified for a crash were 

grouped as one category despite the fact that 13 of the crashes also had another brake problem 

associated with them. For brake system deficiency, 97 of the 121 crashes where brake 

deficiency was listed had only that factor. Twenty-four of the crashes also included brakes OOA 

as a factor. Those 24 crashes were placed in the brake system-deficiency category because of the 

hierarchy used in the analysis. One hundred and sixty-five crashes were characterized by brakes 

OOA alone. 

The next step was to determine the percentage of the crashes that were unlikely to be influenced 

by the truck’s brakes. These were the crashes where another vehicle hit the truck from behind. 

About 23 percent of the crashes with brake problems fall into this category. Thus, the number of 

crashes eligible as candidates for causing a crash is reduced by 23 percent, reducing the 321 

eligible crashes to 247. The distribution of the brake problems among the 321 crashes in the 

LTCCS is shown in Table 5-1 along with the number of eligible crashes with identified brake 

problems after the “truck was hit from behind” accident type was eliminated from the total 

crashes. 
Assessment of Potential Benefits and Costs of 5-5 Final Report 

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Certifying Brake Technicians 

Table 5-1. Distribution of Crashes among Brake Problem Categories 

in the LTCCS 

Brake Problem Category Number of Crashes 

Number of Brakerelated Crashes 

Brake Failure 12 9 

Brake Inoperative 23 18 

Brake System Deficiency 121 93 

Brakes Out of Adjustment 165 127 

Total 321 247 

Next, the role that the various brake problems play in causing a crash was determined. Although 

more than one brake problem was sometimes associated with a crash, for this step, causation was 

linked to the most serious problem in the category. Because the data in the LTCCS provided 

insufficient detail concerning the behavior of individual brakes and the exact nature and severity 

of a particular brake problem, the Battelle Team was unable to estimate precisely the role that a 

brake mechanical problem may have played in leading to a crash. Therefore, since the team 

understood that other pre-crash factors such as human error also might be in play, engineering 

judgment was used to estimate the number of crashes that would either be avoided or mitigated if 

the brake problem could have been eliminated before the crash occurred. As shown in Table 5-1, 

the number in each brake category found in the first column already has been reduced by 

subtracting the percentage of crashes where the crash type involved another vehicle striking the 

CMV from behind. For each of the four categories of brake problems, engineering judgment 

was first applied to determine the likelihood that the crash would either have been prevented or 

mitigated if the brake problem had been eliminated. Next, the percentage of crashes that would 

have fallen into each of those two categories was estimated. The discussion below describes 

how the particular brake crash category was allocated into either the crash-prevented or crash 

impacts-mitigated categories. 

• Brake system malfunction (failure): For this brake problem category, it was estimated 

that all (100 percent) of the nine crashes (excluding where the truck was hit from behind) 

would have been prevented if the total brake failure had been prevented through proper 

maintenance and inspection. 

• Brakes inoperative: For the brakes inoperative category, where the brakes are not 

working, it was assumed that by preventing these problems, all 18 crashes (excluding 

where the truck was hit by another vehicle from behind) would have either been avoided 

or mitigated through proper maintenance and inspection. This percentage was further 

assumed to be about 50 percent where the crash would have been avoided (nine crashes) 

and 50 percent where the crash would have been mitigated (nine crashes). 

• Brake system deficiency: The team evaluated this category to be the third most serious 

of the four brake problem categories. The team applied engineering judgment to 

conclude, based on the nature of brake problems in this group, that about half (50 
Assessment of Potential Benefits and Costs of 5-6 Final Report 

Revising Brake Inspection Procedures and July 31, 2006 

Certifying Brake Technicians 

percent) of the 93 crashes in this category (47 crashes) would either be avoided or 

mitigated if the brake system deficiency had been prevented through proper maintenance 

and inspection. It was further assumed that about half of the 47 crashes would be 

avoided and half mitigated if brake problems had been prevented. 

• Out of adjustment: The team estimated that about 25 percent of the crashes identified 

in the brake OOA category (32 out of 127 crashed) would have been prevented or 

mitigated if this problem had been eliminated through proper maintenance and 

inspection. This percentage was selected because the post-crash inspection required only 

one brake to be identified as OOA to be placed in this category. However, if only one 

brake was OOA, the stopping power of the vehicle would not have been significantly 

reduced, and consequently would not have been the cause of the crash. Battelle also 

estimated that if this braking problem were eliminated, 16 of the 32 crashes would have 

been avoided and 16 mitigated. A better estimate could be placed on this category if the 

number of axles on each vehicle and the number of OOA brakes were known; however, 

the LTCCS did not provide this level of detail. 

Table 5-2 shows the four categories of brake problems with the number of crashes that could 

have been caused by brake problems and the breakdown into whether preventing the brake 

problem would have resulted in either avoiding a crash or reducing a crash’s severity. For the 

purposes of this analysis, the assumption was made that if a crash were mitigated by fixing or 

preventing a brake problem, then the crash impacts would have been reduced by 50 percent. 

Table 5-2. Examination of Brake Safety 

Brake Problem 

Category 

Number 

in 

Category

Number of 

Crashes Caused 

by Problem 

Number of 

Crashes 

Avoided 

Number of Crashes 

with Consequences 

Reduced by 50% 

Brake Failure 9 9 9 0 

Brake Inoperative 18 18 9 9 

Brake System Deficiency 93 47 23 24 

Brakes Out of Adjustment 127 32 16 16 

Totals 247 106 57 49 

In order to estimate the percentage of truck crashes that could be averted by the implementation 

of an enhanced training and brake maintenance program, the number of crashes shown under the 

“Number in Category” column in Table 5-2 must first be converted to the “Number of Crashes 

Caused by Problem” as shown in column 3 of the table. The next step is to convert the number 

of crashes caused by the problem to either “Number of Crashes Avoided” (column 4) and/or 

“Crashes with Consequences Reduced” (column 5). For example, in order to calculate the 

numbers in Table 5-2 for “Brakes Inoperative” (column 1), the project team used the 

assumptions found under each brake problem category and discussed above. Therefore, for 

“Brake Inoperative,” this is considered the second most serious brake problem and all of the 
Assessment of Potential Benefits and Costs of 5-7 Final Report 

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Certifying Brake Technicians 

eligible crashes characterized by this problem and found in the “Number in Category” column 

were estimated to have caused crashes. Table 5-2 shows that the 18 crashes in the “Number in 

Category” column remain 18 in the “Number of Crashes Caused by Problem” column. The next 

step is to allocate the number of estimated crashes caused by the problem to either crashes 

avoided or crashes with the consequences reduced. Based on the discussion of brakes 

inoperative above, the assumption was made that if the brake problem could have been prevented 

or repaired before a crash, then half of the crashes would have been avoided (9 crashes) and half 

of the crashes would have been mitigated (9 crashes). 

In order to estimate the percentage of truck crashes that would either be avoided or mitigated 

once an enhanced training and brake maintenance program was implemented, the project team 

first estimated the percentage of crashes that would have been avoided if the new program was 

fully effective in preventing or repairing brake malfunctions. (Bus crashes are discussed in the 

next section.) To calculate this number, the total number of crashes avoided, as shown in Table 

5-2, was compared with the LTCCS 1,070 sample number to arrive at a percentage of all crashes 

that would have been avoided. The percentage of crashes that would be avoided if the brake 

problem could be eliminated would be 5.3 percent of all crashes. This percentage is calculated 

by dividing the Total Number of Crashes Avoided in Table 5-2 by the total sample number. That 

is, by dividing the 57 crashes avoided by the 1,070 crashes in the sample. 

Second, to obtain a percentage of the total number of crashes that would be mitigated, the total 

number of crashes mitigated as shown in Table 5-2 was compared with the LTCCS 1,070 sample 

number to arrive at a percentage of all crashes that would have been mitigated. The number of 

crashes listed under the Total for Consequences Reduced in Table 5-2 is 49. When 49 is divided 

by the 1,070 LTCCS sample total, 4.6 percent of the total crashes are estimated to have their 

consequences mitigated. Thus, about 10 percent (9.9 percent) of all crashes could either be 

avoided or mitigated if the enhanced brake maintenance and training program was 100-percent 

effective. This percentage (10 percent) falls within the range of 1 to 40 percent estimate of 

crashes that could be prevented that the project team received as estimates from interviewees 

with brake expertise. 

 

Finally, in order to estimate the percentage of truck crashes that either would be avoided or 

mitigated once an enhanced training, certification, and brake maintenance program was 

implemented, the Battelle Team had to estimate the effectiveness of the new program. The team 

assumed that the new program would unlikely be 100-percent effective. Some quality problems 

will always exist and shortfalls may continue to exist in training and effectiveness of 

maintenance and inspection programs. Although the team had no precise metrics to calculate 

new program effectiveness, based on their experience working with changes in vehicle 

maintenance and inspection programs, the team applied their best judgment to develop the 

assumption that the new program would experience program shortfalls in about 30 percent of the 

brake program activities. Thus, the new program would have an estimated effectiveness of 

70 percent. Therefore, the enhanced NTSB recommended brake program (See Section 1.1) 

would result in either avoiding or mitigating about 7 percent (10 percent × 70 percent) of the 

total crashes. This number still falls within the range obtained in the survey results. Although 

the 70-percent program effectiveness estimate represents the project team’s best assumption, the 
Assessment of Potential Benefits and Costs of 5-8 Final Report 

Revising Brake Inspection Procedures and July 31, 2006 

Certifying Brake Technicians 

project team believes it appropriate to perform a sensitivity analysis for a range of effectiveness 

levels. Section 5.4, Benefit-cost Analysis, examines cost-benefit for effectiveness levels of 50, 

60, 80, and 90 percent as well as at the 70-percent program effectiveness level for both crashes 

avoided and crashes mitigated. 

Utilizing the results from the above analysis of LTCCS, about 10 percent of the 416,000 policereported crashes found in the most recent Large Truck Crash Fact Book, 2002 data could 

reasonably have been caused by faulty brakes and could either be avoided or mitigated if the new 

brake training and maintenance program was 100 percent effective. However, when the assumed 

70 percent program effectiveness is used, only 7.0 percent of all crashes would be affected. 

When the data are examined in more detail, 3.6 percent of all crashes would be avoided. The 

percentage of crashes avoided is estimated by assuming that 70 percent of the 57 shown in Table 

5-2 for “Total Crashes Avoided” (about 40) would actually be avoided under the enhanced 

program. This percentage is about 3.6 percent of the total crashes in the LTCCS sample. To 

calculate the estimated number of crashes avoided, 5.3 percent is multiplied by the 416,000 

police reported crashes in 2002. The resulting number, 22,161, is then multiplied by the 

assumed 70 percent program effectiveness rate to give 15,513 annual crashes. When rounded, 

this results in about 15,550 crashes avoided. A similar calculation to estimate the number of 

annual crashes mitigated shows that about 3 percent of the 416,000 crashes would be mitigated 

after the 70 percent efficiency rate is applied. This means that about 13,340 annual crashes 

would have their consequences reduced by half under the enhanced program. 

In order to break down benefits between the two parts of the NTSB recommendations—driver 

training and pre-trip inspections and brake inspector training and certification—a small number 

of trucking industry representatives were contacted in order to allocate the benefits between the 

two recommendations.*

 Each of the trucking industry representatives contacted stated that the 

vast majority of the benefits would result from the brake inspector training certification. These 

views were echoed at a presentation of preliminary findings.† Reasons given for the limited 

usefulness of driver inspections included: 

• High driver turnover rates, 

• Lack of knowledge concerning vehicle maintenance techniques, 

• Limitations in union contracts, 

• Physical constraints, 

• Aversion to the liability risk, and 

• Lack of willingness to crawl under vehicle. 

Based on this input, a range of 10 to 30 percent of the benefits are assumed to be generated 

through driver training and inspection programs. The remainder, 70 to 90 percent, were 

attributed to the proposed brake inspector training and certification programs. 

 

*

 Telephone interviews with Paul Abelson, Marc Clark, Peggy Fisher, and Bob Flesher. October 14, 2005. 

†

 Presentation delivered to the Brake Maintenance Technical Advisory Task Force at the TMC Fall Meeting, 

September, 2005. Valley Forge, Pennsylvania. 
Assessment of Potential Benefits and Costs of 5-9 Final Report 

Revising Brake Inspection Procedures and July 31, 2006 

Certifying Brake Technicians 

5.2.1.2 Avoidable Bus Crashes 

Total bus crashes are listed in National Transportation Statistics report for 2003 (BTS 2004). 

In 2002, there were an estimated 58,000 bus crashes. The National Transportation Statistics 

figure also includes transit and school buses. However, identifying the number of intercity buses 

subject to FMCSA rules involves identifying the number of crashes involving buses not subject 

to FMCSA rules and subtracting them from the total number of crashes. Transit and school 

buses operate in a completely different environment from intercity motor coaches and many 

other passenger CMVs subject to FMCSA’s jurisdiction. Several sources including the 

American Bus Association, National Safety Council, FMCSA databases, and FARS were 

investigated to determine the number of intercity bus crashes alone. The project team 

determined that data from the Transit Bus Integrated Vehicle-Based Safety Systems (IVBSS) 

project provides the best available data and would be used to estimate the annual number of 

intercity bus crashes (FTA 2004). This project began its process to estimate intercity and 

intracity bus crashes by first calculating the number of transit and school bus crashes and then 

subtracting this number from all bus crashes. When these data are used, the annual number of 

intercity bus crashes is estimated at about 7,800. The assumption used for this analysis is that 

the same percentage of intercity bus crashes as was the case with trucks could be caused by 

brake problems. When the same percentage figure of crashes that could have been caused by 

brakes and the same estimated 70 percent program efficiency level are applied to the 7,800 

crashes, about 291 crashes could have been avoided by the implementation of the enhanced 

NTSB recommended brake program. Similarly, about 250 crashes annually could have been 

mitigated if the new training, certification, and inspection programs were in place. As for truck 

crashes discussed in Section 5.2.1.1, the assumptions for distributing benefits between the two 

NTSB recommendations were also applied here. A sensitivity analysis of a range of program 

effectiveness levels is applied to bus crashes in Section 5.4. 

5.2.1.3 Avoided Costs of CMV Crashes 

The CMV crash data presented in the preceding sections are multiplied by the societal costs of 

such crashes to determine program benefits or, more specifically, the costs that would be avoided 

by reducing the number of CMV crashes. The most recent and comprehensive estimates of the 

societal costs of truck and bus accidents are presented in the Pacific Institute’s Revised Cost of 

Large Truck and Bus-Involved Crashes, prepared for FMCSA in 2002 (Zaloshnja, 2002). The 

societal costs as estimated by this report associated with heavy truck crashes and bus crashes are 

$59,153 and $32,548, respectively.*

 These costs, which are represented in 2000 dollars, were 

inflated to 2005 dollars—inflated to $66,813 for large trucks and $36,763 for buses—based on 

growth in the Consumer Price Index. These costs comprise medical-related costs, emergency 

services, property and equipment damage, lost productivity (e.g., wages, fringe benefits, claims 

processing costs, litigation costs, crash investigation costs, recruiting and training replacement 

for disabled workers), and monetized quality-adjusted life years. 

 

*

 The cost estimates presented in Zaloshnja 2002 are based on data related to police-reported crashes for trucks with 

gross vehicle ratings in excess of 10,000 pounds and all transit and intercity buses. Thus, the bus crash estimate is 

based on data collected on crashes involving both transit and intercity buses. 
Assessment of Potential Benefits and Costs of 5-10 Final Report 

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The number of truck- and bus-involved crashes expected to be averted with implementation of 

the recommendations are expanded over the 10-year time horizon using a truck motor carrier 

growth rate based on the American Trucking Associations’ U.S. Freight Transportation Forecast 

to 2016 (ATA, 2005). Furthermore, the estimates of total bus crashes are expanded based on 

motor carrier growth as estimated based on historic growth rates of private commercial buses 

from 1993-2003. This data is found in Federal Highway Statistics in Table MV-10 (FHWA, 

2004). 

To construct estimates of the benefits associated with crash avoidance the total number of 

estimated crashes avoided due to the implementation of the NTSB recommendations—16,941 

for trucks and 308 for buses in 2005—were multiplied by estimated societal costs per crash 

($66,813 for trucks and $36,763 for buses). The number of avoidable truck crashes was assumed 

to grow by 3 percent annually based on forecast growth in the trucking industry.*

 The number of 

bus crashes avoided and mitigated through the implementation of the NTSB recommendations 

was estimated to grow by 1.9 percent annually based on historic growth rates in the number of 

intercity buses.† The dollar values estimated for crash mitigation is the product of the estimated 

number of mitigated crashes (14,563 for trucks and 265 for buses) and the societal costs per 

crash divided in half. As noted previously, we assume that mitigated crashes would generate 

roughly half the costs relative to those crashes that would be avoided. 

Based on the aforementioned assumptions, total crash cost savings are estimated at $18.7 billion 

over the 10-year analysis time horizon. Of this amount, $18.5 billion or 99 percent are attributed 

to the reductions in large truck crashes while $176.6 million are attributed to intercity bus 

crashes. Discounting these values at 7 percent results in an estimated $13.8 billion in avoided 

costs due to enhanced safety over the 10-year (2005-2014) time horizon. These benefits are 

shown in Table 5-3. 

5.2.2 Out-of-Service Violation Impacts 

For OOS truck violations, several surveys such as Operation Airbrake could have been used to 

provide the basis for estimating how many OOS violations could have been prevented by the 

adoption of the enhanced maintenance and inspection activities. The assumption made for this 

analysis is that the MCMIS data for OOS brake-related violations is most appropriate because it 

reflects the actual inspections that a carrier was subjected to by a “qualified technician” in a year. 

Consequently, any reduction in OOS violations derived from the implementation of the enhanced 

brake maintenance and inspection activities should be estimated using the MCMIS OOS data. 

OOS data for 2002, 2003, and 2004 from MCMIS are shown in Table 5-4. 

 

*

 American Trucking Association, U.S. Freight Transportation Forecast to 2008. Washington, D.C. 

†

 Bureau of Transportation Statistics. National Transportation Statistics. 2004. Washington, D.C. 

http://www.bts.gov/publications/national_transportation_statistics/2005/html/table_bus_profile.html 

 
Assessment of Potential Benefits and Costs of Revising 5-11 

Brake Inspection Procedures and Certifying Brake Technicians 

Table 5-3. Benefits Associated with Avoided Crash Costs 

Avoided Mitigated Avoided Mitigated

2005 16,941 14,563 308 265 1,618,404,577 16,187,163 1,634,5

 

2006 17,446 14,997 314 270 1,666,633,033 16,498,149 1,683,1

 

2007 17,966 15,444 320 275 1,716,298,697 16,815,111 1,733,1

 

2008 18,501 15,905 326 280 1,767,444,399 17,138,161 1,784,5

 

2009 19,053 16,378 332 286 1,820,114,242 17,467,419 1,837,5

 

2010 19,620 16,867 339 291 1,874,353,646 17,803,001 1,892,1

 

2011 20,205 17,369 345 297 1,930,209,385 18,145,032 1,948,3

 

2012 20,807 17,887 352 302 1,987,729,624 18,493,633 2,006,2

 

2013 21,427 18,420 359 308 2,046,963,967 18,848,931 2,065,8

 

2014 22,066 18,969 365 314 2,107,963,493 19,211,055 2,127,1

 

Total 194,032 166,799 3,360 2,888 18,536,115,063 176,607,655 18,712,7

 

Total Cras

Savin

Truck Crashes Bus Crashes

Truck Crash Cost 

Savings

Bus Crash 

Savings
Assessment of Potential Benefits and Costs of 5-12 Final Report 

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Certifying Brake Technicians 

Table 5-4. Non-crash Vehicle Inspections and Number of 

OOS Brake Violations 

Number of "non-crash" vehicle inspections performed (Levels 1,2,5) 

Year 

Vehicle Type 2002 2003 2004 Average 

Motor coach 8,917 9,717 9,846 9,493

Truck 2,118,985 2,111,454 2,196,450 2,142,246

Total 2,127,902 2,121,171 2,206,296 2,151,789

 

Number of "non-crash" vehicle inspections with an OOS brake violation 

Year 

Vehicle Type 2002 2003 2004 Average 

Motor coach 446 532 482 487

Truck 193,354 215,070 222,529 209,940

Total 193,800 215,602 223,011 210,804

MCMIS data for 2002 to 2004 show that for an average year, a total of 2,142,246 non-crash 

truck inspections were conducted. Of these inspections, brake violations represent an average of 

about 9.8 percent or 209,940 brake-related OOS violations per year. 

If the same program efficiency of 70 percent is applied to a new brake maintenance and training 

program, 70 percent of the OOS violations could be prevented by the implementation of the 

enhanced brake maintenance and inspection activities. By adopting the new program, this 

calculation would result in a reduction of 146,958 brake related OOS violations annually. 

For the years 2002, 2003, and 2004, MCMIS non-crash motor coach inspection data show that 

for an average year, 9,493 non-crash bus inspections were conducted. Of these, about 5 percent 

or 487 inspections resulted in an OOS brake violation in an average year. If the same 70 percent 

program efficiency level was applied to the bus brake-related OOS violations, 341 OOS 

violations would be avoided in a year by adopting the enhanced training, certification, and 

inspection program. 

The costs associated with OOS violations are based on the assumptions that the average OOS 

violation results in 8.7 hours of downtime and that being placed out of service costs an average 

motor carrier $57 per hour.*

 Based on these assumptions, total savings resulting from a 

reduction in OOS violations as a result of the brake inspection program totals $851.2 million 

over the 10-year time horizon or $629.3 million in discounted present value terms. 

 

*

 Interview with Dan Murray, American Trucking Research Institute, 7/23/05 
Assessment of Potential Benefits and Costs of 5-13 Final Report 

Revising Brake Inspection Procedures and July 31, 2006 

Certifying Brake Technicians 

5.2.3 Impacts on Citations involving Monetary Penalties 

Some cost savings can be expected due to improved maintenance and driver inspections (and 

correction) of stroke adjustment as a result of fines not being assessed for brake OOA violations. 

These would be in addition to the savings for vehicles not placed OOS due to brake adjustment. 

While the amount of a fine for a “stroke beyond the adjustment limit” violation varies from place 

to place, a check of eight jurisdictions resulted in an average fine per violation (including court 

costs) of roughly $100. 

The number of vehicles that would see cost savings from improved maintenance and pre-trip 

inspection due to elimination of OOA violations is calculated based on the assumptions outlined 

below. The data are taken from Operation Air Brake statistics from the years 1998 through 

2004, looking only at the U.S. checks and separate calculations are given for trucks and buses: 

 The total number of trucks inspected: 111,053 

 The total number of truck brakes checked: 866,627 

 Average number of truck brakes per vehicle = 866,627/111,053 = 7.80 

 The total number of truck OOS for brake adjustment = 14,412 

Thus, this is a minimum of 2 × 14,412 = 28,825 brakes OOA on trucks OOS for brakes OOA. 

This assumes that the CVSA 20-percent rule*

 was applied, so at least 2 brakes per truck had to 

be OOA. Another method would take 20 percent of 7.80 brakes average per truck × 14,412 

trucks = 22,494 brakes OOA on trucks OOS for OOA brakes. 

Data compiled from Operation Air Brake statistics indicate that the total number of brakes OOA 

was 54,228. We assume that the total number of brakes OOA (54,228) includes those on trucks 

placed OOS (28,825 or 22,494, depending on which calculation you use). Therefore, the number 

of brakes OOA, but not resulting in OOS (i.e., those which would have been subject to a citation 

and fine) would be 54,228 less 28,825 (or 22,494) = 25,403 (or 31,734). We divide this number 

of brakes by the number of brakes per truck (in order to not be OOS, each truck would only be 

allowed to have only one brake OOA) and get 25,403/7.80 = 3,255 trucks (or 4,066 using the 

second method). 

This results in 3,255/111,053 = 2.9 percent (or 3.7 percent) of the trucks inspected being subject 

to a fine for brakes OOA. Using this percentage of the 2.1 million inspections per year and $100 

dollar average fine, and a 70 percent efficiency of the “maintenance + driver inspections,” a 

savings of $4.4 million per year (or $5.5 million using the second calculation method) are 

estimated. We use the mid-point of these two estimates (3.3 percent) in the benefits calculation 

resulting in an estimated $4.9 million in savings in Year 1. Total savings over the 10-year time 

frame are estimated at $56.6 million (nominal 2005 dollars). 

 

*

 CVSA OOS criteria specify that vehicles with 20 percent or more of their brakes found to be defective should be 

placed OOS. In terms of adjustment, defective means 1⁄4-inch or more beyond the recommended adjustment limit. 
Assessment of Potential Benefits and Costs of 5-14 Final Report 

Revising Brake Inspection Procedures and July 31, 2006 

Certifying Brake Technicians 

The bus analysis follows the truck analysis: 

 The total number of buses inspected: 76 

 The total number of bus brakes checked: 350 

 Average number of bus brakes per vehicle = 350/76 = 4.61 

 The total number of bus OOS for brake adjustment = 11 

Thus, this is a minimum of 2 × 11 = 22 brakes OOA on buses OOS for brakes OOA. 

This assumes that the CVSA 20-percent rule was applied, so at least 2 brakes per bus had to be 

OOA. Another method would take 20 percent of 4.61 brakes average per bus × 11 buses = 10 

brakes OOA on buses OOS for OOA brakes. 

The total number of brakes OOA, as estimated based on data compiled from Operation Air Brake 

statistics, was 31. We assume that the total number of brakes OOA (31) includes those on buses 

placed OOS (22) (or 10, depending on which calculation you use). Therefore, the number of 

brakes OOA, but not resulting in OOS (i.e., those which would have been subject to a citation 

and fine) would be 31 less 22 (or 10) = 8 (or 20). These numbers do not sum to 31 due to 

rounding. We divide the number of brakes by the number of brakes per bus (in order to not be 

OOS, each bus would only be allowed to have only one brake OOA) and get 8/4.61 = 2 buses (or 

4 using the second method). 

This results in 2/76 = 2.3 percent (or 5.8 percent) of the buses inspected being subject to a fine 

for brakes OOA. Using this percentage of the 9,500 inspections per year and $100 dollar 

average fine, and a 70 percent efficiency of the “maintenance + driver inspections,” we get a 

savings of $15,000 per year (or $38,500 using the second calculation method). We use the midpoint of these two estimates (4.1 percent) in the benefits calculation resulting in an estimated 

$27,000 in savings in Year 1. Total savings over the 10-year time frame are estimated at 

$310,000 (nominal 2005 dollars). 

5.3 Costs Assessment 

Implementing the NTSB recommendations would generate training, inspection, testing, and 

certification costs as well as administrative costs associated with record keeping and retention. 

Training would be required of bus and truck drivers responsible for performing pre-trip 

inspections. Brake inspectors would train in preparation for the testing and certification process 

called for in the NTSB recommendation. Training costs would include the costs associated with 

preparing training materials, compensating internal trainers, paying fees to external trainers, and 

labor costs for staff receiving the training. Training costs would include those required to train 

both new and existing drivers in initial and refresher training courses. The brake inspector 

certification process also would result in costs associated with registration and testing fees. 

Finally, pre-trip inspections would take drivers away from revenue-generating activities and 

would, thus, result in additional labor costs. In each case, these costs would be borne by the 

motor carrier industry. This section of the report examines these costs and examines the costs 

each would impose on industry. 
Assessment of Potential Benefits and Costs of 5-15 Final Report 

Revising Brake Inspection Procedures and July 31, 2006 

Certifying Brake Technicians 

5.3.1 Training, Testing, and Certification Costs 

The recommendations set forth by NTSB would require a sufficient level of training in brake 

systems for both CMV drivers and brake inspectors. The results of the training, testing, and 

certification surveys suggest that the intensity of training necessary for drivers and brake 

inspectors would be different reflecting their particular responsibilities. Drivers would need to 

attain an acceptable level of knowledge to ensure for proper maintenance of CMV brake systems 

by conducting pre-trip inspections to identify the presence of brake deficiencies. 

Initial training costs in Year 1 for driver training and for brake inspector training are made up of 

the costs to deliver the training, fees paid to third-party vendors, and labor replacement costs. 

The costs to deliver and receive the training are based on input provided from training, testing, 

and certification surveys regarding the duration of the training, pay for trainers, and class size. 

Labor data for truck and bus drivers, as well as brake inspectors, were obtained from the 

following sources: the National Compensation Survey (Bureau of Labor Statistics [BLS]), 

Occupational Employment Statistics (Bureau of Labor Statistics), American Trucking 

Associations Driver Compensation Survey, and Bureau of Transportation Statistics Office of 

Motor Carrier Information’s Financial and Operating Statistics. The total number of truck 

drivers who would need to be trained initially was estimated by FMCSA at 7.0 million. The total 

number of brake inspectors used in the analysis is 456,666, and is also based on data provided by 

FMCSA. 

Respondents indicated that an initial training course taking 4 hours would be sufficient to train 

drivers. Brake inspectors, however, would need a higher level of understanding to properly 

inspect, maintain, service, and repair CMV brake systems and to pass testing for certification as 

recommended by NTSB. The respondents indicated that brake inspectors would be required to 

undergo 8 hours of initial training and 2 hours of testing and certification. 

Training costs over Years 2-10 of the 10-year analysis timeframe include the additional training 

needed to account for periodic refresher courses. To determine refresher training costs, 

assumptions were required regarding the wage of the participants, average class size, frequency, 

and duration of the refresher training course. Truck driver turnover rates were obtained from 

comments provided on an initial draft of this report at the TMC Fall Meeting in Valley Forge, 

PA. These comments identified turnover rates by industry segment (LTL, truckload, private). 

This information was combined with ATRI market share data to estimate driver turnover rates 

for the entire industry. Bus driver turnover rates were assumed to mirror those of truck drivers, 

and brake inspector turnover rates are based on BLS averages for the transportation sector and 

information acquired through stakeholder interviews. Interview respondents indicated that the 

NTSB recommendations would require truck drivers to undergo 2 hours of refresher training 

every year, while brake technicians would take 2 hours of refresher training every 2 years. 

The research team assumed that driver training for companies employing 20 or more individuals 

would be conducted in-house. The in-house training costs are a function of training material 

costs ($4 per student), the hourly cost of the trainer ($34.70 per hour), training time (4 hours for 

initial training and 2 hours for refresher training), and average class size (17.5 students per class). 

The basis for each assumption is detailed in Table 5-5. Based on these assumptions, the average 
Assessment of Potential Benefits and Costs of 5-16 Final Report 

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Certifying Brake Technicians 

cost to supply the course in-house is estimated at $12 per student for initial training and $8 per 

student for refresher training. Because small companies lack the resources and capabilities to 

perform training in-house, companies with 19 or fewer employees are assumed to rely on 

external trainers. Based on the data collected in support of the brake technician course cost 

analysis presented in Table 5-6, fees paid to external trainers are estimated at $15 per student per 

hour. The 2002 Economic Census indicates that roughly 24.9 percent of all individuals 

employed in NAICS 484 Truck Transportation and 14.4 percent of all individuals employed in 

NAICS 4852 Interurban and Rural Bus Transportation and NAICS 4855 Charter Bus Industry 

are employed by companies with fewer than 20 employees (U.S. Department of Commerce 

2002). Based on these assumptions, the numbers of truck and bus drivers seeking external 

training in the first year following implementation are estimated at 1.7 million and 3,503, 

respectively. External training costs are estimated at $15 per student per hour based on a scan of 

training schools presented in Table 5-6. 

The more complex needs associated with training and certifying brake technicians is assumed to 

be performed completely by third-party vendors. The fees associated with external training 

courses for brake technicians were determined through a scan of comparable programs offered 

through training schools and academic institutions around the United States, as highlighted in 

Table 5-6. The costs associated with these training courses ranged from $45 to $250, with most 

in the $150-$250 range. However, these programs are generally more comprehensive and take 

much more time than the amount most motor carriers view as necessary to complete the training 

considered in this study. The list of comparable classes presented in Table 5-6 ranges from 

simple pre-trip inspection courses to more comprehensive brake technician courses. When 

normalized on a per-hour cost basis, the hourly training cost for these courses generally falls 

between $10 and $20. Based on these data, this analysis assumes an average training course cost 

of $15 per student per hour or $120 for initial brake technician training and $30 for all refresher 

training courses. This cost does not include the certification testing nor does it cover the labor 

costs associated with the time brake technicians spend in class. 

Training cost estimates also account for payments to workers who replace drivers attending 

training. These labor replacement costs are a function of the hourly rates paid to replacement 

labor and the time drivers spend in class. The overtime provisions of the Fair Labor Standards 

Act does not apply to CMV drivers. Therefore, it is assumed that labor replacement costs would 

be paid at standard hourly rates and motor carriers would not incur overtime costs. Based on 

these assumptions, the labor replacement costs, which include fringe benefits, are estimated at 

$19.00, $19.25, and $22.69 for truck drivers, bus drivers, and brake technicians, respectively. 
Assessment of Potential Benefits and Costs of 5-17 Final Report 

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Certifying Brake Technicians 

Table 5-5. Training Cost Assumptions 

Data Requirements Assumption Source 

1. Number of truck drivers 7.0 million in 2005 FMCSA (Gruberg 2005) 

2. Number of bus drivers 24,380 in 2005 BTS, NTS 

3. Number of brake inspectors 456,666 in 2005 FMCSA 

4. Time required to train drivers 

initially 

4 hours Interviews 

5. Time requirements and 

frequency of refresher training 

for drivers 

2 hours every year Interviews 

6. Time required to train brake 

technicians initially 

8 hours Interviews 

7. Time required for testing and 

certification process 

2 hours Interviews 

8. Time requirements and 

frequency of refresher training 

for brake technicians 

2 hours every 2 years Interviews 

9. Average class size 15-20 (assumed 17.5) Interviews 

10. Training materials costs $4 per student Interviews 

11. Average salary + fringe 

benefits of trainer 

$34.70/hr Interviews 

12. Average salary + fringe 

benefits of truck drivers 

$19.00/hr ATA Driver Compensation Study, 

Occupational Employment Statistics, BLS 

National Compensation Study 

13. Average salary + fringe 

benefits of bus drivers 

$19.25/hr National Transit Database BLS Employer 

Costs for Employee Comparative Statistics 

14. Average salary + fringe 

benefits of brake technicians 

$22.69/hr Bureau of Labor Statistics, Occupational 

Employment Statistics 

15. Truck driver turnover rates 55 percent Comments provided at TMC Fall Meeting in 

Valley Forge, PA concerning turnover rates 

by industry segment (LTL, truckload, private) 

combined with ATRI market share data. 

16. Bus driver turnover rates 55 percent Assumed to be same as truck drivers’ 

17. Brake technician turnover 

rates 

15 percent BLS, Transportation Sector and Interviews 

18. Payments to third party 

trainers for brake technician 

courses (initial / refresher 

training) 

$120 per student 

(initial) / $30 per 

student (refresher) 

Scan of training schools 

19. Registration and testing costs 

for brake technicians 

$32 registration + $25 

testing = $57 (initial); 

$25 testing fee for 

renewals 

Scan of training schools 

20. Share of drivers working for 

companies with fewer than 20 

employees 

24.9 percent (truck 

drivers), 14.4 percent 

(bus drivers) 

2002 Economic Census - NAICS 484 (Truck) 

and 4852 (Bus) and 4855 (Bus) 
Assessment of Potential Benefits and Costs of 5-18 Final Report 

Revising Brake Inspection Procedures and July 31, 2006 

Certifying Brake Technicians 

Table 5-6. Driver and Technician Training Courses and Associated Fees 

School Class Cost Cost per Hour 

of Instruction 

Advance Driver Training Air brakes $250 $21 

Western Wyoming Community 

College 

Commercial vehicle pre-trip 

inspection $45 $12 

Catawba Valley Community 

College Vehicle safety inspection course $50 $6 

Central Pennsylvania Institute of 

Science and Technology 

Mechanic inspection certification, 

including brake systems $198 $11 

Aspire Brake training video and manual $129 N/A 

Fox Valley Technical College Various diesel service mechanic 

and technician courses $224 $14 

Based on these assumptions, total training, testing, and certification costs are estimated at 

$5.4 billion over the 10-year time horizon in discounted 2005 dollars. Of that amount, 

$4.8 billion are attributed to the training of truck drivers, $13.3 million to training bus drivers, 

and $564.9 million to the training, testing, and certification of brake inspectors. 

In the short-term, the availability of external training options for drivers and brake inspectors 

could be limited. Based on the assumptions outlined previously in this section, the NTSB 

recommendations considered in this report would result in 1.7 million drivers and 456,666 brake 

inspectors attempting to locate external training options to satisfy new training requirements. 

Furthermore, motor carriers across the country would require time to develop training curricula 

and associated materials in order to train approximately 5.3 million drivers in the first year 

following implementation of the NTSB recommendations. 

In 2004, there were roughly 2,000 automotive service technician training programs that had been 

certified by the National Institute for ASE. The NATEF has also certified more than 100 schools 

offering M/H technician training programs. There are 700 testing centers nationwide used by 

ASE in the certification process. These and other training facilities could be used to satisfy the 

requirements outlined in the NTSB recommendations; however, there are concerns that 

implementing the NTSB recommendations could be difficult in terms of both the ability of 

external trainers to meet the demand in the short-term and the geographic distribution of trainers 

and training facilities. 

The economic analysis presented in this report does not make any assumptions regarding the 

availability of training seats, nor does it examine the impact of the enhanced demand for training 

caused by the NTSB recommendations on the prices associated with external training classes and 

certification testing. In order to address industry concerns regarding the challenges associated 

with meeting the requirements outlined in the NTSB recommendations, FMCSA could consider 

an extended implementation period (e.g., 2-4 years). Extending the implementation period 

would ease the burden on industry by allowing motor carriers more time to develop internal 
Assessment of Potential Benefits and Costs of 5-19 Final Report 

Revising Brake Inspection Procedures and July 31, 2006 

Certifying Brake Technicians 

training programs and enabling the training industry to expand the supply of training seats and 

address the issues relating to the geographic dispersion of motor carrier operations. 

5.3.2 Inspection Costs 

The NTSB recommendations would require that CMV drivers inspect vehicle brakes before each 

trip. To estimate the cost of pre-trip inspections, the research team calculated the product of the 

total number of axles on single-unit and combination trucks operating on U.S. highways, the 

average number of trips taken by heavy trucks annually in the United States, per-axle inspection 

time requirements, and the average wage of the truck drivers performing the inspections. This 

section of the report describes the methods used to determine the costs associated with pre-trip 

inspections and estimates total pre-trip inspection costs associated with the NTSB 

recommendations. 

Total Number of Axles on Single-Unit and Combination Trucks 

Since the interview survey respondents estimated pre-trip inspection costs on a per-axle basis 

(2 minutes per axle), it became necessary to determine the number of axles on single-unit and 

combination trucks operating in the United States. The Federal Highway Administration’s 

(FHWA’s) Highway Statistics presents annual data on the number of single-unit and combination 

trucks operating in the United States in Table VM-1 (FHWA, 2004). These values were 

combined with data presented in the 2002 Vehicle Inventory and Use Survey (VIUS) in order to 

estimate the number of axles on trucks requiring pre-trip inspections (U.S. Census Bureau, 

2004). The results of this analysis are presented in Table 5-7. Note that the NTSB 

recommendations would not apply to vehicles weighing 10,000 pounds or less. Therefore, these 

vehicles were excluded from the analysis. As shown, the number of axles on single-unit and 

combination trucks was estimated at 16.4 million in 2003. 

Table 5-7. Number of Axles on Single-unit and Combination Trucks 

Truck Type Total Number of Vehicles Total Number of Axles 

Single Unit Trucks 

2 axles 1,852,642 3,705,284 

3 axles 760,670 2,282,010 

Axles not specified 7,385 18,463 

Combination Trucks 

3 axles 155,088 465,264 

4 axles 354,487 1,417,948 

5 axles or more 1,543,496 7,717,480 

Axles not specified 192,014 768,055 

Total 4,865,782 16,374,504 
Assessment of Potential Benefits and Costs of 5-20 Final Report 

Revising Brake Inspection Procedures and July 31, 2006 

Certifying Brake Technicians 

Annual Number of Trips Taken by CMVs 

The 2002 Vehicle Inventory and Use Survey (VIUS) published a comparative summary of 

operation ranges for U.S. trucks registered in the 1997 and 2002 VIUS (U.S. Census Bureau, 

2004). These estimates represent average miles per trip, as shown in Table 5-8. VIUS data 

indicate that roughly 50 percent of all trucks operate in an area of less than 50 miles, the average 

trip length for 16.8 percent of all trucks falls between 51 to 200 miles, and only about 9.5 percent 

of all trucks’ average trip length exceeds 200 miles. 

The drawback of using these percentages for the CMV brake inspection and maintenance study 

is that they do not represent trucking industry averages. Rather, VIUS statistics represent 

aggregate statistics of all types of trucks. This study, on the other hand, focuses on trucking and 

intercity bus industry motor carriers that are largely under-represented in VIUS data. 

Table 5-8. VIUS Percentage of Trucks Based on Range of Operation 

Range of Operation 1997 2002 

50 miles or less 52.5 52.3 

51 to 200 miles 23.9 16.8 

201 miles or more 15.1 9.5 

Off the road, not reported, and not applicable 8.5 20.4 

Forkenbrock, in a study titled “External Costs of Intercity Truck Transportation,” used an ATA 

database principally comprised of Class I (annual revenues in excess of $10 million) carrier data 

to estimate the proportion of for-hire truckload general freight trucking operations falling into 

three ranges of operation categories: less than 250 miles, 250 to 500 miles, and over 500 miles 

(Forkenbrock, 1999). These data are shown in Table 5-9. The data set used in Forkenbrock (on 

pages 505 to 526), had a small number of Class II carriers (annual revenues between $3 and 

$10 million) and almost no Class III carriers (annual revenues of less than $3 million). Due to 

the bias inherent in the data used in the study, the percentage of trucks traveling in excess of 

500 miles per trip would not appear to apply to the overall trucking industry. 

Table 5-9. Percentage of Trucks Based on Range of Operation 

Range of Operation 

Highway Miles Operated 

(thousands) 

Percentage 

Share of Total 

Less than 250 Miles 723,052 8.09% 

250 - 500 Miles 1,367,380 15.30% 

Over 500 Miles 6,845,397 76.61% 

Total 8,935,829 100.00% 
Assessment of Potential Benefits and Costs of 5-21 Final Report 

Revising Brake Inspection Procedures and July 31, 2006 

Certifying Brake Technicians 

Neither of the two studies outlined previously are directly applicable to this study; however, they 

could represent upper and lower bounds on most likely estimates. Thus, the research team 

initially adopted a mid-range estimate of 300 to 400 miles per trip on average for the CMVs 

studied here. However, when considering that long-haul trucking operations would be required 

to inspect the brake systems each day prior to departure, the most miles a truck could travel 

between inspections would be roughly 660 (60 miles per hour multiplied by 11 hours on the 

road). Thus, the low-end estimate was reduced to 200 miles. When combined with annual 

mileage estimates on a per-truck and bus basis appearing in Highway Statistics, this range 

produces an estimate of 68 to 136 inspections per year per truck and 21 to 43 inspections per 

year per bus. 

Inspection Costs 

The annual number of axles inspected is computed as the product of the number of annual 

inspections (68-136 as outlined in the previous section) and the total number of axles on singleunit and combination trucks (16.4 million as documented in Table 5-7). Based on these 

assumptions, the total number of truck axles requiring inspection was estimated at between 

1.1 and 2.2 billion in 2005. Based on truck driver salaries previously noted in the training cost 

analysis (Table 5-5), total estimated costs associated with performing 2-minute pre-trip 

inspections on each axle would result in approximately $4.9 to $9.9 billion in inspection costs 

over the 10-year study time horizon. 

The total number of bus axles inspected annually is a function of the number of inspections 

outlined in the previous section of this report (21-43 annually) and the total number of bus axles 

(estimated at 279,790). The cost to inspect each axle is a function of the time required to inspect 

it (2 minutes or 1/30th of an hour) and the hourly wage plus fringe benefits of bus drivers ($19.25 

as documented in Table 5-5). Based on these assumptions, total inspection costs are estimated at 

between $25.2 and $50.3 million over the 10-year study time horizon. 

Administrative Costs 

There are administrative costs borne by the motor carrier industry associated with coordinating 

training for drivers and brake inspectors and maintaining training and certification records. To 

determine the costs associated with these activities, there were several questions posed to 

industry regarding the costs associated with these administrative functions. Unfortunately, the 

interview surveys failed to produce conclusive results in this area. Thus, based on limited data 

and additional analysis of the administrative requirements under the NTSB recommendations, 

the research team estimates administrative costs at 10 minutes per driver and brake inspector 

trainee. The annual administrative costs are, therefore, estimated as the product of the number of 

annual driver and brake inspector trainees and 10 minutes salary for executive secretaries and 

administrative assistants, estimated in the BLS OES at $22.64, including fringe benefits. Based 

on these assumptions, total administrative costs are estimated at $316.7 million over the 10-year 

time horizon (2005 to 2014). Of this amount, $303.7 million was attributed to administering the 

driver training programs, with the remainder ($13.0 million) tied to brake inspector training and 

certification. 
Assessment of Potential Benefits and Costs of 5-22 Final Report 

Revising Brake Inspection Procedures and July 31, 2006 

Certifying Brake Technicians 

5.4 Benefit-cost Analysis 

The incremental costs incurred by the motor carrier industry to implement the NTSB 

recommendations in the base case analysis (70 percent program effectiveness) are summarized in 

Tables 5-10 and 5-11. Benefits associated with improved safety and reduced OOS violations are 

also included in these tables. The most significant costs are those incurred during pre-trip 

inspections, which total roughly $4.9 to $9.9 billion over the 10-year time horizon (2005 to 

2014). Though each inspection would require only 2 minutes per axle, the costs of this 

requirement are significant because they would require billions of inspections to be performed 

over the next 10 years. The cost range is due to varying the assumption regarding the average 

distance per trip between 200 and 400 miles. Training, testing, and certification collectively 

represent the next highest cost item, totaling $5.4 billion over the 10-year analysis timeframe. 

Administrative costs are relatively low at $316.7 million over 10 years. 

Overall, estimated benefits are higher than projected costs over the 10-year time horizon in the 

base case analysis when low-end cost assumptions are used, with discounted benefits (using a 

7 percent discount rate) totaling $14.5 billion ($19.6 billion in nominal benefits), compared to 

$10.7 billion in costs. When the high-end cost assumption regarding the number of inspections 

is used, estimated costs grow to $15.6 billion and exceed estimated benefits by $1.1 billion. 

Thus, net benefits are estimated at ($1.1) to $3.8 billion. These numbers correspond with 

benefit-cost ratios of .93 and 1.36. These results demonstrated nearly no sensitivity to variations 

in discount rates. At a 10 percent discount rate, the benefit-cost ratio ranges between .92 and 

1.35 and varies from .93 and 1.07 when a 4 percent discount rate is applied. The lack of discount 

rate sensitivity occurs because benefits and costs are realized relatively evenly over the 10-year 

time horizon, with the exception of relatively higher training costs in Year 1.
Assessment of Potential Benefits and Costs of Revising 5-23 

Brake Inspection Procedures and Certifying Brake Technicians 

Table 5-10. Benefit-cost Analysis Findings (Average Trips by CMV Assumed to be 200 m

Trucks Intercity Buses Trucks Intercity Buses

Administrative 

Costs

2005 1,713,889,124 1,713,889,124 1,920,157 696,909,995 1,167,723,733 6,202,826 184,461,554 28,250,387 2

 

2006 1,764,789,808 1,649,336,269 528,587,581 1,530,354 1,123,803,801 5,908,405 35,513,159 27,665,991 1

 

2007 1,817,204,004 1,587,216,354 508,728,496 1,457,715 1,081,535,767 5,627,960 51,180,876 29,762,014 1

 

2008 1,871,176,752 1,527,437,610 489,615,519 1,388,524 1,040,857,500 5,360,826 37,932,763 29,619,836 1

 

2009 1,926,754,431 1,469,911,730 471,220,618 1,322,617 1,001,709,207 5,106,372 47,770,212 31,441,674 1

 

2010 1,983,984,801 1,414,553,744 453,516,816 1,259,838 964,033,344 4,863,996 39,189,244 31,640,612 1

 

2011 2,042,917,046 1,361,281,887 436,478,147 1,200,039 927,774,529 4,633,124 45,315,399 33,281,720 1

 

2012 2,103,601,811 1,310,017,485 420,079,622 1,143,079 892,879,465 4,413,210 39,710,098 33,749,340 1

 

2013 2,166,091,252 1,260,684,830 404,297,191 1,088,822 859,296,859 4,203,735 43,474,724 35,279,227 1

 

2014 2,230,439,077 1,213,211,075 389,107,708 1,037,141 826,977,349 4,004,203 40,384,942 36,042,290 1

 

Total 19,620,848,106 14,507,540,108 4,798,541,694 13,348,285 9,886,591,552 50,324,657 564,932,970 316,733,092 15

 

Year

Inspector 

Training, Testing 

and Certification 

Costs

Driver Training Cost

Benefits

Discounted 

Benefits 

Tota

Pre-Trip Inspection Costs

Table 5-11. Benefit-cost Analysis Findings (Average Trips by CMV Assumed to be 400 m

Trucks Intercity Buses Trucks Intercity Buses

Administrative 

Costs

2005 1,713,889,124 1,713,889,124 696,909,995 1,920,157 583,861,866 3,101,413 184,461,554 28,250,387 1

 

2006 1,764,789,808 1,649,336,269 528,587,581 1,530,354 561,901,900 2,954,203 35,513,159 27,665,991 1

 

2007 1,817,204,004 1,587,216,354 508,728,496 1,457,715 540,767,883 2,813,980 51,180,876 29,762,014 1

 

2008 1,871,176,752 1,527,437,610 489,615,519 1,388,524 520,428,750 2,680,413 37,932,763 29,619,836 1

 

2009 1,926,754,431 1,469,911,730 471,220,618 1,322,617 500,854,604 2,553,186 47,770,212 31,441,674 1

 

2010 1,983,984,801 1,414,553,744 453,516,816 1,259,838 482,016,672 2,431,998 39,189,244 31,640,612 1

 

2011 2,042,917,046 1,361,281,887 436,478,147 1,200,039 463,887,264 2,316,562 45,315,399 33,281,720 

 

2012 2,103,601,811 1,310,017,485 420,079,622 1,143,079 446,439,732 2,206,605 39,710,098 33,749,340 

 

2013 2,166,091,252 1,260,684,830 404,297,191 1,088,822 429,648,430 2,101,868 43,474,724 35,279,227 

 

2014 2,230,439,077 1,213,211,075 389,107,708 1,037,141 413,488,674 2,002,101 40,384,942 36,042,290 

 

Total 19,620,848,106 14,507,540,108 4,798,541,694 13,348,285 4,943,295,776 25,162,329 564,932,970 316,733,092 10

 

Year Benefits

Discounted 

Benefits

Inspector 

Training, Testing 

and Certification 

Costs 

Driver Training Cost Pre-Trip Inspection Costs

Tota
Assessment of Potential Benefits and Costs of 5-24 Final Report 

Revising Brake Inspection Procedures and July 31, 2006 

Certifying Brake Technicians

Table 5-12 presents the findings of the benefit-cost analysis when the ratio of program 

effectiveness is varied between 50 and 90 percent and the benefits and costs are split between the 

two NTSB recommendations (driver inspection and training and brake inspector training and 

certification) As discussed in Section 5.2, roughly 70 to 90 percent of the benefits associated 

with reducing the number of crashes, fines and violations are attributed to the proposed brake 

inspector training and certification program. The majority of the costs, however, were attributed 

to the driver training and pre-trip inspection recommendation. 

Table 5-12. Benefit-cost Analysis Findings (Alternative Scenarios) 

Benefit-cost Ratios 

Program 

Effectiveness 

Driver Training/ 

Pre-trip 

Inspections 

Brake Inspector 

Training and 

Certification 

Both Driver and Brake 

Inspector NTSB 

Recommendations 

50% 0.07-0.31 12.65-16.26 0.66-0.97 

60% 0.08-0.37 15.18-19.51 0.80-1.17 

70% 0.10-0.43 17.71-22.77 0.93-1.36 

80% 0.11-0.49 20.24-26.02 1.06-1.56 

90% 0.12-0.55 22.77-29.27 1.19-1.75 

The final step in conducting the benefit-cost analysis (BCA) is to compare the societal costs and 

benefits and to construct BCRs in order to quantify the extent to which benefits exceed or fall 

short of costs. A BCR is equal to the present value of benefits divided by the present value of 

costs. Thus, a BCR in excess of 1.0 demonstrates positive economic returns to society. When 

BCRs exceed 1.0, society experiences net benefits from the regulation (net present value of 

benefits = present value of benefits – present value of costs). Under the high-end estimate 

concerning the costs associated with pre-trip inspections (200-mile average trip), the NTSB 

recommendations produce net benefits with BCRs in excess of 1.0. Under the low-end estimate 

(400-mile average trip), the recommendations fail to produce net benefits when the program 

effectiveness drops below 76 percent (i.e., the BCR is below 1.0). 

The driver training and pre-trip inspection recommendation fails to produce net benefits under 

any of the scenarios considered in Table 5-12. The driver training and pre-trip inspection 

recommendation produced BCRs ranging from 0.07 (50 percent ratio of effectiveness, 200-mile 

average trip) to 0.55 (80 percent program effectiveness, 400-mile average trip). 

The brake inspector and certification recommendation, on the other hand, produced large net 

benefits, with BCRs exceeding 12.65 in all scenarios considered in this study. The BCRs 

range from a low of 12.65 (50 percent program effectiveness, 200-mile average trip) to 29.27 

(90 percent program effectiveness, 400-mile average trip). 
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APPENDIX A. REFERENCES

ATA (American Trucking Associations), 2005. U.S. Freight Transportation Forecast to 2016-

Booklet. 

Battelle for FMCSA, 2005, Hazardous Materials (HAZMAT) Database. 

Bendix Commercial Vehicle Systems Company. Air Brake Handbook; September, 2000. 

Blincoe, L. et al., (NHTSA) The Economic Cost of Motor Vehicle Crashes, 2000. May 2002 

Blower, Daniel. Vehicle Condition and Heavy Truck Accident Involvement. In Proceedings of 

2002 International Large Truck and Bus Safety Research and Policy symposium, Knoxville, TN, 

2002. 

BTS (Bureau of Transportation Statistics), 2004, National Transportation Statistics 2003, U.S. 

Department of Transportation, Washington D.C.

CVSA (Commercial Vehicle Safety Association), 2004, Operation Air Brake Statistics, 1998 to 

2004. 

FHWA (Federal Highway Administration), 2004, Federal Highway Statistics, Washington, D.C. 

FMCSA, 2004, Large Truck Crash Facts 2002; FMCSA-RI-04-021; Washington D.C., 

FMCSA, 2005, The Large Truck Crash Causation Study (LTCCS) Draft Data. 

FMCSA, 2005a, Motor Carrier Management Information (MCMIS) Inspection File. 

Forkenbrock, David J. (1999) “External Costs of Intercity Truck Freight Transportation.”

Transportation Research. Part A. Volume 33. 

FTA (Federal Transit Administration), 2004, Understanding Transit Accidents Using the 

National Transit Database and the Role of Transit Intelligent Vehicle Initiative Technology in 

Reducing Accidents 6. Performing Organization Code, DOT-VNTSC-FTA-04-02. 

Gruberg, Richard, FMCSA Analysis Division. Estimates for the number of CDL and non-CDL 

Drivers in the National Fleet, Based on May 2005 MCMIS Data and 2003 Drug & Alcohol 

Survey. June 2005. Washington, D.C. 

Moses, Leon N. and Savage, Ian. The Effectiveness of Motor Carrier Safety Audits. Accident 

Analysis and Prevention, Volume 24, Issue 5, 1992. 

NHTSA (National Highway Traffic Safety Administration). The Economic Burden of Traffic 

Crashes on Employers, December 2003. 
Assessment of Potential Benefits and Costs of A-2 Final Report 

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OMB (Office of Management and Budget). 2002. Circular A-94 Guidelines and Discount Rates 

for Benefit-Cost Analysis of Federal Programs. Washington, D.C. 

Shelton, Terry, What is the Current Level of Compliance? North American Brake Safety 

Conference, Toronto, Canada, September 2000. 

TMC/ATA, Technician Certification Program Guidelines, RP 528—1, 2004. 

United States Census Bureau, 2004, 2002 Vehicle Inventory and Use Survey. Washington, D.C. 

U.S. Department of Commerce. Economics and Statistics Administration. U.S. Census Bureau. 

2002 Economic Census, Transportation and Warehousing. Establishment and Firm Size: 2002. 

November 2005. Washington, D.C. 

United States Department of Transportation, Office of Motor Carrier Safety, 1998, Upper Great 

Plains Transportation Institute; Educational and Technical Assistance to CMV Drivers and 

Motor Carriers: Peer Exchange. 

University of Michigan Transportation Research Institute (UMTRI). 2005, Trucks Involved In 

Fatal Accidents (TIFA) data. Data for: 1993 to 2000. 

VanderZwaag, Rolf, Practical Airbrakes; Techni-Com Inc., Richmond Hill, Ontario, 2001. 

VanderZwaag, Rolf. Sponsored by CVSA, supported by Canadian Council of Motor Transport 

Administrators and FMCSA. Report of Driver Survey: Air Brake Adjustment Knowledge. 

CVSA, Washington D.C., 2003. 

Volpe National Transportation Systems Center for FMCSA. FMCSA Safety Program 

Effectiveness Measurement: Intervention Model; Roadside Inspection and Traffic Enforcement 

Effectiveness Annual Report. FMCSA-RI-04-029, December 2004. 

Zaloshnja, Edward and Miller, Ted (Pacific Institute for Research and Evaluation), Revised 

Costs of Large Truck- and Bus-Involved Crashes, prepared for FMCSA, November 18, 2002. 
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APPENDIX B. ADDITIONAL ANNOTATED REFERENCES

This appendix describes data sources, papers, reports, and books that were consulted during this 

study but not discussed directly in the Section 2, Literature Review. Although the annotated 

references were not used directly for the report preparation, they served to provide background 

material and information or to validate another source and indicate its applicability to the project. 

Material here is organized under the following categories used for the Literature Review in 

Section 2. 

• Data and studies on crashes and OOS violations that could be prevented or mitigated, 

• The need for better driver/ brake technician training and inspection, 

• Existing brake training programs, and 

• Economic analysis techniques. 

No additional annotated references are described under economic analysis techniques. 

B.1 Data and Studies for Use in Estimating Crashes and OOS Violations That 

Could be Prevented or Mitigated 

(CPIR-B File) Smist, T.E.;Ramney, T.A., Heavy Truck Causation: Analysis of the CPIR-B 

File; U.S. Department of Commerce, National Technical Information Service, April 1983 

The CPIR-B (Heavy Truck) accident file identifies specific factors related to heavy truck 

accident causation. The population of over 335 trucks includes both straight and articulated 

(semis) trucks but was selected by a number of different sources over a number of years. 

Consequently, the sample is not random or necessarily representative of the overall population of 

large trucks. Furthermore, the methodology concerning how the various accident categories 

were determined is not fully detailed. This makes it difficult for the reader to evaluate the 

usefulness of the data. 

The analysis does provide a tabulation of component failures for those vehicles involved in the 

crashes. For the 335 trucks involved in the accidents, known brake failure represents 3.6 percent 

of the total. 

(FACT Database) Shelton, Terry, “What is the Current Level of Compliance?” North 

American Brake Safety Conference, Toronto, Canada, September 2000 

The contribution of brake defects as a contributor to truck crashes is uncertain. Some study 

analyses show brake defects being responsible for up to 45 percent of truck crashes and trucks 

involved in crashes are at least as likely to have brake defects as trucks sampled randomly. The 

Michigan FACT project, which included a detailed field inspection of trucks involved in fatal 

accidents, showed that about 31 percent of trucks involved in fatal crashes had brake defects. 

However, it is uncertain how often these defects actually caused the crash. 
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Fleischer, G.A., Philipson L.L., Statistical Analysis of Commercial Vehicle Accident 

Factors Volume II – Summary Report. NHTSA, Washington D.C, 1978 

This report is based on an analysis of about 3,000 California State Highway Patrol accident 

reports for a one-year period. The statistical analysis focuses on quantitative risk analysis. The 

report does include a breakdown of the “inadequacy of certain functions.” Braking in-lane 

represented 27 percent, brake and steering 15.8 percent, brake-fade 0.7 percent, brake-caused 3.3 

percent for skid, and 3.3 percent for leaving lane. However, in only about 200 cases did an 

officer cite equipment violations. 

Freund, Deborah M., Woodford, Gary R., Minor, Larry, Stopping on 18 Dimes: A Decade 

of Progress in Motor Vehicle Brake Safety.” Proceedings of 2002 International Large 

Truck and Bus Safety Research and Policy Symposium, Knoxville, TN, 2002. 

This article describes the changes in brake safety standards over time, the role of the FMCSA in 

brake safety and publishing brake regulations, and the trend in OOS brake violations identified in 

inspections from fiscal years 1989 through 2000. The article cites the development and adoption 

of automatic brake adjusters and brake adjustment indicators as being major steps forward in 

ensuring brake safety. Both NHTSA and FMCSA have been active in issuing rules requiring 

anti-lock braking systems (ABSs). 

Performance-based brake testing has been supported by the FMCSA, which has published 

specifications for brake-testing machines purchased by States with FMCSA grants. The FMCSA 

also proposed regulations for pass/fail criteria to be applied to brake testers that are used in CMV 

inspections. 

The article also examines data from roadside inspections concerning the number of OOS brake 

violations found during each of the fiscal years from 1989 through 2000. The data show a 

decrease in OOS brake conditions from 54.6 percent in 1989 to 34.3 percent in 2000. The 

authors attribute the improvement in reducing the number of OOS brake adjustment violations 

by more than 60 percent. 

It may be possible to determine the reduction in crashes over the same time period and estimate 

the fraction of those that may be attributed to the reduction in OOS brake adjustment violations 

Jones, Ian S., Stein, Howard S., Vehicle and Driver Factors in Relation to Crash 

Involvement of Heavy Trucks. (Insurance Institute for Highway Safety) Proceedings of 

Strategic Research Program and Traffic Safety on Two Continents in Gothenburg, 

Sweden, September, 1989. VTIrapport 351A, 1990. 

Large truck (greater than 10,000 pounds) crashes on Washington interstates were investigated for 

a two-year period. For each large truck involved in a crash, three trucks were randomly selected 

for inspection at the same location and time of day as the crash but one week later. The effects 

of truck and driver characteristics on crashes were assessed by comparing their relative 

frequency among those trucks that crashed compared to the sampled trucks. The study found 
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that trucks with defective equipment were over-involved in crashes. Trucks with brake defects 

had a crash risk one-and-a-half times that for trucks without brake defects. 

The study involved 667 crashes involving 734 large trucks over a two-year period. The sample 

was then limited to tractor trailers. These represented about 60 percent of the crash sample. 

Seventy-seven percent of crashes involved tractor trailers had at least one defect violation 

compared to 66 percent of the comparison sample. Trucks with brake defects were present in 

56 percent of the crash sample compared with 44 percent of the comparison sample. Thus, the 

relative risk for trucks with out-of-service defects (OOS) was estimated to be 1.7. Trucks with 

only violation defects (and not placed OOS) were 1.5 times the risk. Clearly, defective brakes on 

tractor trailers result in more accidents than trucks with good brakes. However, the actual 

increased risk for a crash must also take into account such factors as driving long hours and 

driver inexperience. 

Kolstad, James and Harris, Claude, Air Brake Problems–New NTSB Recommendations 

(Sessions Summary), The Trailblazer, October 1992. 

This article summarizes a conference session held in October, 1992. The participants agreed that 

significant brake problems are quite widespread. For example, in 1988, the NTSB investigated 

189 heavy truck accidents and found significant braking problems in 32 of them according to 

Kolstad, a former NTSB chairman (16.9 percent). A 17-month study that began in 1989 

examined the brakes on 1,520 5-axle trucks at weigh stations. More than 56 percent of the trucks 

(856 trucks) were taken out of service because of brake system violations. More than 46 percent 

of the trucks were placed out of service for OOA brake violations alone. 

Kolstad commented on the significance of OOA or deficient brakes by stating that although these 

brakes can stop or slow a truck in a routine stop, they may be incapable of stopping a truck in an 

emergency braking operation. 

(Operation Air Brake) Ford, David W., Brake Safety on Trucks Still a Concern; MSP 

Obtains Infrared Cameras, Michigan State Police Online Newsletter, Michigan.gov/msp, 

September 2002. 

The Michigan State Police completed their annual Operation Air Brake report for 2002. The 

results showed that approximately 15 percent of all trucks checked during the random 

inspections were placed out of service for brake violations. In 2001, 16 percent of all trucks 

checked were placed out of service because of brake violations. This percentage of OOS brake 

violations can be related to crashes that could potentially be avoided with improved inspection 

and maintenance. 

Rune, and Vaa, Truls, The Handbook of Road Safety Measures, Elsevier, 

Oxford, U.K., 2004. 

This handbook summarizes the results of more than 1,700 road safety evaluation studies. The 

book includes all vehicle types and diverse studies relating to road safety measures. Subjects 
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covered include highway engineering, traffic control, vehicle design, and driver training. 

Unfortunately, the section on heavy truck ABS and Disc Brakes does not include any studies that 

focus on heavy truck performance or, more specifically, the role of brake malfunctions in 

accidents. However, in another section on safety equipment on trucks and heavy vehicles, the 

authors state that trucks with technical defects have an accident rate that is 70 percent higher than 

trucks without defects. This indicates that increased inspections of semitrailer trucks should be 

able to reduce accidents. In a section dedicated to vehicle and garage inspections (including 

roadside inspections) the authors cite two studies that examine the affect of periodic inspections 

on heavy vehicles. These are described elsewhere in this literature review. 

SafeStat 2003 Data for Preventable OOS as a Percentage of Total OOS Violations, 

Interpreted by Zonar Systems Corporation, 2003. 

Zonar Systems prepared a graph showing the percentage of preventable OOS as a percentage of 

total violations. Brake violations are shown as 22.14 percent of the total. 

Wilson, D.F.; Kenik, E.A.; Blau, P.J., Evaluation of Corrosion Failure in Tractor-Trailer 

Brake System. Oak Ridge National Lab., TN, July 2002. 

This report analyzes an example of a tractor-trailer brake that failed due to corrosion. Although 

the report indicates that an increasingly large number of brakes on tractor trailers are failing 

because of corrosion, there is no attempt in the report to quantify this conclusion or to link the 

number of corrosion induced brake failures to crashes. 

B.2 Need for Better Driver/Brake Technician Training and Inspection 

Clark, B., Preventive Maintenance: The Key to Dependability, Owner Operator, Vol. 10 

Issue No. 4, 1980. 

Preventive maintenance for trucks is described as the best way to avoid breakdowns on the road. 

Preventive maintenance is defined as a series of scheduled inspections and services scheduled on 

a time or mileage frequency. The purpose is to prevent major problems by catching problems 

when they are small and by ensuring that parts are properly lubricated. Brake-lining checks are 

cited as an example of a type of preventive maintenance that keeps watch on lining wear and 

replaces it before damage is done to the drums. Model preventive maintenance/inspection forms 

are included with the article. 

Technology & Maintenance Council’s (TMC) Future Chassis (Brakes) Task Force Future 

Brake Position Paper (2001)—1, TMC/ATA, Future Truck Program Position Paper, 

Future Braking System, Equipment User Expectations, 2001. 

This paper, which is the result of an effort by a TMC task force, describes future braking 

systems. The position paper describes the needs of motor carriers with respect to future braking 

systems during the next 5 to 10 years. The paper notes that the trucking industry has expressed 

the need for further enhancements resulting in improved product performance, maintenance, and 
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safety. Any improvements made should be compatible with, and not adversely affect, other 

systems. Future braking systems should significantly reduce stopping distance which would 

likely reduce the number and frequency of crashes. This will result in a safer vehicle under all 

driving conditions. In addition, future vehicle changes, such as changes in GVW, vehicle 

geometry, and vehicle performance improvements, have to be considered in order to satisfy 

future requirements for stopping distance reduction. The paper recommends that future brake 

systems have enhanced diagnostics and warning capabilities including status indication for 

wearable components that require periodic maintenance. Furthermore, the onboard diagnostic 

capabilities should include maintenance scheduling and service prediction, prior to experiencing 

severe, unsafe vehicle conditions that would lead to out-of service or worse conditions. 

Selected NTSB Reports 

The NTSB crash investigations cited below represent those that are brake related. NTSB reports 

were consulted to gain an understanding of the types of crashes likely caused by pre-crash brake 

problems. 

 

Highway Accident Report, Collision Between Truck-Tractor Semi Trailer and School 

Bus Near Mountainburg, Arkansas on May 31, 2001, NTSB/HAR-02/03 

PB2002-916203 National Transportation Safety Board, 2002. 

This report analyzes a fatal crash that occurred on May 31, 2001, near Mountainburg, Arkansas, 

involving a Gayle Stuart Trucking, Inc., truck-tractor semitrailer that collided with a 65-passenger 

school bus operated by the Mountainburg, Arkansas, Public Schools. Three school bus passengers 

were killed; two other passengers received serious injuries. The southbound truck-tractor 

semitrailer exited Interstate 540 at State Highway 282 near Mountainburg, Arkansas. The 

driver was unable to stop at the stop sign at the bottom of the ramp. The 79,040-pound 

combination unit was traveling approximately 48 mph when it entered the intersection and 

collided with the right side of the westbound school bus. After their investigation, the NTSB 

determined that the probable cause of the accident was the truck driver’s inability to stop the 

tractor semi trailer at the stop sign at the bottom of the ramp due to the reduced braking 

efficiency of the truck’s brakes. Furthermore, the NTSB determined that the brakes had been 

poorly maintained and inadequately inspected.

NTSB/HAB-01/01, Accident No.: HWY-99-FH012, March 2, 1999. 

This NTSB report describes a fatal bus crash that the NTSB concluded was caused by 

malfunctioning brakes. An inspection determined that the steering-axle brakes were OOA 

and the brake drums had dark spots, typically seen on overheated drums. The drive axle 

brakes were also OOA to the extent that they were incapable of providing any braking force. 

The brakes on the auxiliary weight-bearing axle, commonly referred to as a “tag axle,” were 

not operational because they were “cammed over.” Both tag axle drums were worn beyond 

the manufacturer’s accepted limits. 
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On March 2, 1999, a 1979 Motor Coach Industries MC-9, 47-passenger charter motor coach, 

owned and operated by Shuttle Jack, Inc., (Shuttle Jack) of Santa Fe, New Mexico, carrying 

2 adults and 34 children was returning from a ski trip. The bus was descending a 14-mile 

mountainous roadway when about halfway down the roadway, the driver discovered that the 

vehicle’s air brakes were no longer capable of slowing or stopping the bus. He noted that the 

brake air-pressure-gauge reading was between 90 and 120 pounds per square inch, which was 

the normal system operating pressure for this vehicle. During the next 3.5 miles, the driver 

made several unsuccessful attempts to bring the bus under control by pumping the air brakes, 

down-shifting the automatic transmission, pulling on the emergency/parking brake valve, and 

shutting off the engine. Eventually, the driver lost control of the bus while rounding a lefthand curve. The bus departed the right side of the roadway, crashed into a rock 

embankment, and then rolled onto its left side back onto the roadway. Two passengers were 

fatally injured and the 35 other occupants received varying degrees of injuries. 

NTSB/HAB-02/14, Accident No.: HWY-98-SH-018, February 17, 1998, 4:00 p.m. 

This NTSB report describes the fatal crash involving a double semitrailer and a van. The 

NTSB determined that the likely cause of the accident was inoperable brakes. The driver of 

the tractor-double semi trailer stated that she noticed traffic on Interstate Highway 405 

slowing in front of her and began applying the brakes. When she applied her brakes, the air 

pressure for the brake system depleted rapidly. The double semitrailer crashed into the first 

vehicle stopped in traffic ahead, a Dodge van, and pushed it into five other vehicles. The 

double semitrailer and van erupted in fire. Three van occupants were fatally injured; seven 

others involved in the collision sustained minor injuries. 

B.3 Training Programs 

Ohio Commercial Drivers License Manual; Version 2.0, June 1998 

The manual provides driver licensing testing information for all drivers who wish to have a CDL. 

The manual includes pre-trip inspection information for air brakes as well as a section describing 

how to use the brakes while driving in such situations as on a downhill stretch. This recent 

commercial driver’s handbook was used as a resource for considering driver training measures 

for brake inspection and maintenance.