The Hanover Insurance Group

Road testing

Any employee who may, during their employment, be responsible for the operation of a vehicle should be subject to an evaluation to determine their driving capabilities. Generally referred to as a road test, the evaluation can provide valuable feedback to the employer as to the employee’s driving abilities and if any supplemental training may be necessary. In the case of commercial vehicle (CV) operators, the U.S. Department of Transportation's (DOT) Federal Motor Carrier Safety Administration (FMCSA) regulations specifically require a road test prior to operation of a CV.

Introduction

When a person applies for a job that requires the operation of a vehicle, the hiring process should include an evaluation of that person's driving capabilities. To assure that the potential driver possesses the minimum skills necessary to drive safely and to determine what training may be needed before the driver is assigned a vehicle, the applicant should be given a comprehensive road test. Additionally, motor carriers subject to FMCSA are required to have potential drivers successfully complete a road test and must issue the driver a certificate upon successful completion. The regulations state that in lieu of the actual test a motor carrier may accept:

  • A valid Commercial Driver’s License (CDL) issued to the driver by a state which road tests drivers for the specific category (i.e., class) of vehicle to be driven. However, if the driver will be transporting or operating special trailers, such as doubles/triples or tank vehicles, the employer must administer the road test in a representative vehicle.
  • A valid certificate of road test issued within the past three years, for the specific category (class) of vehicle to be driven.

Where a license or prior road test is accepted in lieu of a road test conducted by the motor carrier, the motor carrier must maintain a copy of the license or certificate in the driver's qualification file. A motor carrier is not required to accept a substitute for an actual road test and doing so is not recommended. Under the regulations, a motor carrier may require any person who presents a license or certificate, as equivalent to the road test, to take a road test, or any other test of his/her driving skill, as a condition of employment.

This report discusses the procedures for developing, conducting, and documenting the road test, as well as the requirements of the FMCSA regulations for driver road testing by motor carriers subject to the CV regulations.

Developing a road test

A standardized road test should be developed to afford comparison of applicants and assure that all necessary skills have been included in it. All tests should be conducted using the type of equipment that the applicant will be driving, if hired. The driver test must be of sufficient duration to enable the person who administers the test to evaluate the skill of the driver.

A form for recording the results of the road test is essential and should be made part of the personnel file of each person evaluated. If the information developed from a road test is to be used to enhance a driver's abilities, it must indicate areas found acceptable, as well as identifying those areas where a driver needs additional training. Employers may designate a third party to administer the road test as long as the person who administers the road test is competent to perform the evaluation.

Road tests are typically broken up into three distinct parts as follows:

Pre-trip inspection

The first part of the road test that should be conducted is a pre-trip inspection, which should include vehicle inspection, operation of any specialized equipment, and in the case of trailers, coupling and uncoupling procedures. Vehicle inspections should focus on the roadworthiness of the vehicle, should be based on the owner's manual, and should at least address:

  • Tire pressure and head depth
  • Fluids levels, including adequate fuel
  • Windows
  • Mirrors
  • Lights, including marker and headlights
  • Turn signals and break lights

See page 8, Pre-Trip Inspection of Automobiles, Vans, and Light Trucks, for a detailed pre-trip checklist for small non CMVs.

CMV pre-trip

To be effective, a pre-trip inspection of CMV must be thorough and systematic and the individual inspecting the vehicle must know what to look for. FMCSA regulations, 49CFR392.7, provides additional requirements for CMV pre-trip inspections, including that the following points be inspected:

  • Service brakes, including trailer brake connections
  • Parking (hand) brake
  • Steering mechanism
  • Lighting devices and reflectors
  • Tires
  • Horn
  • Windshield wiper or wipers
  • Rear-vision mirror or mirrors
  • Coupling devices
  • Wheels and rims
  • Emergency equipment

See, Pre-Trip Inspection of Heavy-Duty Straight Trucks, Pre-Trip Inspection of Medium-Duty Straight Trucks, Pre-Trip Inspection of School Buses, and Pre-Trip Inspection of Tractor-Trailer Units, for a detailed pre-trip checklist for CMVs.

Maneuverability

Prior to an open road evaluation of a driver, basic vehicle handling should be evaluated. This evaluation should be designed based on the vehicle type, size, and function. At a minimum, the maneuverability evaluation should include:

  • Parking
  • Backing in straight line
  • Backing into a dock
  • Turning

Open road

A driver should be evaluated for their ability to operate a vehicle on the road. A predetermined course should be established to present the widest possible variety of driving and operating conditions that the driver might encounter. This segment of the road test will evaluate the driver's skills in normal vehicle operations including:

  • Accelerating
  • Braking
  • Lane changing
  • Turning
  • Maintaining a safe following distance

For sample road test forms see, Road Testing for Drivers of Automobiles, Vans, and Light Trucks, and Road Testing for Drivers of Trucks. Additional criteria to that contained in the forms may be necessary, depending on the type of operation and/or equipment, and can easily be added to the forms.

Summary

The purpose of a road test is to evaluate the ability of the driver to drive defensively and provide an indication of the driver's attitude. It is safe to assume that the driver will be trying to perform in the best possible manner. However, improper driving habits are not easily hidden and should be evident to a qualified evaluator. Before starting the road test, the applicant's driver's license should be examined for validity and any restrictions.

The purpose of each segment of the test should be explained and any questions resolved before starting. Directions to the driver should be clear and concise. Ample time to safely perform the required maneuvers must be available. Any conversation during the test should be related to the test itself. When conducting a driver test, the evaluator must determine the driver's current level of expertise and what training would be needed in the immediate future.

References

  1. Federal Motor Carrier Safety Administration. Best Highway Safety Practices: A Survey about Safety Management Practices among the Safest Motor Carriers. Washington, D.C.: FMCSA, March 2003. http://ai.fmcsa.dot.gov/CarrierResearchResults/PDFs/BestHighwaySafetyPractices.pdf.
  2. —. Federal Motor Carrier Safety Regulations, 49 CFR 300-399. Washington, DC: U.S. Department of Transportation, June 27, 2018. https://www.ecfr.gov/cgi-bin/text-idx?SID=550a0a03ffd128b0ce88732590d331a7&mc=true&tpl=/ecfrbrowse/Title49/49CIIIsubchapB.tpl .

Copyright © 2018, ISO Services, Inc.

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The recommendation(s), advice and contents of this material are provided for informational purposes only and do not purport to address every possible legal obligation, hazard, code violation, loss potential or exception to good practice. The Hanover Insurance Company and its affiliates and subsidiaries ("The Hanover") specifically disclaim any warranty or representation that acceptance of any recommendations or advice contained herein will make any premises, property or operation safe or in compliance with any law or regulation. Under no circumstances should this material or your acceptance of any recommendations or advice contained herein be construed as establishing the existence or availability of any insurance coverage with The Hanover. By providing this information to you, The Hanover does not assume (and specifically disclaims) any duty, undertaking or responsibility to you. The decision to accept or implement any recommendation(s) or advice contained in this material must be made by you.

LC FEB 2019-090
171-1184 (12/18)


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