The Crash Causal Factors Program (CCFP) is a detailed crash data collection and analysis effort intended to:
- Identify the key factors that contribute to crashes involving commercial motor vehicles (CMVs),
- Inform countermeasures to prevent these crashes, and
- Establish a foundation for continued data collection, sharing, and analysis.
Through a series of robust studies, the CCFP pursues a nuanced understanding of crashes involving CMVs so that policymakers, law enforcement agencies, regulators, and other interested parties can implement effective crash prevention strategies and programs.
Despite several decades of positive progress, the last few years have seen a concerning rise in fatal crashes in the United States, with fatal crashes involving CMVs increasing 17 percent from 2020 to 2021.1 Authorized by Congress, the CCFP is part of the DOT and FMCSA’s heightened effort to reverse this trend and pursue a long-term goal of zero roadway fatalities.
The CCFP’s multi-phase approach will target unique vehicle types and/or crash severities for each causal factors study. Phase 1 focuses on fatal crashes involving heavy-duty trucks (Class 7/8 trucks) and will leverage existing State and local jurisdiction crash data collection processes to streamline data collection efforts. Future phases will continue to identify existing resources, leveraging these efforts to the extent possible. In addition to producing datasets and analytical reports, the CCFP will establish a foundation for continued data collection and analysis that FMCSA and States can routinely use to optimize their CMV safety activities.
- 1.2021 Fatality Analysis Reporting System (FARS). Accessible through A&I Crash Statistics.
Background
The CCFP expands on the original Large Truck Crash Causation Study (LTCCS) that investigated nearly 1,000 injury and fatal crashes involving large trucks from 2001 to 2003. However, an increase in fatal crashes involving CMVs in the last few years, along with changes in technology, vehicle safety, behavior, and roadway design, has created the need for a new study. The CCFP takes these changes, as well as the growth of the CMV industry, into account and pursues an updated understanding of the causal factors contributing to crashes today.
What’s Happening Now
The CCFP team is working with States and select local jurisdictions to establish sampling locations for the study; qualifying crashes that occur in these locations will be included in the study sample. Additional efforts include creating a CCFP database, establishing data protection measures, and developing tools and training to support data collection.
CCFP Timeline
Timing approximate; schedule subject to change.
2020–2021
Funding & Authorization
Congress appropriates $30 million for a causal factors study on large trucks.
The Infrastructure Investment and Jobs Act (IIJA) expands its scope to include all CMVs.
2022–2025
Program Establishment
FMCSA establishes the CCFP to carry out a multi-phase study of crashes involving CMVs.
Phase 1 Preparation
The Heavy-Duty Truck Study is planned and developed.
FMCSA identifies in-scope States for a nationally representative sample and finalizes the analysis plan.
2026–2028
Phase 1 Execution
FMCSA collects data for two years, leveraging State and local jurisdiction resources, and then analyzes the data.
Phase 2 Preparation
FMCSA kicks off the Medium-Duty Truck Study, pending funding.
2029
Phase 1 Results
The Heavy-Duty Truck Study final report is released.
Future Phases Continue
The Medium-Duty Truck Study is developed and executed. Additional phases will be planned dependent on funding; associated timelines TBD.
Mark Schremmer
The trucking industry is trapped in a cycle of perpetual driver churn, according to a new analysis from the OOIDA Foundation.
In a recently released white paper, “The Churn: A Brief Look at the Roots of High Driver Turnover in U.S. Trucking,” the research arm of the Owner-Operator Independent Drivers Association dispels the notion that there is a driver shortage and, instead, places the spotlight on annual turnover rates of 90% or higher for major truckload carriers.
“Only by understanding the systemic and structural reasons for churn can industry and policymakers begin to allow genuine market forces to work toward a more sustainable equilibrium – one where driving a truck is a viable, even desirable long-term occupation, not a grueling trial with razor-thin margins that one endures only until a better opportunity comes along,” the OOIDA Foundation wrote.
The American Trucking Associations has claimed for years that there has been a shortage of truck drivers. However, multiple studies have debunked the claims of a driver shortage.
A 2024 study from the National Academies of Sciences said that the idea of a driver shortage goes against the basic economic principles of supply and demand. Previous studies came from economics professor Stephen V. Burks and the U.S. Department of Labor. All of the studies revealed that there is not a shortage of truck drivers. Instead, any issues in the labor supply could be corrected by increasing wages.
Perpetual driver churn
According to the OOIDA Foundation, the roots of high driver turnover rates date back to deregulation through the Motor Carrier Act of 1980. Deregulation allowed thousands of new carriers to enter the market, leading to increased competition and reduced profit margins.
“This competitive landscape effectively eliminated companies’ ability to raise pay significantly without losing business, embedding high turnover as a standard business strategy,” the OOIDA Foundation wrote. “In today’s highly fragmented truckload sector, minimal differentiation among employers keeps drivers cycling between similar low-quality jobs or leaving the industry entirely rather than seeing substantial improvements in pay or conditions.”
Rather than a driver shortage, the OOIDA Foundation noted that what the industry is experiencing is high turnover that’s become the standard operating model for large carriers.
Why hasn’t it been corrected?
The OOIDA Foundation said that several intertwined factors mute the natural market corrections that would typically resolve labor shortages:
- Extreme competition: Intense competition restricts carriers from raising wages significantly without losing business.
- Labor supply inflation: Industry and government initiatives continually increase the labor pool through non-market means, artificially depressing wages.
- Regulatory loopholes: The overtime exemption for motor carriers and misclassification practices shift costs onto drivers, artificially suppressing market wages.
- Limited bargaining power: Fragmented and individually powerless drivers cannot negotiate better conditions effectively.
- Information asymmetry: Many new drivers enter the industry under misconceptions about earnings and conditions – ones sometimes intentionally fostered by dishonest parties – which maintains a high turnover cycle.
“The persistent churn in trucking results from systemic distortions rather than a genuine shortage,” the OOIDA Foundation wrote. “Addressing these foundational issues – realigning incentives, improving transparency and reforming exploitative practices – would allow genuine market corrections, fostering a more stable, sustainable workforce. Until then, the trucking industry remains trapped in a cycle of perpetual churn, undermining its long-term efficiency and safety.”
Mark Schremmer
Truck drivers often vent about the amount of regulations they must follow and how many of them do nothing to improve highway safety.
Well, the time has come for truck drivers to do something about it. But the clock is running out.
On April 3, the U.S. Department of Transportation published a notice in the Federal Register asking the public to help identify regulations that can be modified or repealed without hindering safety.
“The Department of Transportation seeks comments and information to assist DOT in identifying existing regulations, guidance, paperwork requirements and other regulatory obligations that can be modified or repealed, consistent with law, to ensure that DOT administrative actions do not undermine the national interest and that DOT achieves meaningful burden reduction while continuing to meet statutory obligations and ensure the safety of the U.S. transportation system,” the notice stated.
The notice opened a 30-day comment, which runs through Monday, May 5. So far, about 600 comments have been submitted.
Comments can be made by going to Regulations.gov and entering Docket No. DOT-OST-2025-0026.
The DOT is seeking information on:
- Unconstitutional regulations and regulations that raise serious constitutional difficulties, such as exceeding the scope of the power vested in the federal government by the Constitution
- Regulations that are based on unlawful delegations of legislative power
- Regulations that are based on anything other than the best reading of the underlying statutory authority or prohibition
- Regulations that implicate matters of social, political or economic significance that are not authorized by clear statutory authority
- Regulations that impose significant costs upon private parties that are not outweighed by public benefits
- Regulations that harm the national interest by significantly and unjustifiably impeding technological innovation, infrastructure development, disaster response, inflation reduction, research and development, economic development, energy production, land use and foreign policy objectives
- Regulations that impose undue burdens on small business and impede private enterprise and entrepreneurship
Many of the comments submitted so far have suggested the need for more flexibility in the hours-of service regulations.
“If you are driving 11 hours a day and taking a 30-minute break within the first eight hours and working a total of 14 for the day, there is no need to have the 70-hour rule,” Stacey Dain wrote. “As a driver, I get plenty of rest following the other three rules, not being overworked.”
Others have asked the Trump administration to stop a proposal that would mandate speed limiters on commercial motor vehicles.
“Another rule that has been proposed but not enacted is the speed limiter proposal,” Dwayne Pope wrote. “If enacted, this will destroy many lives, because car drivers have become so impatient and dangerous nowadays. They cut slower-moving vehicles off and perform very dangerous maneuvers to get around trucks. Accidents will increase, and then the FMCSA and DOT will blame trucks and implement more useless regulations.”
In addition to the comment period, the DOT will accept emails on a continuing basis at Transportation.RegulatoryInfo@dot.gov about regulations that could be modified or repealed. Include “Regulatory Reform RFI” in the subject line of the email.
Major changes are coming to the medical certification process for commercial vehicle drivers as a long-delayed Federal Motor Carrier Safety Administration (FMCSA) rule goes into effect in June.
The compliance date for the FMCSA’s Medical Examiner’s Certification Integration rule will go into effect nationwide on June 23, 2025, resulting in significant changes for Commercial Driver’s License (CDL) and Commercial Learner’s Permit (CLP) Holders in terms of medical qualification reporting.
The rule is intended to digitize and streamline the medical certification process for commercial vehicle drivers, eventually eliminating the need for drivers to present a paper copy of their Medical Examiner’s Certificate (MEC) to show that they meet physical qualifications to operate a commercial vehicle to state licensing agencies.
Starting on June 23, Certified Medical Examiners (MEs) will be required to submit all commercial vehicle driver medical exam results directly to the FMCSA and State Driver’s Licensing Agencies (SDLAs) through the National Registry of Certified Medical Examiners. Results of exams must be submitted by midnight of the calendar day following the exam, per the rule.
The FMCSA will then electronically transmit driver identification, examination results, restriction information, and medical variance information to SDLAs, a provision meant to reduce errors and streamline the medical certification process. This means that drivers would no longer be required to submit an MEC to SDLAs themselves.
Additionally, after the June 23 compliance date, motor carriers will no longer be required to verify that CLP/ CDL drivers were examined by a certified ME listed on the National Registry.
The Medical Examiner’s Certification Integration Final Rule was adopted in 2015. The compliance date was initially set for June 22, 2018. It was pushed to June 22, 2021, and then to June 23, 2025, due to IT system issues.
Drivers should continue to carry a paper copy until the June 23 deadline and after in case of any issues with the implementation of the online system.
Jason Cannon
A U.S. Circuit Court has reduced the financial penalty levied against Wabash last year in a fatal 2019 motor vehicle accident in which a passenger vehicle struck the back of a nearly stopped 2004 Wabash trailer.
A St. Louis jury last September reached a $462 million verdict against trailer manufacturer Wabash National in a case stemming from a May 2019 fatal crash in which a passenger vehicle hit the rear of a 2004 Wabash trailer being pulled by now-defunct Akron, Ohio-based GDS Express.
Two men, the driver and a passenger, were killed in the collision, which occurred 15 years after the trailer involved was manufactured in compliance with existing regulatory standards, according to Wabash. Evidence Wabash presented in court showed the car was traveling 55 mph at impact – 20 mph faster than the current National Highway Traffic Safety Administration (NHTSA) underride standard, and 25 mph faster than the NHTSA standard at the time of the crash.
A Circuit Court last week ordered the punitive damages award reduced to $108 million with the compensatory damages award remaining at $11.5 million.
“Wabash continues to believe both that the damages remain abnormally high and the verdict is not supported by the facts or the law,” the company said via emailed statement. “The company continues to evaluate all available legal options.”
NHTSA in July 2022 upgraded its safety standards for rear underride protection in crashes of passenger vehicles into trailers and semitrailers by adopting requirements similar to Transport Canada’s standard for rear impact guards. With this final rule, the standards require rear impact guards to provide sufficient strength and energy absorption to protect occupants of compact and subcompact passenger cars impacting the rear of trailers at 35 mph. The final rule provides upgraded protection for crashes in which a passenger motor vehicle hits the rear of the trailer or semitrailer such that 50% to 100% of the width of the passenger motor vehicle overlaps the rear of the trailer or semitrailer.
NHTSA last year published an advance notice of proposed rulemaking exploring possibly requiring side underride guards on trailers. Earlier this year the NHTSA Advisory Committee on Underride Protection (ACUP), a group tasked with providing advice and recommendations to the Secretary of Transportation on safety regulations to reduce underride crashes and fatalities related to underride crashes, said it will recommend to Congress that any trailer built in the last quarter century meet IIHS ToughGuard standards.
Reps. Troy Nehls (R-Texas) and Chrissy Houlahan (D-Pennsylvania) have reintroduced a bill (H.R. 2514) that would require facilities where truck drivers pick up or deliver freight to grant drivers access to restrooms.
The bill, which Nehls and Houlahan introduced twice before, would establish that restrooms would be in an area that does not create an obvious health or safety risk to the driver or post an obvious security risk to the establishment. The bill includes specific provisions for drayage truck operators. For more information, visit https://www.congress.gov/bill/119th-congress/house-bill/2514.
