by Jim Park
There probably isn't a Class A driver in Ontario near, at, or over age 65 who hasn't heard of regulation 340/94, particularly section 16 - the one that can wipe out a decades-long, multimillion-mile safe driving career with a trip around the block. Class A drivers in Ontario are currently required to "re-license" upon reaching age 65, and annually thereafter. Age is the sole trigger for this requirement, and Ontario is the only jurisdiction in North America (perhaps the world) where this occurs.
Ontario's Ministry of Transportation calls it a "safety" issue, "citing the increased responsibilities and higher level of proficiency required to operate commercial vehicles, coupled with the fact that truckers spend long hours at the wheel, often under adverse driving conditions, thus increasing their exposure to the risk of a collision."
Lately though, in remarks to drivers enquiring about the validity of the test, Ontario's current Transport Minister, Donna Cansfield, has added something to the unofficial party line (above), what she says is statistical justification for the testing.
"Class A licensed drivers that are age 65 and older are 1.5 times more likely to be involved in an injury collision than those aged 45 to 64. Looking at that statistic, it tells us that we have to ensure that they're obviously ready to drive or continue to drive. That's why we have the testing," Cansfield told highwaySTAR in a recent interview.
But, is there a higher accident rate among working senior class A license holders?
Responses from bureaucrats and a succession of politicians have been creative and convoluted, but never conclusive, says Joanne Ritchie, head of the Owner-Operator's Business Association of Canada (OBAC).
"To see research that justifies the testing, we're told, requires a formal Freedom of Information request and, of course, a fee. So how about the total number of class A license holders age 65 and older and the number of convictions under the HTA for that group? ‘It's not that simple,' the people at the licensing administration office tell me. Information for speeding convictions, for example, doesn't link age with license class. So they can tell you the range of speed by age group and range of speed by license class, but they can't tell you how many older class A license holders are speeding. Go figure."
What they will say is that the requirement for testing, introduced in 1976, is based on research showing that aging can affect a person's driving ability. That's why, they say, the Canadian Council of Motor Transport Administrators (CCMTA) has developed Medical Standards for Drivers. Indeed, Standard 6 of the National Safety Code sets out medical requirements for all drivers - not just commercial drivers or aging drivers - and is intended as a guide in establishing basic minimum medical qualifications.
There is little question that the body deteriorates with age. The data are reasonably clear that psychomotor, perceptual, and cognitive abilities change with aging as well.
Natural decline, illnesses, and medications all can contribute to reducing driving competence.
But, claims Ritchie, there is no evidence anywhere that would suggest age, in and of itself, should act as a barrier to employment or driving privileges.
"In fact, the CCMTA medical standard - MTO likes to fall back on - clearly states that restrictions against motor vehicle operation are to be based on support from a physician familiar with the individual's medical history," says Ritchie.
The Influence of Aging
There is a significant body of research on "aging" and a growing number of organizations concerned with ensuring sustainable, safe mobility for older Canadians in the general population, yet surprisingly little research has addressed the actual evaluation of driver competence or methods for identifying potentially unsafe older drivers, and none of the research addresses commercial drivers specifically.
Dobbs, whose test is geared to automobile drivers with medical conditions, emphasizes that the issue is driving competence, not age. "Talking about older drivers puts the focus on the wrong group," Dobbs explains. "The best of drivers - no matter what their age - can become unsafe when medical conditions alter their abilities. There's no doubt that as you get older, you are more likely to have these conditions. But the issue isn't age; it's illness."
One disconcerting aspect of the Ontario testing regime is the on-road test itself, which is the same test administered to all new class A applicants; there is nothing in the exam that would reveal shortcomings related to age, such as eroding cognitive skills, reaction time, decision-making capability, or physical dexterity.
But it doesn't take a medical expert to figure that out. Ask OBAC member Jim Rylance his opinion of the annual road test. Says 76-year-old Rylance who has logged over five million accident-free miles in his 57-year driving career: "I can't imagine what they hope to prove about my ability to handle a truck by making me do a circle check and drive a few miles around town. If they wanted to test my reaction time and awareness of what's going on around me, they could do that on a pinball machine." There are about 3,000 other senior class A drivers in Ontario who are subjected to the same ritual.
According to John Brock, Ontario's arbitrary age-trigger for testing is flawed in two respects: older commercial drivers can be discriminated against if invalid tests are used, and even worse, people who should not be driving because of cognitive impairment can slip right through the screen.
Brock, who has over 40 years of experience in human factors engineering and research, was involved in one of the very few age-based research studies that looked at real-world tasks for commercial drivers, a 1995 study commissioned by the U.S. Federal Highway Administration entitled "Research to Enhance the Safe Driving Performance of Older Commercial Vehicle Drivers."
Brock's research team found that while older commercial drivers demonstrated the expected performance deficiencies on traditional ability measures (e.g., reaction time, range of motion, simple problem solving), they actually drove a truck simulator better than younger truck drivers in a control group. Maturity and experience, not surprisingly, can compensate for loss of driving skills and capabilities in older commercial drivers. Typically, they maintain their performance levels by using their experience, automation of some activities, and streamlining of tasks.
Where To From Here?
The fact that Minister Cansfield is quoting road safety statistics is the first hint that her ministry may be actually taking their head out of the sand on this issue. MTO is currently conducting a review of commercial driver licensing requirements, and Cansfield says her ministry is looking at a number of initiatives, including license reviews and possible retesting for all commercial drivers based on driving record and violation history.
"[If the measures come to pass] upon renewal, they would have to pass a normal written exam, and a written air brake exam [as is the case now]," Cansfield told us. "The practical road test and air brake exam would only be required if the driver had more than five demerit points, and more than one preventable collision in the last two years, or more than one Commercial Vehicle Safety Alliance Out-of-Service condition in the previous two years."
"No argument there," says Ritchie. "We have no problem supporting testing of class A license holders on an as-required basis - regardless of age - as long as the trigger is linked to factors such as a driver's safety record, the demerit point system, or medical-based criteria that suggests testing is warranted."
"But who do they think they're kidding today?" asks Ritchie. "To believe they're taking unsafe old drivers off the road by administering the current mark-and-measure, circle-check, and drive-around-the-block test is just plain silly, and until there's a test developed that can measure the failing abilities associated with aging, the ministry needs to end this humiliating, costly, and utterly useless practice of harassing some of Ontario's most conscientious and safest drivers."
When questioned about the validity of the current test, Cansfield agreed driver's concerns were legitimate.
"That's a fair point," Cansfield replied. "To be honest with you, I don't have an answer on that. I would have thought they were testing driver related skills based on age. Certainly your cognitive ability at 20 or 30 is different than at age 60 or 65 or 70. Your ability to react, and your gross motor skills are quite different as well. If you're saying that they're not testing to that, well, maybe there is an opportunity to really review this. And that's why that review is under way."
How Old is Too Old to Drive?
The same regulation that can put an experienced commercial driver out to pasture at 65, has vastly different rules for other classes of drivers. Holders of class G or M licenses - automobile or motorcycle drivers - need undergo vision and knowledge tests every two years beginning at age 80, and a road test only if the driving record or medical testing deem the driver to be at risk. If you're a 70 year-old automobile or motorcycle driver who has been convicted of a collision-related offence, you'll be subject to vision, knowledge, and road testing before you're on your way again. Even holders of a class D license (straight trucks), are subject to the annual road test only at age 80.
Ontario's age-only trigger leaves the experts scratching their heads. The U.S. Transportation Research Board (TRB) has a "Safe Mobility of Older Persons Committee" that provides a forum for researchers and practitioners to share research and information on improving the safety and mobility of older drivers. According to Richard Pain, TRB's Transportation Safety Coordinator in Washington, one of the problems researchers have is defining just what an "older driver" is. "We simply don't use age as a starting point for any research," says Pain. "It's all based on physical and mental health and/or medical conditions." If pushed to put a number to "old," Pain admits it's generally in the 75-80 range before it even registers on their radar screen.
In Canada, as elsewhere, there is growing awareness of the major long-term challenges governments face in meeting the transportation needs of an aging population.
CCMTA has recently developed an ambitious aging-driver strategy that acknowledges mobility is necessary to preserve social, mental, and physical health and well-being, and points out that giving up one's driver license can be one of the most significant events in an individual's life, symbolizing for many the loss of independence and rejection from ‘adult' society. The comprehensive strategy, while it is completely silent on issues related to commercial drivers and the trauma associated with losing one's livelihood, says OBAC's Ritchie, is clear in its assertion that government policies and programs must be, among other things, fitness-based, not age-based.
"It boggles the mind how Ontario continues to stand alone in ignoring, in the case of class A commercial drivers, the growing body of scientific and medical evidence that the aging process varies from person to person, and the correct measure of fitness to drive is functional ability, not age," Ritchie adds.