It has been more than a month since the Federal Motor Carrier Safety Administration’s (FMCSA) game-changing entry-level driver training (ELDT) rule went into effect. Under the rule, anyone training drivers — both those new to the industry (Class A and B CDLs), those seeking endorsements (passenger, school bus or hazardous materials) for the first time or even experienced drivers looking to upgrade their CDLs — must meet minimum training standards and receive that training from a registered institution.
To be certified, drivers must complete their training from a school or other entity (including carriers) listed on FMCSA’s Training Provider Registry (TPR) before taking the CDL skills test or CDL knowledge test for hazmat endorsement.
For carriers, the big change with the ELDT rule is that if they provided training or assistance to individuals looking to obtain a CDL — often done as part of the onboarding process for new hires — they must now register with the TPR and certify their compliance with the new regulation. There may also be state registration or additional instructional requirements in some instances. Carriers could also decide to outsource the entire process, explained J. J. Keller & Associates.
As with anything, there are pros and cons for carriers continuing to conduct their own training. On the plus side is the ability to integrate CDL training with company-specific policy and procedure training. Training can also be conducted on the equipment the driver will be expected to operate. And in the current climate of too few drivers, it reduces the chance the student will be poached by a competing company as he or she finishes up driver training school.
Conversely, carriers must consider some of the drawbacks, including cost and dedication of resources to complete the training. (These are detailed below). There is also the chance the student leaves the employ of the carrier either before training is completed or soon thereafter, denying the chance to recoup the costs invested in the training process.
The decision to train
For carriers that decide to conduct driver training, the first step is to ensure they are listed on the TPR. The TPR serves three distinct purposes. It serves as a repository for schools or other entities to verify they are in compliance with the ELDT rule. Schools must submit to the TPR:
- Provider name and contact information.
- Facility name and contact information.
- Type of provider — i.e., for hire or in-house.
- Type of training provided.
- Average training hours and cost.
- Third-party affiliations, certifications or accreditations.
Prospective students are able to search the TPR for approved programs. Once training is completed, the school or entity conducting the training must submit the following information on the student (this must be submitted by midnight of the second business day following completion of driver training):
- Driver trainee name, date of birth, license/permit number and issuing state.
- CDL class/endorsement and type of training completed (behind the wheel or theory).
- Total number of clock hours spent behind the wheel (if applicable).
- Training provider name, location and TPR ID number.
- Date of successful completion of training.
Before a carrier makes the decision to register with TPR and conduct training, it needs to understand the process. This includes theory and behind-the-wheel instruction.
Theory instruction must be conducted in 30 specific areas (for a Class A CDL, requirements vary for Class B, passenger, school bus or hazardous materials endorsement) and students must achieve at least an 80% overall score on a theory assessment. Instruction may include lectures, demonstrations, computer-based instruction, audio-visual presentations, online instruction and driving simulators.
The second part of training is behind-the-wheel instruction. Class A behind-the-wheel is focused on 19 specific areas, with proficiency achieved (meaning the skill must be completed multiple times) based on the instructor’s professional opinion of the student’s ability.
Training the trainer
A key component of any driver training program is the instructors. For carriers undertaking the training, it’s imperative to have qualified instructors. Joe DeLorenzo, acting associate administrator for enforcement and director of the office of enforcement and compliance for FMCSA, previously explained to FreightWaves the importance of having qualified trainers.
“There are requirements for trainers that are laid out in the rule so when the school submits their certifications, they are submitting that they are in compliance with the training requirements and that their trainers are in compliance,” he said.
Carriers may need to pull a top driver off the road to conduct training or hire from outside. In either case, trainers must have the correct class of CDL and all applicable endorsements, and their CDLs must be valid and not revoked, suspended or canceled. In addition, the trainer must have two years of experience as a CDL driver or behind-the-wheel CDL instructor.
In addition, J. J. Keller Senior Editor Jill Schultz advised evaluating the trainer’s driving record and track record with your company (including accidents, incidents, near misses, customer praise and/or complaints, and performance reviews). The carrier may also want to conduct a company-administered road test to evaluate behind-the-wheel proficiency.
Also, instructors must be certified in the same way as drivers, including a driver qualification file and drug and alcohol testing requirements.
Program must-haves
When building an ELDT training program for your trainers, it’s important to ensure uniformity across all instructors. All instruction must address the ELDT requirements as well as the organization’s policies and procedures, Schultz said.
Instructor candidates should complete educational courses that may include instruction on teaching, public speaking and adult learning best practices in addition to the requirements on all aspects of ELDT instruction and record-keeping.
Training facilities must meet all federal, state and local requirements under the federal ELDT rule. Theory training should be conducted in a room large enough to accommodate the training class and include all necessary materials/assets, including computers, projectors, dry-erase boards, etc.
Behind-the-wheel instruction can take place on a range and roadways. For range training, it must take place in an area that is free of obstructions, enables the driver to maneuver safely and free from interference from other vehicles and hazards, and features adequate sight lines. The range area could be a parking lot or other area not readily accessible by other vehicles. Instructors should consider the skills being taught when selecting a range area, Schultz advised.
When on-the-road training begins, the instructor should be taught to choose the appropriate atmosphere with challenges that are acceptable to meet the skills being taught.
Vehicle requirements
An advantage of a carrier conducting its own training is the ability to train candidates on the type and class of vehicle the student intends to drive. All vehicles must meet federal, state and local requirements.
Instructors must maintain adequate visibility down the left side of the vehicle and be able to stop the vehicle at a moment’s notice, Schultz said. This may mean a carrier will likely need to install an additional brake for the instructor. There may also be additional students in the vehicle, so proper seating must be installed to enable observation in these cases.
Record-keeping requirements
As with any fleet operation, there are records to be maintained. In the case of ELDT training, there are both student and instructor records that must be preserved. The timeline for these is typically three years from the date each record is generated or received, although in some cases, state or local requirements may dictate longer record retention.
Student records that must be maintained include:
- Certification by the student that he/she will comply with federal, state and local laws and regulations related to controlled substances testing, age, medical certification, licensing and driving records.
- Driver qualification file and drug and alcohol records.
- A copy of the commercial learner’s permit (CLP).
- A copy of the CDL (if applicable).
Instructor records that must be maintained include:
- Driver qualification file and drug and alcohol records.
- Instructor qualification documentation of driving and/or training experience, as applicable.
- Copies of CDLs and applicable endorsements.
In addition, training-related records such as lesson plans, student assessments, checklists and any other record documenting student performance or instructional time must be retained.
Carriers interested in hiring new drivers typically have two choices: recruit from driver training schools or create their own program. There are obvious advantages to both approaches, but in either case, it is the details that matter and enlisting the help of third-party compliance specialists can smooth the process.
DeLorenzo told FreightWaves that the ELDT rule is a baseline for which to ensure the industry is able to attract and train safe commercial vehicle operators.
“As with any federal regulation, it is a minimum standard, but in this case, it is also a performance standard,” he said. “We wanted to ensure the instructor has the ability to [train] the hours needed to meet that minimum performance standard. You can always go above the federal standard.”
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