Entry-level driver training rule changes game for behind-the-wheel safety

For fleets that run their own driver training program, however, the rule is adding another layer of compliance and complexity. Joe DeLorenzo, acting associate administrator for enforcement and director of the office of enforcement and compliance for FMCSA, said fleets operating their own programs will have to certify their curriculum meets FMCSA’s standards, which apply to all entities conducting driver training.

“What it’s doing is creating a uniform consistent minimum standard of training for CDL holders across the board,” he told FreightWaves. “It’s a self-certification [process] but they do have to submit their curriculum along with their training certification.”

All driver training programs run by schools or fleets must register with FMCSA’s Training Provider Registry (TPR). The registry sets out standards for schools, such as:

• Specific criteria addressing curriculum, instructors, facilities, vehicles, equipment and recordkeeping must be met.
• If a state has requirements to be an educational institution, school or training provider, these requirements must be met.
• If the school is open to the public.
• The type of training provided.
• Average training hours.
• Average training cost. 

Any third-party affiliations, certifications or accreditation must be included in the application. Training providers must also transmit records of successful driver trainee completion of ELDT to applicable state driver licensing agencies.

DeLorenzo said prospective drivers can only obtain a CDL if they have graduated from a TPR-listed program.

“As of February, if a driver doesn’t go to a school on the TPR, they are not going to be able to get their license,” he said, noting that this also applies to any driver seeking hazardous materials, passenger or school bus endorsements for the first time. As of Oct. 26, there are 2,363 training providers covering 2,740 locations registered with the TPR, FMCSA said.

“Companies that train their own drivers will now need to prepare their trainers to teach the required ELDT curriculum and also provide the tools needed to deliver that training,” said Dustin Kufahl, director of driver training at J. J. Keller & Associates Inc. “When we developed our J. J. Keller ELDT Certified Driver Trainer Program, we created a hands-on service that teaches trainers how to deliver our complete ELDT curriculum in the classroom, on the range and on the road and then provide the teaching materials to facilitate that training. This gives fleets a turnkey solution for preparing their trainers to meet the compliance deadline quickly.”

For fleets running their own programs, time is running short to ensure their programs and instructors meet the curriculum requirements. DeLorenzo said the programs must update their status every two years.

“Anybody can become a training provider as long as they meet those standard requirements,” he said. “The whole point is you have this minimum standard training requirement. … 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.”

The new rule makes several changes from previous training standards, said Kufahl.

“The new ELDT rule is such a significant change from the current rule,” he said. “Starting Feb. 7, 2022, your entry-level drivers won’t be able to take their CDL test until they successfully complete a specific program of theory and behind-the-wheel instruction provided by a school or other entity listed on FMCSA’s Training Provider Registry. If your company trains its own drivers, you’ll need to start updating your entire training program to meet the new requirements.”

Theory curriculum 

For drivers seeking Class A or B CDLs, the ELDT prescribes instruction in five major areas:

• Basic operation including pre- and post-trip inspections, coupling and uncoupling (Class A only).
• Safe operating practices including visual search, night driving and extreme driving conditions.
• Advanced operating practices including hazard perception, skid control/recovery and other emergencies, and railroad-highway grade crossings.
• Vehicle systems and reporting malfunctions including identifying and diagnosis of malfunctions, maintenance and roadside inspections.
• Non-driving activities including handling and documenting cargo, hours of service and post-crash procedures.

For Class A CDL trainees, there are 30 total specific theory topics that must be addressed, while a Class B requires 29 theory topics to be studied. Instructors must complete an assessment of each unit of instruction to determine proficiency. Students must achieve a minimum score of 80 to receive credit.

Getting behind the wheel

The ELDT rule requires both theory and behind-the-wheel instruction. Instructors must hold the appropriate class of CDL for at least two years and have either two years of experience driving or two years of behind-the-wheel commercial vehicle instructor experience.

What the ELDT doesn’t mandate, however, is a minimum number of hours behind the wheel, instead deferring to the instructor to determine when the student is sufficiently prepared. DeLorenzo explained that the ELDT rule was “built around performance standards” to provide flexibility to the training provider.

“As with any federal regulation, it is a minimum standard, but in this case, it is also a performance standard,” DeLorenzo 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.”

When teaching the behind-the-wheel curriculum for both Class A and B CDLs, instruction must be completed in a vehicle of the same group or type the driver trainee intends to use for the CDL skills test, Kufahl said. Additionally, the instructor must engage in active two-way communication with driver trainees during all active behind-the-wheel public road training sessions.

Behind-the-wheel instruction includes:

• Range instruction on seven topics (six for a Class B CDL) including vehicle inspection, backing and coupling/uncoupling for Class A CDLs.
• Public road instruction on 12 topics including visual search, speed and space management, and safe driver behavior.
• Demonstrated proficiency with each required maneuver successfully repeated several times until proficiency is achieved as determined by the instructor’s assessment of the performance of required elements and professional judgment.

Endorsements

For the first time, the ELDT is requiring those seeking passenger, school bus or hazardous materials endorsement to complete the formal training.

Passenger endorsement requires training on 18 topics, including theory instruction on baggage and/or cargo management and passenger management and behind-the-wheel instruction on six topics including vehicle orientation.

School bus endorsement training covers 11 theory topics including danger zones and use of mirrors and school bus security and six behind-the-wheel topics including loading and unloading and emergency exit and evacuation.

For hazardous materials endorsements, 13 topics must be covered in theory instruction, including loading and unloading, emergency response procedures and routes and route planning.

Record-keeping

The final piece of the new ELDT puzzle is record-keeping, and this is especially true for fleets that may run their own programs. The rule mandates training-related documentation be held for at least three years from the date each required record is generated or received. This includes: 

• Driver-trainee documentation, including self-certifications of compliance and a copy of the CLP.
• Instructor qualification documentation, including a copy of the CDL.
• A copy of the registration submitted to the TPR.
• The lesson plans for theory and behind-the-wheel (range and public road) training curricula, as applicable.

Some states and/or federal agencies may prescribe a longer period of record retention, so fleets and training schools should be aware of and adhere to those requirements, Kufahl said.

For those concerned about varying levels of training across programs, DeLorenzo said if the training program is meeting the minimum standards as set forth in the rule, that shouldn’t be an issue.

“If we saw a pattern of poor performance coming from a school, then we would have to take a look [at its curriculum],” DeLorenzo said.

CVTA’s Wood said the rule is the right approach for the industry. “The quality of a truck driver will go up and that’s good,” he said.

February will be here soon and fleets that know they will be training new drivers need to start the preparation process now. 

“For fleets that know they will need to train new drivers, it’s critical to prepare now by getting trainers ready to train according to the new ELDT requirements,” Kufahl said.

Click for more articles by Brian Straight.

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