FMCSA’s Entry-Level Driver Training (ELDT) Requirements

On December 8, 2016, the Federal Motor Carrier Safety Administration (FMCSA) published its long-awaited Entry-Level Driver Training (ELDT) rule. The rule, which will be implemented on February 7, 2020, establishes new minimum training requirements for individuals who want to obtain a commercial driver’s license (CDL); upgrade a CDL; or obtain a passenger, school bus or hazardous materials endorsement. The requirements for those who instruct these individuals are also changing.

We've prepared the information below to help you understand the rule, who it affects, and the compliance deadline, and have provided useful resources to help answer your questions regarding the ELDT final rule.

GENERAL INFORMATION

Key Requirements

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Under the new requirements, an entry-level driver must successfully complete a prescribed program of theory (knowledge) and behind-the-wheel (BTW) (range and public road) instruction. The training must be provided by an entity listed on FMCSA’s Training Provider Registry (TPR) prior to taking the state-administered CDL skills test, or for the H endorsement, prior to taking the knowledge test

Who Must Comply?

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The rule applies to operators of commercial motor vehicles (CMV) in interstate and intrastate commerce who are:

  • Applying for a Class A or Class B CDL
  • Upgrading their CDL (e.g., a Class B CDL holder seeking a Class A CDL)
  • Obtaining a Passenger (P), or School Bus (S) or Hazardous Materials (H) endorsement for the first time

The ELDT requirements do not apply to individuals holding a valid CDL or a P, S or H endorsement issued before the compliance date of the final rule. The rule also does not cover individuals for whom states have waived the CDL skills test under 49 CFR 383.

What Is The Compliance Date?

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The compliance date of the ELDT rule is February 7, 2020. Individuals who obtain a commercial learner’s permit (CLP) on or after February 7, 2020 will have to satisfy the applicable requirements. Individuals who obtain a CLP before February 7, 2020 are not required to comply with the new ELDT rule as long as they obtain the CDL or endorsement before the CLP (or renewed CLP) expires.

Is There A Mandatory Order in Which the Training Must Be Administered?

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There is no mandatory order in which the theory, BTW-range, and BTW-public road training must be administered. Also, the rule does not require that theory training must be completed before obtaining a CLP.

Can Theory And BTW Training Be Provided By Separate Training Providers?

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Theory and BTW training may be delivered by separate training providers, as long as each provider is listed on FMCSA’s TPR. Both providers must submit driver-specific training certification information (i.e., proof of training) to FMCSA.

However, driver trainees must receive both the range and public road portions of the BTW training from the same provider.

What Impact Does The ELDT Final Rule Have On Existing State Entry-Level Driver Training Requirements?

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States will be allowed to keep their own entry-level driver training requirements that exceed the new federal minimum standards. However, the final rule does not prohibit driver-trainees from obtaining training outside their state of domicile. Therefore, any entry-level driver training requirements that may exist in the licensing state would not be applicable to the driver-trainee who obtained skills training outside that state, even if the he or she returns to the licensing state to take the skills test.


THEORY (KNOWLEDGE TRAINING)

What Is The Minimum Number Of Theory Instruction Hours Required?

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There is no minimum number of hours that driver-trainees must spend on the theory instruction.

What Areas/Topics Must Be Covered In The Class A Or Class B CDL Theory Training?

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The five areas of theory instruction and the training topics for Class A or Class B CDL applicants are:

1. Basic Operation

  • Orientation
  • Control Systems/Dashboard
  • Pre-Trip and Post-Trip Inspections
  • Basic Control
  • Shifting/Operating Transmissions
  • Backing and Docking
  • Coupling and Uncoupling (Class A only)

2. Safe Operating Procedures

  • Visual Search
  • Communication
  • Distracted Driving
  • Speed Management
  • Space Management
  • Night Operation
  • Extreme Driving Conditions

3. Advanced Operating Procedures

  • Hazard Perception
  • Skid Control/Recovery, Jackknifing, and Other Emergencies
  • Railroad-Highway Grade Crossings

4. Vehicle Systems and Reporting Malfunctions

  • Identification and Diagnosis of Malfunctions
  • Roadside Inspections
  • Maintenance

5. Non-Driving Activities

  • Handling and Documenting Cargo*
  • Environmental Compliance Issues*
  • Hours-of-Service Requirements
  • Fatigue and Wellness Awareness
  • Post-Crash Procedures*
  • External Communications*
  • Whistleblower/Coercion*
  • Trip Planning*
  • Drugs/Alcohol*
  • Medical Requirements*

* On March 5, 2019, the FMCSA amended the level of theory training for individuals who are upgrading from a Class B to Class A CDL by removing eight topics within the area of “Non-Driving Activities.” However, Class B CDL holders upgrading to a Class A CDL are free to choose to complete the Class A theory instruction standard curriculum. This amended rule applies only to Class B CDL holders. Individuals obtaining a Class A CDL who do not already hold a Class B CDL must complete the full Class A theory standard curriculum.

What Topics Must Be Covered In The Theory Training To Obtain A Passenger (P) Endorsement?

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The Passenger (P) endorsement theory training must, at a minimum, contain the following:

  • Post-Crash Procedures
  • Other Emergency Procedures
  • Vehicle Orientation
  • Pre-Trip, En Route, and Post-Trip Inspection
  • Fueling
  • Idling
  • Baggage and/or Cargo Management
  • Passenger Safety Awareness Briefing
  • Passenger Management
  • Americans with Disabilities Act (ADA) Compliance
  • Hours of Service (HOS) Requirements
  • Safety Belt Safety
  • Distracted Driving
  • Railroad (RR)-Highway Grade Crossings and Drawbridges
  • Weigh Stations
  • Security and Crime
  • Roadside Inspections
  • Penalties and Fines

What Topics Must Be Covered In The Theory Training For A School Bus (S) Endorsement?

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The School Bus (S) endorsement theory training must, at a minimum, contain the following:

  • Danger Zones and Use of Mirrors
  • Loading and Unloading
  • Vehicle Orientation
  • Post-Crash Procedures
  • Emergency Exit and Evacuation
  • Railroad-Highway Grade Crossings
  • Student Management
  • Special Safety Considerations
  • Pre- and Post-Trip Inspections
  • School Bus Security
  • Route and Stop Reviews

What Topics Must Be Covered In The Theory Training To Obtain A Hazardous Materials (H) Endorsement?

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The Hazardous Materials (H) endorsement theory training must, at a minimum, contain the following:

  • Basic Introductory Hazardous Materials Requirements
  • Operational Hazardous Materials Requirements
  • Reporting Hazardous Materials Crashes and Releases
  • Tunnels and Railroad-Highway Grade Crossing Requirements
  • Loading and Unloading Hazardous Materials
  • Hazardous Materials on Passenger Vehicles
  • Bulk Packages
  • Operating Emergency Equipment
  • Emergency Response Procedures
  • Engine (Fueling)
  • Tire Check
  • Routes and Route Planning
  • Hazardous Materials Safety Permits

What Is The Minimum Score Driver-Trainees Must Achieve On the Theory Assessment?

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The rule requires that driver-trainees demonstrate their understanding of the material by achieving an overall minimum score of 80% on the theory assessment (written or electronic).


BEHIND-THE-WHEEL TRAINING (RANGE AND PUBLIC ROAD)

What Is The Minimum Number Of BTW Instruction Hours Required?

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There is no minimum number of hours that driver-trainees must spend on the BTW (range and public road) elements of the Class A, Class B, or P or S endorsement instruction. (Please note: California has enacted legislation that requires CDL applicants 15 hours of behind-the-wheel training, with ten of those 15 hours being on a public road.)

In What Class of CMV Must The BTW Training Be Conducted?

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All BTW training must be conducted in the class of commercial motor vehicle in which the trainee intends to use for their CDL skills test. The rule does not permit BTW training to be conducted by using a driving simulation device, and a driver-trainee may not use a simulation device to demonstrate proficiency. However, simulators may be used in theory training.

What Topics Must Be Covered In The Class A Or Class B CDL BTW Training?

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The instructor must cover all training topics listed in the Class A Or Class B CDL BTW curriculum, which includes:

1. Range

  • Vehicle Inspection Pre Trip/En Route/Post Trip
  • Straight Line Backing
  • Alley Dock Backing (45/90 Degree)
  • Off-Set Backing
  • Parallel Parking Blind Side
  • Parallel Parking Sight Side
  • Coupling and Uncoupling (Class A only)

2. Public Road

  • Vehicle Controls including: Left Turns, Right Turns, Lane Changes, Curves at Highway Speeds, and Entry and Exit on the Interstate or Controlled Access Highway
  • Shifting/Transmission
  • Communications/Signaling
  • Visual Search
  • Speed and Space Management
  • Safe Driver Behavior
  • Hours-of-Service (HOS) Requirements
  • Hazard Perception**
  • Railroad-Highway Grade Crossing**
  • Night Operation**
  • Extreme Driving Conditions**
  • Skid Control/Recovery, Jackknifing, and Other Emergencies**

**These topics must be discussed during public road training, but not necessarily performed. Driver-trainees are not required to demonstrate proficiency in these skills.

The instructor must engage in active two-way communication with driver-trainees during all active BTW public road training sessions.

A driver-trainee’s proficiency is determined by the instructor providing the training. The instructor must also document the total number of clock hours each driver-trainee spends to complete the BTW curriculum.

What Topics Must Be Covered In The BTW Training For A Passenger (P) Endorsement?

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The passenger endorsement BTW training must, at a minimum, contain the following:

  • Vehicle Orientation
  • Pre-Trip, En Route, and Post-Trip Inspection
  • Baggage and/or Cargo Management
  • Passenger Safety Awareness Briefing
  • Passenger Management
  • Railroad-Highway Grade Crossings

Passenger endorsement BTW training may take place on a driving range or a public road. The instructor must engage in active communication with the driver-trainees during all BTW training sessions.

A driver-trainee’s proficiency is determined by the instructor providing the training. The instructor must also document the total number of clock hours each driver-trainee spends to complete the BTW curriculum.

What Topics Must Be Covered In The BTW Training For A School Bus Endorsement?

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The school bus endorsement BTW training must, at a minimum, contain the following:

  • Danger Zones and Use of Mirrors
  • Loading and Unloading
  • Emergency Exit and Evacuation
  • Special Safety Considerations
  • Pre- and Post-Trip Inspections
  • Railroad-Highway Grade Crossings

School bus endorsement BTW training may take place on a driving range or a public road. The instructor must engage in active communication with the driver-trainees during all BTW training sessions.

A driver-trainee’s proficiency is determined by the instructor providing the training. The instructor must also document the total number of clock hours each driver-trainee spends to complete the BTW curriculum.


COMPLETION OF TRAINING

What Happens When A CDL Applicant Completes The Training?

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After an individual completes the training, the provider must, by midnight of the second business day after the driver-trainee completes the training, electronically transmit the ELDT certification to the TPR website. As soon as FMCSA confirms the ELDT certification information is complete, the Agency will electronically transmit it through CDLIS to the State Driver Licensing Agency (SDLA) for entry onto the driver's record. Then, SDLAs will simply need to confirm, by checking the applicant's driver record, that they have completed the required ELDT before allowing the individual to take the applicable skill test(s) or, in the case of the H endorsement, the knowledge test.


TRAINING PROVIDER REGISTRY

What Entities Are Included in The Training Provider Registry?

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The TPR will include all entities (including public and private CDL training schools, educational institutions, rural electric cooperatives, motor carriers, state/local governments, school districts, joint labor management programs, owner-operators, etc.) that register with FMCSA and self-certify they meet the curriculum, instructor and facility requirements for providing CDL training. Eligible providers may provide training either on a “for-hire” or “not-for-hire” basis.

FMCSA emphasizes, however, that merely because a training provider is listed on the TPR does not mean that the Agency certifies or otherwise “approves” that provider’s operations. Therefore, prospective entry-level drivers are encouraged to perform their own due diligence before selecting a suitable training provider.

What Are The Minimum Qualifications For An Entity To Be Eligible For Listing On The TPR?

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The rule establishes the minimum qualifications for an entity to be eligible for listing on the TPR. At a minimum, training providers must offer and teach a training curriculum that meets all FMCSA standards for entry-level drivers and must also meet requirements related to:

  • Course administration
  • Qualifications for instructional personnel
  • Assessments
  • Issuance of training certificates
  • Training vehicles (i.e., equipment)

Training providers that meet these requirements would be eligible for listing on the TPR and must continue to meet the eligibility requirements in order to stay listed on the TPR. Training providers must also attest that they meet the specified requirements, and in the event of an FMCSA audit or investigation of the provider, must supply documentary evidence to verify their compliance.

FMCSA emphasizes that merely because a training provider is listed on the TPR does not mean that the Agency certifies or otherwise “approves” that provider’s operations. As such, prospective entry-level drivers are encouraged to perform their own due diligence before selecting a suitable training provider.

When Will The Training Provider Registry (TPR) Be Operable? 

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The TPR will officially be operable by February 2020. The TPR will not be functional before that date to accept certification of individual student's training, etc.

Training providers will be able to register for the TPR prior to this February 2020 date, however, the date for registering has not yet been determined.

USEFUL ELDT RESOURCES

QUESTIONS?

For further assistance regarding the ELDT final rule, please contact us online at Lancer SafetyLink Hotline or call 800-664-7222.