Entry-Level Driver Training (ELDT) is coming in 2022, along with a slew of new rules and regulations. If you train entry-level truckers, now is the time to start preparing for the new law. Which you’re totally doing – right?
We get it — any new government regulation is complicated and confusing, especially with a name like “49 CFR 380.503.” Not to worry – we’ve been on this since the start and have sat on the panel making recommendations to the rule-making body.
We talk regularly with the experts at the Commercial Vehicle Training Association (CVTA) and translated into plain English the Department of Transportation (DOT) ELDT frequently asked questions to give you your one-stop guide you’ve been looking for.
What is ELDT and Who is Affected?
In layman’s terms, the federal government (specifically, the DOT) ruled that if you want to get a commercial driver’s license (CDL), you must first undergo training that meets certain federally mandated standards.
Training must be delivered by a qualified instructor and from an approved training provider (i.e. a CDL school, local trade group, community college, etc.). Federal ELDT requirements don’t supersede or replace any state-level requirements that exceed these minimum standards.
The ELDT ruling applies to:
- Anyone seeking a CDL for the first time
- Anyone seeking to upgrade their CDL (i.e. from Class B to Class A) for the first time
- Anyone seeking a hazardous material (H), passenger (P) or school bus (S) endorsement for the first time
|ELDT At A Glance|
|Current Rules||After ELDT Takes Effect|
|CDL training and testing standards are determined by the states||Sets new federal minimum standards for CDL schools|
|Any organization that meets state requirements can be a training provider||Establishes new Training Provider Registry* that CDL schools must apply to join|
|Training standards vary widely from state to state||Standardizes 31 theory course topics and 19 behind-the-wheel skills|
|CDL schools must record hours spent behind-the-wheel, but no federal minimum|
|DMVs are responsible for testing behind-the-wheel and inspections skills. There is no written test requirement.||CDL schools must administer written test and share student scores with DOT. Students must score 80% or higher to pass.|
|Behind-the-wheel and inspection skills still tested at state DMV|
|No minimum requirements for instructors||Mandates new minimum qualifications for instructors|
|*The TPR is not live, nor has guidance been provided for the application process.|
When Does ELDT Go into Effect?
ELDT goes into full effect as of February 7, 2022.
Why is ELDT Important?
Before ELDT, CDL training requirements were set by states and varied widely. As a result, many new drivers are ill-equipped to deal with situations encountered on the road. The consequences can be devastating.
ELDT will help ensure that new drivers are adequately trained before hitting the road for the first time, making the roads safer for everyone, leaving the potential to avoid trucking’s retention problem. New drivers will be easier to hire because there will be more consistency in their training. Time and resources required to train prospective CDL drivers will increase significantly, making early CDL school preparation critical.
What’s the Process to Become an Approved Training Provider?
As we mentioned above, only approved training providers are authorized to deliver ELDT. To become an approved training provider, you must apply to be listed in the DOT’s yet-to-be-built Training Provider Registry (TPR), otherwise known as a database of all approved training providers in the country.
While the TPR hasn’t been built yet, we’re closely monitoring the situation and will continue to post updates as we learn more.
Here’s What We Know So Far
It’s a common misconception that ELDT only applies to CDL schools. This isn’t true. Any company that trains entry-level people to get their CDL for the first time is subject to ELDT, including private fleets. For-profit CDL schools, non-profit community colleges, local trade organizations, private fleets running dock-to-driver programs and over-the-road fleets with their own internal CDL schools are all examples of organizations that must apply to the registry.
The DOT states that training providers will be able to apply to the TPR prior to ELDT’s February 2022 start date. We aren’t sure as of right now as to when that application process will open.
The Process of Becoming an Approved Training Provider
Becoming an approved training provider requires:
- Submitting an electronic application to the Training Provider Registry
- Self-certification that they meet all ELDT requirements
- Affirming, under penalty of perjury, that they will only teach the prescribed ELDT curriculum
- Documentation proving ELDT compliance in the event of an audit
Once a training provider has been accepted to the TPR, they’ll be assigned a unique training provider ID number, which will appear on a driver-trainee’s record in the Commercial Driver’s License Information System.
In theory, local DMV employees will be able to look up a CDL applicant’s record and use the unique training provider ID number to confirm the applicant’s requisite training completion. This part is theoretical since the government’s TPR backbone of the enforcement system doesn’t exist yet.
Individual instructors are not required to register with the TPR. Instead, it’s up to training providers to vet instructors and ensure they meet all necessary requirements.
What Does “Qualified Instructor” Mean?
According to the DOT, all ELDT instructors must meet the following qualifications:
- Hold a CDL of the same (or higher) class as the commercial vehicle for which they’re providing training
- Have at least 2 years’ experience driving a commercial vehicle of that class or have at least 2 years’ experience as a behind the wheel instructor for commercial vehicles.
Since rules aren’t complicated enough already, there are two exceptions:
- A theory instructor is not required to hold a current CDL if the instructor previously held a CDL of the same (or higher) class and meets all other qualifications
- If a behind the wheel instructor provides training solely on a range that is not a public road, a current CDL is not required if the instructor previously held a CDL of the same (or higher) class and meets all other qualifications.
It’s important to note that these requirements are in addition to any state-level requirements for CDL instruction.
What are ELDT Training Requirements?
The actual training is broken up into two portions: theory and a behind the wheel. Driver-trainees must demonstrate proficiency in both theory and behind the wheel training portions. The training must be delivered by a qualified instructor that meets the above outlined requirements.
Let’s take it one step at a time.
ELDT Theory Portion
To meet ELDT requirements, CDL schools must educate driver-trainees in the following 30+ curriculum areas prescribed by the DOT:
|Designation||Visual Search||Speed Management||Post-Crash Procedures|
|Control Systems/ Dashboard||Jackknifing & Other Emergencies||Handling & Documenting Cargo||Hours of Service Requirements|
|Pre & Post-Trip Inspections||Railroad-Highway Grade Crossings||Environmental Compliance Issues||Fatigue & Wellness Awareness|
|Basic Control||Distracted Driving||Trip Planning||Roadside Inspections|
|Medical Requirements||Extreme Driving Conditions||Whistleblower/ Coercion||External Communications|
|Backing & Docking||Night Operation||Hazard Perception||Skid Control/Recovery|
|Coupling & Uncoupling||Identification & Diagnosis of Malfunctions||Shifting/Operating Transmissions||Drugs & Alcohol|
There’s no minimum number of hours driver-trainees need to spend on the theory portion, but they must demonstrate proficiency before taking the CDL test. To demonstrate proficiency, a driver-trainee must score 80 percent or higher on the written or electronic assessment of the theory curriculum.
ELDT Behind the Wheel Portion
The behind the wheel portion is further divided into two sections: range training and public road training, with specific instruction requirements for each. ELDT doesn’t mandate a minimum number of total hours behind the wheel, but CDL schools are required to record the total amount of time students spend behind the wheel. Some states will have time requirements for behind the wheel training.
It’s currently up to instructors to assess driver-trainee proficiency behind the wheel, which begs the question – what exactly does it mean to be “proficient?” Talking to many people in the industry, no one is in love with this vague direction. Without clear guidance from the DOT, your school needs to show you’re assessing students and instructors consistently.
We do know that instructors must assess proficiency in all the following areas, as outlined by the DOT:
Range Training (instructors must teach these activities on a driving range and not public road)
|Pre-, Enroute & Post-Trip Inspections||Alley Dock Backing (45/90 Degree)||Parallel Parking Blind Side||Coupling & Uncoupling
|Straight Line Backing||Off-Set Backing||Parallel Parking Sight Side|
As part of range training, instructors are also required to teach “Get Out and Look” (GOAL) to the driver-trainee for all applicable areas.
Behind the Wheel — Public Road Training (instructors must teach these activities on a public road)
|Vehicle Controls*||Visual Search||Hours of Service (HOS) Requirements||Night Operation**|
|Shifting/Transmission||Speed & Space Management||Hazard Perception**||Extreme Driving Conditions**|
|Communications/ Signaling||Safe Driver Behavior||Railroad (RR)-Highway Grade Crossing**||Skid Control/Recovery, Jackknifing, & Other Emergencies**|
* Including: Left turn, right turn, lane changes, curves at highway speeds as well as entry and Exit on the interstate or controlled access highway
** These skills must be discussed during public road training, but driver-trainees are not required to demonstrate proficiency in them.
Both range and public road behind the wheel training must take place in a vehicle that represents the CDL class or endorsement being sought instead of a simulator. This is not to be confused with the fact that simulators can be used in the theory portion. If the driver-trainee is seeking a Class A license, their behind the wheel training has to take place in a Class A commercial vehicle.
How will ELDT Compliance Be Enforced?
We don’t exactly know. What we do know is that the local DMV will be referencing the TPR as students get their tests. Students who haven’t demonstrated proficiency or who took training from noncompliant schools won’t be able to test at all for the CDL.
The DOT plans to compare the driving records of those who received different amounts of behind the wheel training to see if there’s a correlation between hours of training and safety outcomes. This could potentially lead to future minimum behind the wheel hour requirements.
Why You Should Care About ELDT
Do you like safe roads and fewer incidents? That’s reason enough for you to care about ELDT.
Even beyond the goodness of your heart, there are good reasons to support entry-level drivers. Until ELDT goes into full effect, many new drivers will still join your fleet without sufficient training. There’s a reason why the safest fleets have an aggressive, frequent training schedule for inexperienced drivers.
Most fleets should also find a higher level of training in their new CDL holders. There are excellent CDL schools out there today, and this new rule should raise the training to that higher standard across the board.
Prepare your Drivers for the Future, Today
Combining best practices with new clarity on the Entry Level Driver Training standards will definitely be a challenge. but it is one the industry can and must accept to prepare drivers for a long and safe career. There may be many shades of grey in adoption of the new ELDT law, but there is ultimately one black-and-white goal: a safe and productive driver.
Did you know SambaSafety offers ELDT with our On Ramp platform? Schedule your demo to learn more today!