This article was originally posted in the Minnesota Trucking Association’s “Trucking Minnesota”. It has been modified to address changes and current understandings to the regulation
The creation of the ELDT is another step in the process of standardizing Commercial Vehicle Driver training. The standardization of training really started in 1985 when Model Curriculum was proposed and created as a template for states to use which documented the Knowledge needed to drive a commercial vehicle. The ELDT regulations take a major step forward in that starting February 7, 2020, all persons wishing to obtain a CDL (Class B or A) for the first time, upgrade their CDL, or add certain endorsements to their license for the first time (Hazardous, Passenger, School Bus, and/or Longer Commercial Vehicles – Doubles/Triples), must attend training at a provider that is registered with the FMCSA, certifying that the training provider meets a long list of requirements and standards. For CDL training and Hazmat endorsements, the training providers must certify the driver-trainees have properly passed all aspects of training before taking either their skills (road) test for CDL or their Hazardous Materials Endorsement written exam.
The ELDT rules were created through the use of negotiated rulemaking. This is a process involving a government entity and stakeholders who work together to reach consensus on the text and/or major concepts of a proposed rule. These stakeholders included representatives from motor carrier transportation, highway safety, driver training, state licensing, law enforcement, labor unions, and insurance. This committee worked from February to May of 2015 to create the proposed rule. The proposed rule created by this committee and the final rule, which was published on December 8th, 2016 were very similar to each other with one major difference. The proposed rule established minimum hours for Behind the Wheel (BTW) training which was not included in the final rule.
The ELDT regulations include curriculum standards for both Theory (Knowledge) and BTW training. The BTW portion is divided into both Range and Public Road requirements. It also includes requirements for Facilities, Vehicles, Instructors, and Record Keeping. There are separate but similar curriculum standards for obtaining your Class B and Class A license for the first time (Class B training does not include topics like Coupling and Uncoupling, or the jackknifing portion of skid control). There was, however, an amendment to the regulations which was published on March 6th, 2019 which stated that those individuals upgrading their license from a Class B to a Class A license did not need to receive the same level of training as those obtaining their license for the first time (although all topics still needed to be covered).
The Theory (Knowledge) curriculum for a person obtaining their CDL is divided into 5 categories with specific topics listed in each category. Assessments must be made of these topics and students must pass with a combined score of at least 80%. There is no minimum number of hours the training must take, but all topics must be covered and documented. Below are the Theory categories and required topics to be covered for the Class A curriculum:
- Basic Operation – Orientation; Control Systems/Dashboard; Pre/Post-Trip Inspections; Basic Control; Shifting/Operating Transmissions; Backing and Docking; and Coupling and Uncoupling.
- Safe Operating Procedures – Visual Search; Communication (i.e. horn, turn signals, etc.); Distracted Driving; Speed and Space Management; Night Operations; and Extreme Driving.
- Advance Operating Procedures – Hazard Perception; Skid Control/Recovery, Jackknifing, and Other Emergencies; and Railroad-highway Grade Crossings.
- Vehicle Systems and Reporting Malfunctions – Identification and Diagnosis of Malfunctions; Roadside Inspections; and Maintenance.
- 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; and Medical Requirements.
BTW training is the hands-on aspect of what was taught in the Theory portion of the training. For BTW training, there is no required minimum number of instruction hours, but all topics must be covered. BTW training must be conducted in a CMV for the Class of license the student is trying to obtain. The instructor must determine and document that each driver-trainee has demonstrated proficiency in all elements of the BTW curriculum, and must separately document the number of clock hours spent on both the Range and Public Road. Also of note, a simulation device cannot be used to conduct BTW training or to demonstrate proficiency (It can be included as Theory training, but doesn’t count toward any BTW time). As with Theory curriculum, the Class A and Class B BTW training is virtually identical with the exception of the Class of vehicle being used and the fact that coupling/uncoupling are not covered in the Class B training.
For BTW Range training, driver trainees must demonstrate proficiency in: Vehicle Inspection (Pre-Trip/In-route/Post-Trip); Straight Line, Alley Dock, and Off-Set Backing; Parallel Parking (both blind and sight side); and Coupling and Uncoupling (not included in Class B BTW Range training). Backing maneuvers should include training on Get Out And Look (GOAL).
BTW Public Road training must have the driver-trainee demonstrate proficiency in the following areas which are very similar to the Theory portion of the training (items with a “*” in front of them only need to be discussed while performing BTW Public Road training and not actually demonstrated): Vehicle Controls Including: Left, Right, Lane Changes, Curves at Highway Speeds, and Entry/Exit on Interstate or Controlled Access Highways; Shifting/Transmission; Communication/Signaling; Visual Search; Speed and Space Management; Safe Driver Behavior; Hours of Service Requirements; *Hazard Perception; *Railroad-Highway Grade Crossing; *Night Operation; *Extreme Driving Conditions; and *Skid Control/Recovery, Jackknifing, and Other Emergencies.
There are additional Theory and BTW requirements that the registered training provider must provide for Entry Level Drivers seeking to add Passenger and/or School Bus endorsements to their license for the first time. Many of these are duplicates of the Theory and BTW training already listed, but add in specific items related to passenger vehicles such as (not a complete list): passenger evacuation training, medical emergencies, ground clearances, restrooms and associated environmental requirements, abandoned luggage, fueling, Idling, Baggage Management, Passenger Safety Briefings, ADA Compliance, and Loading and Unloading of Passengers.
For drivers wishing to add a Hazardous Materials Endorsement to their license for the first time, they must attend training at a registered training provider that covers 13 areas of Theory instruction. These include: Basic Introductory HM Requirements; Operational HM Requirements; Reporting HM Crashes and Releases; Tunnels and Railroad-Highway Grade Crossing Requirements; Loading and Unloading HM; HM on Passenger Vehicles; Bulk Packages; Operating Emergency Equipment; Emergency Response Procedures; Fueling procedures; Tire Checks; Routes and Route Planning; and HM Safety Permits.
The regulations for training Facilities and Equipment are rather succinct, yet far reaching. The area for the range must be free of obstructions, enable the driver to maneuver safely and free from interference from other vehicles and hazards, and have adequate sight lines. The range must comply with all applicable Federal, State, and/or Local statutes and regulations, and the vehicles must be in the same group and type that the driver-trainee intends to operate for their CDL skills test.
Instructor requirements are also included in the Regulations. Theory and BTW Road Instructors must hold a CDL equal to or higher than the class of vehicle used in training (including any necessary endorsements) and have at least 2 years of driving experience or 2 years of CMV training experience. BTW Range instructors do not need to currently hold a CDL, but they must meet the other requirements listed above. All instructors must also meet any/all state requirements for CMV instructors. There are also regulations and restrictions related to if an Instructor has had a suspended, cancelled, or revoked license.
Record Keeping is another item addressed in the regulations. Record of Self-Certification that accepted applicants will adhere to parts 40, 382, 383, and 391 of the DOT regulations; copies of driver-trainee CLP and/or CDL (as applicable); Instructor qualification documentation; Training Provider Registration Form; lesson plans for theory and BTW training curricula, and records of individual entry-level driver training assessments all need to be retained for a minimum of 3 years unless required by a particular state to be for a longer period.
Please remember, this is just a summary all of the information and requirements of the regulations. For more information and in-depth descriptions of the various topics discussed, a person would have to look to the actual regulations. They are found in part 380 of the FMCSRs. Specifically, in Subparts F and G from 380.600 through 380.725 including Appendixes A-E.