Despite much-discussed technical issues that many hoped would delay the Entry-Level Driver Training (ELDT) rule, the new law will take effect as planned on February 7, 2020.
FMCSA has been very clear about this. In our recent ELDT 101 webinar, Rich Clemente from the FMCSA stated that the new entry-level driver requirements will go into effect on schedule. Yet there are still holdouts who’d prefer to watch and wait.
So I’ll be blunt: the time for watching and waiting is over. ELDT is really, truly coming, and your window for getting ready is shrinking. Fast. With the holidays and start-of-year planning just weeks away, you need to act ASAP or risk incurring steep noncompliance fines when February rolls around.
These are the five steps you need to take this fall to get ready for ELDT (the sooner the better):
1. First, Educate Yourself.
The amount of information out there can feel overwhelming, so we’ve pulled together just the essentials of what you need to know.
- A Plain-English Guide to ELDT - Written in plain English as opposed to government-speak, this handy guide covers all the basics of ELDT: what the law is, who it applies to, and all the requirements you’ll need to comply.
- Everything You Need to Know About the Proposed ELDT Delay - This article covers the partial ELDT delay, what it affects, and what you still need to do by February 7, 2020 (spoiler: pretty much everything).
- Webinar: ELDT 101 - We brought in a guest speaker from FMCSA, along with a CDL school and the head of the Commercial Vehicle Training Association, to walk you through ELDT and answer the biggest questions we’ve heard about the law.
2. Review Your Instructor Qualifications.
To comply with ELDT, all instructors who train entry-level drivers must meet the following qualifications:
- Hold a CDL of the same (or higher) class as the commercial vehicle for which they're providing training, and
- Have at least 2 years experience driving a commercial vehicle of that class, or have at least 2 years experience as a BTW instructor for commercial vehicles.
There’s a good chance your current instructors meet those qualifications already, but you’ll want to make sure. If they don’t, you’ll need time to bring them up to speed – up to 2 years, depending on which qualifications they lack – and/or maybe hire new instructors to fill the gap.
3. Plan for Longer Completion Times.
The industry predicts that ELDT’s robust new curriculum requirements could add at least a week to CDL trainees’ completion time.
Evaluate all of your school’s systems, budgets, processes, staff and schedules to make sure they’re ready to absorb that extra week. You may also need to adjust the expectations you set in your marketing materials and recruitment practices.
One possible way to mitigate this is with a high-quality online training program for the theory portion of ELDT. Multiple studies have shown that students tend to learn faster and retain more information with online training vs. traditional classroom training. In practice, this means you could deliver more effective ELDT theory training in less time with online training.
4. Gather Your Documentation.
Before February 7, 2020, all schools, private fleets, public organizations and other entities that train entry-level drivers will need to apply to become an approved training provider via the Training Provider Registry (TPR).
The application process looks like this:
- Submit an electronic application to the TPR to become an approved training provider.
- Self-certify that you meet all ELDT requirements.
- Affirm, under penalty of perjury, that you will only teach the prescribed ELDT curriculum.
- In the event of an audit, you must supply documentation proving ELDT compliance.
The TPR is still being built, but start getting your documentation together now so you’re ready to apply as soon as the TPR is live. Crucially, this will also make it easier to prove compliance in the event of an audit.
5. Create an ELDT-compliant Curriculum, Implement a Testing Plan, and Build a Database to Keep Track of All Your Records (Or Get ITI’S On Ramp™ to Do It for You).
When it comes to ELDT compliance, there’s no reason to reinvent the wheel. On Ramp takes the work of developing a compliant curriculum with the 31 required courses, administering and scoring tests, recording and storing all required data, and (eventually) integrating with the TPR off your plate.
Using On Ramp is faster, easier and most likely cheaper than trying to comply with ELDT on your own.
And for those few skeptics out there who still doubt that ELDT will ever really happen, consider this: sooner or later, you will have to prove your ELDT compliance to the DOT and your state DMV. Better to invest a little time and money preparing now, rather than spend the same time and money later, plus huge penalties.
To modify one of our favorite expressions at ITI, the best time to get ready for ELDT was six months ago. The second best time is now.