FMCSA has made it crystal clear: despite a partial delay with the Training Provider Registry (TPR), ELDT will go into effect as planned on Feb. 7, 2020.
This news should dash any lingering hopes among CDL schools of extending the deadline and focus attention back where it belongs: on getting ready for ELDT. The task might seem daunting, but the consequences of putting it off are even worse. Noncompliant schools could face fines and possible closure while prospective CDL applicants who took training from those schools won’t be allowed to test for their CDL.
Here are 10 really good reasons to get started on ELDT now.
1. Your Instructors May Not Be Qualified Anymore.
According to FMCSA, 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, 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.
2. Document, Document, Document!
It’s not enough to be fully compliant by the deadline. When applying to become an approved training provider through the TPR (which also needs to happen by Feb. 7, 2020), CDL schools need to self-certify that they meet all ELDT requirements and, crucially, have documentation in place to back it up.
The application process for CDL schools looks like this:
- Submit an electronic application to the TPR to become an approved training provider.
- Self-certify that they meet all ELDT requirements.
- Affirm, under penalty of perjury, that they will only teach the prescribed ELDT curriculum.
- In the event of an audit, they must supply documentation proving ELDT compliance.
3. Federal Funding Could Be at Stake.
Many public community colleges offer CDL training. Because ELDT is a federal regulation, these schools risk losing federal funding if their CDL programs aren’t ready for ELDT in time. Also, as part of the Nationally Association of Publicly Funded Truck Driving Schools (NAPFTDS) Code of Ethics, schools must "ensure that educational and business practices are in observance to applicable laws, regulations and accrediting standards."
Most colleges plan their curriculum months in advance, so depending on your school’s specific schedule and curriculum planning process, you might need to be ready even sooner.
4. Longer Completion Times Will Be the New Normal.
Currently, training requirements for CDLs are set by the states, and they vary widely. In some states, trainees can go from starting training to testing for their CDL in as little as a couple of weeks. All that changes when ELDT goes into effect. The industry predicts that ELDT’s robust new curriculum requirements could add at least a week to CDL trainees’ completion time.
Are all of your school’s systems, budgets, processes, staff and schedules ready to absorb that extra week? What about the expectations you set in your marketing materials and recruitment practices? If the answer is anything but a confident “Yes!”, you’ve got work to do.
5. Two Words: Curriculum. Audit.
Speaking of that robust new curriculum, what’s your plan to audit all your existing curriculum and bring it into compliance?
The curriculum requirements have two parts: a theory portion and a behind-the-wheel (BTW) portion. The theory portion consists of 30+ federally-mandated areas such as speed management, hazard perception, roadside inspections and distracted driving. Trainees must pass a written or online test at 80% or better to demonstrate proficiency.
The BTW portion is further divided into range training and public road training, with specific instruction requirements for each. It's up to instructors to assess driver-trainee BTW proficiency, and it's a bit of a gray area. Without clear guidance from DOT, your school needs to show that you're assessing students and instructors consistently.
6. Scantrons, Scores and Systems, Oh My!
Under ELDT, CDL schools must administer written or online tests on the theory portion of the curriculum, and trainees must score 80% or better before they’re allowed to sit for their CDL. DMVs are still responsible for testing CDL applicants’ BTW and inspection skills.
Schools must also keep track of trainee test scores independently until the TPR is fully implemented (after which time they’ll need to pass that information to the TPR). We don’t know exactly how schools will be required to share this information with FMCSA and/or local DMVs in the meantime; we’re monitoring the situation and will post an update as soon as we learn more.
7. Record-Keeping. All the Record-Keeping.
Test scores aren’t the only thing CDL schools are required to track. For every trainee at your school, you’ll need a system in place to record and share all of the following with FMCSA:
- Contact information
- Copy of commercial learning permit
- Hours spent in BTW training
- Certificate upon completion
8. Better Recruiting and Job Placement
Despite (or perhaps because of) the driver shortage, trucking companies are frequently disappointed with the quality and training of the drivers they hire. By adopting ELDT standards sooner, you show fleets that your school produces better-trained drivers, thereby improving your school’s reputation, your trainees’ chances of job placement, and your ability to recruit new trainees to your program.
But don’t take our word for it. Tim Blum, executive director of the Professional Truck Driver Institute, stated as much in a recent Heavy Duty Trucking article. “Trucking companies can benefit from sources that graduate drivers who meet the standards,” he says. To that end, he encourages fleets to urge CDL schools “to adapt and meet the new requirements sooner rather than later.”
9. Don't Get Stuck at the Back of the Line.
There’s a limited number of vendors equipped to help you become ELDT-compliant. As the Feb. 7 deadline approaches, they’re going to get busier and busier assisting their existing clients and closing deals in their pipeline.
Wait too long to reach out, and you might not find anyone with the bandwidth to help you become fully compliant in time to meet the deadline.
10. ELDT Is Going to Be a Lot of Extra Work.
Yes, even more than you think it will be, for all the reasons listed above and more. But now that we’ve got you good and scared, we also have a solution: On Ramp Entry-Level Driver Training.
On Ramp takes the work of developing a compliant curriculum, administering and scoring tests, recording and storing all required data, and (eventually) integrating with the TPR off your plate.
You also save time and money with online training, which can help you make up for some of the lost efficiency from longer student completion times. Prefer classroom training so you can add context to the video? We have a Group Training mode for that, and it also includes testing!
Still Have Questions? Join Our Webinar to Hear from an FMCSA Guest Speaker
If you still aren’t sure what the delay means or what you need to do before February 7, 2020, join our upcoming webinar, ELDT 101: What CDL Schools Need to Know.
We’ll have guest speakers from FMCSA, CVTA, and the Blue Ridge Community College CDL program to educate you about ELDT and answer your questions.