We've said it before, and we'll say it again: ELDT is coming in less than a year, and a slew of new rules and regulations comes with it. If you train entry-level drivers, 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 entry level driver requirements. Not to worry. We've been on this since the start. Our VP of Training Development, Laura McMillan, 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 DOT ELDT FAQs (say that three times fast!) to put together this short, friendly guide to ELDT. And if you're interested in a background on how ELDT came about, we've included an ELDT background article near the bottom.
|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.|
What Is ELDT and Who Is Affected?
ELDT stands for Entry-Level Driver Training. Basically, the federal government (specifically, the DOT) ruled that if you want to get a commercial drivers license (CDL), you must first undergo training that meets certain federally-mandated standards.
Note that federal ELDT requirements don't supersede or replace any state-level requirements that exceed these minimum standards.
The ELDT rule 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 materials (H), passenger (P), or school bus (S) endorsement for the first time.
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.). More on both of those things below.
When Does ELDT Go into Effect?
ELDT goes into full affect on February 7, 2020. That's 11 months from now, in case you're counting.
Why Is ELDT Important?
Before ELDT, training requirements for CDLs were set by states, and they varied widely. This variance means that unfortunately, many new drivers today are ill-equipped to deal with the situations they encounter on the road. The consequences can be devastating.
ELDT will help ensure that new drivers are adequately trained before they hit the road for the first time, which makes the roads safer for everyone. It will also make new drivers easier to hire because there will be more consistency to their training.
It also means that the time and resources required to train prospective CDL holders will increase significantly, which is why early preparation for CDL schools is 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), which will be a database of all approved training providers in the country.
And yes, you read that correctly. 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.
First, 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 claims that training providers will be able to apply to the TPR prior to ELDT's February 2020 start date. We don't know when the application process will open.
To become an approved training provider, training providers must:
- Submit an electronic application to the Training Provider Registry.
- 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.
Once a training provider has been accepted to the TPR, they'll be assigned a unique training provider ID number. This ID number will appear on a driver-trainee's record in the Commercial Driver's License Information System (which already exists).
In theory, local DMV employees will be able to look up a CDL applicant's record and use the unique training provider ID to confirm that the applicant completed the requisite training. This part is, again, theoretical because 11 months before a new rule is supposed to be enforceable, the government's TPR backbone of the enforcement system doesn't exist.
Individual instructors are not required to register with the TPR. It's up to training providers to vet instructors and ensure they meet all necessary requirements.
What Does “Qualified Instructor” Mean?
According to 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, 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.
But because the rules aren't complicated enough already, there are two exceptions:
- A theory instructor is not required to hold a current CDL as long as the instructor previously held a CDL of the same (or higher) class and meets all the other qualifications.
- If a BTW instructor provides training solely on a range that is not a public road, a current CDL is not required as long as the instructor previously held a CDL of the same (or higher) class and meets all the other qualifications.
Note that these requirements are in addition to any state-level requirements for CDL instruction.
What Are the ELDT Training Requirements?
The actual training is broken up into two parts: a theory portion and a behind-the-wheel (BTW) portion. Driver-trainees must demonstrate proficiency in both the BTW and theory portions of the training, and the training must be delivered by a qualified instructor (see above). Let's take it one at a time.
ELDT Theory Portion
To meet ELDT requirements, CDL schools must educate driver-trainees in the following 30+ curriculum areas prescribed by 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 that driver-trainees need to spend on the theory portion, but they must demonstrate proficiency before they can take the CDL test. To demonstrate proficiency, a driver-trainee must score 80% or higher on the written or electronic assessment of the theory curriculum.
ELDT Behind-the-Wheel (BTW) Portion
The BTW 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 schools are required to record the total amount of time students spend behind the wheel. Some states, however, will have time requirements for BTW training.
Currently, it's up to instructors to assess driver-trainee BTW proficiency. We've written before about this grey area of assessment. 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 DOT, your school needs to show you're assessing students and instructors consistently.
We do know that instructors must assess proficiency in all of the following areas, as outlined by DOT:
BTW — Range Training (instructors must teach these activities on a driving range, 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 (essentially, everything, except Coupling & Uncoupling).
BTW — 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 Turns, Lane Changes, Curves at Highway Speeds, & Entry & 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.
Additionally, all BTW training, both range and public road, must take place in a vehicle that represents the CDL class or endorsement being sought, not in a simulator (though simulators can be used in the theory portion). So if the driver-trainee is seeking a Class A license, their BTW training has to take place in a Class A commercial vehicle.
How Will ELDT Compliance Be Enforced?
We don't know exactly, but we do know 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 for the CDL at all.
The DOT plans to compare the driving records of drivers who received different amounts of BTW training to see if there's a correlation between hours of training and safety outcomes, which could lead to minimum BTW hour requirements in the future.
"I'm Not a CDL School, and I Don't Train CDL Students. Why Should I Care about ELDT?"
Do you like safe roads and fewer accidents? Then you should care about ELDT. But even beyond the goodness of your heart, there are good reasons to support your entry-level drivers. Until ELDT goes into full effect, many new drivers will still join your fleet without sufficient training. Our 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 level across the board.
Here's a list of several things you can do right now to support these vulnerable employees. ELDT or not, they're a great way to help your new drivers become successful, long-term employees.
Background on ELDT
This background article on ELDT was written in 2017 from Laura McMillan, ITI's VP of Training Development, who sat on the board of advisors for the FMCSA. It raises many of the issues that continued to be thorny as the FMCSA neared its launch, and ultimately delayed the launch two years.
Adapting to the Variables in the New Entry Level Driver Training Standards
On Dec. 7, the FMCSA formalized new Entry-Level Driver Training rules, capping a faster-than-normal rule-making process. The new standards are much broader and more robust than most within the industry expected and perhaps, even desired.
The Shades of Grey in the Standards
Under the ELDT rules, the industry has until February 2020 (Now February 2022. -ed) to adopt the new training standards. As the case with many federal rulings, it is one law that can be expected to produce many shades of grey as each state seeks to “soften” or “harden” aspects of the ruling to address current and anticipated industry challenges.
Industry challenges such as driver shortages, instructor shortage and long wait times for license examiners are ever-present and show signs of getting worse. Looking beyond the challenges, the industry can find success. But true success will ultimately come from engagement and commitment to the new driver training standards as well as greater instructor qualifications and attention to standards.
How Do Your Instructors Define Proficiency?
The new federal law for training entry-level drivers requires 30 knowledge and skill areas. In an 11th hour decision, FMCSA turned away from a time basis approach to training of key skills. For example, FMCSA abandoned a minimum number of 30 hours for the behind-the-wheel portion of entry-level driver training for fleets. Now it is up to individual instructors and trainers to determine the proficiency of the student driver. Those are instructors employed by your fleet.
Focusing on the student’s proficiency is great, but the fact that proficiency is now defined by individual instructors makes consistency a huge challenge. Even at a well-run CDL school, getting a consistent measure of what “proficiency” means (and ensuring all of a school’s instructors follow those self-imposed standards) will be a big undertaking.
Create Your Own Consistency to Combat the Variables
Alignment of proficiency standards — making sure that every student hits the same benchmarks — usually requires a lot of rigor and effort. Schools must select the right people to be instructors. And they have to provide initial training of the instructors on the standards and definitions of “proficiency.”
Plus, at some point, there should some level of instructor performance review or school audit as a quality control measure. One element that well-run schools should all adopt: A continuing learning program for the instructor. All instructors need to be kept up-to-date on trends in safety and innovative tools like driver simulation.
So if we accept that the instructor is a variable that needs ongoing management, how can a school or fleet ensure consistency when training new CDL students?
Online Courses for Both Instructors and Students
The use of online training for CDL schools can go a long way in achieving consistency. Online course content, which can be used for any or all of the new ELDT law’s 30 knowledge topics, delivers the same message each and every time without variation. And it tests student knowledge without any subjective evaluation. This helps keep the curriculum objective, managing against the substantial level of subjectivity that instructors apply.
Additionally, tests taken online have the added benefit of recording results automatically into what’s called a learning management system (LMS). The LMS is a great way for any training provider to keep thorough and comprehensive records on student progress. Lastly, online lesson content frees up instructor time to put towards valuable hands-on, in-person training that requires the skill and experience of a good teacher. That could be answering questions, driving on the range, or behind-the-wheel time. This makes the training provider both efficient and effective.
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.