Entry Level Driver Training (ELDT) requirements are scheduled to go into effect on February 7, 2022. While FMCSA maintains that the program will be fully operational, this program is poised to be a larger disaster than the Clearinghouse Program rolled out two years ago. After February 7th, all state’s Department of Motor Vehicles (DMV) will be required to check the Driver Training Registry to verify that any driver wanting a Class A or B CDL or seeking a Hazardous Material, School Bus or Passenger endorsement has completed training with a registered training provider.
ELDT Regulations Went Into Effect February 7, 2022.
Do You Understand the Regulation and Your Responsibility as an Employer?
All other endorsements (tanker, air brakes, etc.) and temporary restricted Class B (fertilizer employee anhydrous tank driver) licenses are not effected by the ELDT mandate.
A huge misunderstanding is that drivers can still take the CDL A or B, school bus, or passenger knowledge test at the DMV BEFORE enrolling with a registered training provider! Yes, an individual can still receive his or her Commercial Learners Permit (CLP), which is valid for one year BEFORE they register or complete theory and behind- the-wheel training from a registered training provider.
All state DMV’s are only required to check the registry prior to the driver performing the skills or road testing for a Class A & B CDL, School Bus and Passenger endorsements. Taking the knowledge test does not require a registry check or any formal training. The actual test given at the DMV will not change or cover any of the additional topics listed in the FMCSA training requirements. This is an important factor to understanding ELDT. The test given at DMV will not change after Feb. 7, 2022.
FMCSA fumbled horribly by not educating the industry that this crucial step can be a part of the process. For a company who wants to train their own drivers, it is beneficial knowing the individual has the capacity to achieve a valid CLP before investing time and resources in training.
Hazardous material endorsement applicants are treated differently as they must complete the theory training from a Registered Training Provider (RTP) prior to the knowledge test at the DMV. The hazardous materials endorsement does not have a driving or skills testing requirement.
What are your options to comply with ELDT?
- Send the driver to a RTP for the full 160 hour course requirement in Illinois.
- Register your company to be a private RTP.
- Have the driver receive theory instruction online and find a BTW to give driving instruction.
- Send your driver to a public RTP in any other state to meet the requirements.
What makes the ELDT requirement so complicated lies in the fact the FMCSA has two sets of rules that training providers must meet, and that is dependent on who and how they are training students. Within the rule the FMCSA states that all training providers must register on the Training Provider Registry (TPR).
FMCSA also allow states to be more restrictive than the federal guidelines for being a training provider, but not less. In Illinois, there are extremely complicated and restrictive rules for anyone providing CDL training for compensation (state funded schools or private instruction companies), but the Illinois laws are silent on private driver training that is not completed with compensation to the training provider.
If your company registers as a private trainer in Illinois, you must follow only the federal rules for training providers, and not the state. Registering to be a training provider requires you to go to https://tpr.fmcsa.dot.gov/ and follow the instructions to register.
You cannot train anyone for compensation, meaning they pay you to train a driver, or a driver pays you to train them, but you can train your own drivers if you have registered and have met the federal guidelines. More on that later.
Also, any registered training provider anywhere in the United States can train a CDL driver for ELDT. The training is not dependent on the instruction occurring in the same state that the driver will take the test. So, a person can receive CDL training online or in another state and still take the driving test in Illinois so long as the training provider they used is registered on the TPR.
So, to interpret the new rules for Illinois-based companies, you (your company) can register with FMCSA to become a private ELDT training provider in Illinois. You will only follow the federal guidelines for training and do not have to follow the state guidelines for CDL schools. The registration is free, and has no cost associated at this point. Also, registering does not include any type of automatic audit process but does require biannual filing requirements. The FMCSA will not be showing up to audit your curriculum or behind-the-wheel trainers randomly based on the fact you registered as a training provider. There is also no requirement that you are required to train any number of drivers within a given time. You could register and never train anyone without any impact.
But, what if you don’t want to provide all the licenses or endorsements that require training? You don’t have to, as you can pick and choose what you register to provide. If you only want to train drivers for hazmat endorsement, then that is all you register for. Don’t need a passenger or school bus endorsement? No problem, don’t register to provide that training. Only want to train for a class B license? Just register to provide that CDL license training for theory and behind-the-wheel (BTW).
Where it starts to get confusing is that you could register to only do the theory instruction, but not the behind-the- wheel (BTW) training. The problem with registering that way is you will have to find another registered training provider to give the BTW training. Unfortunately, there are currently no schools in Illinois that will provide that instruction without providing the curriculum first.
I will encourage you to provide the curriculum and BTW training so long as your BTW and theory trainer (can be the same person) meets the qualifications to train drivers outlined in the federal requirements. All BTW driver trainers must have 2 years experience driving with the credentials they are training and have a valid CDL license with appropriate endorsements for the instruction. Registering to be a training provider requires you to go to https://tpr.fmcsa.dot.gov/ and follow the instructions to register. FMCSA has a tremendous amount of resources for training providers. It is not easy to navigate and I encourage you to click on every available link before you register as a provider.
A large misunderstanding of the ELDT training is the theory instruction has virtually nothing to do with successful operation of the CMV. The theory training is designed to educate the driver on all their responsibilities and applicable rules for operating a commercial motor vehicle. This includes understanding the drug and alcohol testing, Clearinghouse registration, hours of service rules and any specific rules regarding a drivers responsibilities.
What about the curriculum? This is where you will have to dedicate some time and resources to become a training provider. There are some free curricula on the internet, but I cannot verify they are comprehensive for use for Class A & B, Passenger or School Bus endorsement. To find the curriculum topics required to be covered go to: https:// tpr.fmcsa.dot.gov/content/Resources/ELDT-Curriculum- Summary_508.pdf .
Hazardous material training only requires theory instruction. Mid-West Truckers Association’s hazardous materials training module and tests will meet all the requirements of the curriculum so long as it is administered by a trainer that has two years of a hazmat endorsement. You can purchase the video and materials by contacting our office at (217) 525-0310.
Interestingly, there is no time requirement or extensive testing requirement. You only need to verify the required topics were covered and the student has retained the knowledge by scoring at least 80% on your ‘tests’ which can be paper or electronic. There is no mandated format on how detailed or the volume of questions required in each topic area. You can cover theory topics as you deem necessary for the trainee.
There are certain topics that may not be applicable to your operation but you will have to cover them. Topics include hours of service, whistleblower, post accident procedures and the Clearinghouse driver requirements. You will be required to cover only what the trainee needs to understand under the topics as a driver, not what your company has to do. The key to all this is document, document, document each of the theory required topics.
How much time you spend on any part of ELDT training will be dependent on the needs of your company and the ability of the trainee to retain the information. For example, if you operate only in short haul or ag exempt hours-of- service, then it will be important to your company that the trainees understand how they will use those exemptions. Overall, you are going to have to give the driver a basic knowledge of all the topic areas listed, but you will spend more time making sure they understand the exemptions they will be working under, regardless of ELDT. There are a few companies that have created curriculum that you can purchase, but none we can recommend that will meet the needs of every individual company. You may already do this now with new drivers and have much of the required curriculum via your driver onboarding process.
The BTW training has no set time or hour requirement, only that your trainer signs off that they trained and the student can complete the skills outlined. The facilities requirement only state that the area be large and free of obstructions for the trainee to complete the tasks. The BTW training requires that the trainer document the trainees abilities and they can complete the task topics listed.
Once the trainee has completed the required training, you have two business days to upload and update the student’s training progress and for them to complete the skills and driving testing at the DMV.
What about Covered Farm Vehicle (CFV) drivers? If someone is only going to drive a farm-plated vehicle, then they do not have to get a Class A or B CDL. Illinois has a Class A license that is farm designated known as J51. J51 Class A licenses and regular Class B licenses do not have to follow ELDT regulations as they are not a federally administered license. They have no endorsements because endorsements are part of CDL, not state issued licenses. A J51 Class A or Regular B license holder cannot drive any commercial motor vehicle that does not have a farm designated plate. CFV drivers can travel anywhere within the state of Illinois and up to 150 air miles from their base of operation traveling out of state.
If a farmer or any entity becomes a RTP for a Class A or B CDL, they must train the driver on all the topic areas, even if they themselves are exempt. The reason why is that once the driver receives a full CDL, they can drive for anyone, not just a farmer. The same goes for a municipality, school or other entity that is exempt from certain FMCSA regulations. They still must train a driver on all the required topic areas as a registered training provider.
Rest assured, the FMCSA and state DMV’s will make ELDT requirements a bigger mess as it goes into effect. Just remember to reach out to MTA for information, not the DMV. We have more issues with DMV employees and locations giving out incorrect CDL driver information to drivers than any other topic.
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