Entry Level Driver Training (ELDT) April, 2019

ELDT FINAL RULE Entry-level driver training (ELDT) final rule published in 12/8/16 Register [FMCSA-2007-27748]; “Key” date is rule’s compliance date -- February 7, 2020; Individuals who obtain a CLP before February 7, 2020 are not required to comply with the new ELDT rule as long as they obtain the CDL or endorsement before the CLP (or renewed CLP) expires; and Rule does not cover individuals for whom States have waived the CDL skills test under 49 CFR 383.77 (Military Skills Test Waiver).

ELDT RULE REQUIRES Established new training standards for individuals applying for: Class A or B CDL for the first time; A CDL upgrade (e.g., a Class B CDL holder seeking a Class A CDL); or A hazardous materials (H), passenger (P), or school bus (S) endorsement for the first time.

‘B’ to ‘A’ RULE UPDATE In the spring of 2017, Executive Orders 13771 and 13777 directed executive agencies to “manage the costs” and “alleviate unnecessary regulatory burdens placed on the American people”. In accordance with those Presidential directives, FMCSA reviewed the ELDT final rule and is considering revisions to the theory training requirements applicable to CMV drivers already holding a Class B CDL who wish to upgrade to a Class A CDL; and The Class A theory instruction curriculum set forth in the ELDT final rule included 30 instructional units, including 10instructional units related to non‐driving activities. FMCSA is reviewing the 10 instructional units related to non‐driving activities and how to address those questions.

EDLT UPGRADE ‐ Basics FMCSA estimates that Class B CDL holders upgrading to a Class A CDL would, on average, need 24 hours to complete the proposed theory instruction upgrade curriculum. FMCSA estimates the Class A theory instruction curriculum set forth in the ELDT final rule would take 60 hours to complete; FMCSA is working to provide an estimate a time savings that the final rule would provide when an applicant upgrades from a Class B holder to a Class A CDL; and FMCSA is considering what changes might or might not need to be made to BTW training requirements as a results of the public comments.

VERIFYING SUCCESSFUL COMPLETION OF TRAINING FMCSA is considering the viability for training providers to transmit the training certificate electronically for each student to FMCSA via some sort of Training Provider Registry system; and With the implementation of a National Training Provider Registry, FMCSA is aware that there might be the need for SDLAs to modify their IT systems to receive the certificates from FMCSA and to post certain information on the CLP/CDL record.

NO SPECIFIED BTW HOURS The rule does not require any minimum number of BTW hours for the completion of any of the BTW (e.g., Class A, Class B and the P and S endorsements); The proficient completion of the BTW portions of the various curricula is based solely on the training instructor’s assessment of each driver‐trainee’s individual performance of the required elements of BTW training on the range and public road. All BTW training must be conducted in a representative vehicle for the CDL class or endorsement being sought.

CDL APPLICANTS REQUIREMENTS Must complete a prescribed program of instruction presented by an entity listed on the Training Provider Registry (TPR), prior to taking the CDL skills test, or for the H endorsement, prior to the knowledge test; and TPR will include all entities (including public/ private & fleet-operated training programs) that register with FMCSA and self-certify they meet requirements for providing CDL training.

REQUIRED TRAINING FOR ELDT The core and endorsement curricula are subdivided into theory (knowledge) and behind‐the‐wheel (BTW) (range and public road) segments; No minimum number of hours that students must spend on the theory portions of any of the individual curricula; Training provider must provide instruction in all elements of the applicable theory curriculum and driver trainees must receive an overall score of at least 80% on the theory assessment; and Training provider must not issue the training certificate unless the driver‐trainee demonstrates proficiency in performing all required BTW skills.

ELDT CURRICULA Rule includes five separate curricula: Class A CDL; Class B CDL; Hazardous Materials (H) endorsement; Passenger (P) endorsement; and School Bus (S) endorsement

TYPES OF TRAINING Class A & B CDL & endorsement curricula subdivided into theory (knowledge) & behind-the-wheel (BTW) (range/public road) segments; No minimum number of hours that trainees must spend on theory or BTW portion of any curricula; Training provider must provide instruction in all elements of the applicable theory and BTW curricula and trainees must receive an overall score of at least 80% on assessment (written or electronic).

TRP LISTING ELIGIBILITY To be eligible for TPR listing, an entity must: Follow a curriculum that meets the applicable criteria in Appendices A-E of Part 380; Utilize facilities meeting §380.709; Utilize vehicles meeting §380.711; Utilize instructors meeting §380.713; Meet recordkeeping requirements §380.725; Be licensed, certified, registered, or authorized to provide training in accordance with the applicable laws and regulations of any State where in-person training is conducted.

TRAINING PROVIDER REGISTRY (TPR) To be placed on FMCSA’s TPR a person or institution must: Meet the applicable Eligibility Requirements; Complete and submit (online) a Training Provider Identification Report; and Affirm under penalties of perjury that they will teach the prescribed curriculum appropriate for that license or endorsement and that they meet the eligibility requirements.

TRAINING PROVIDER REGISTRY Training providers must transmit electronically the training certification information for each student to FMCSA via the TPR when student completes course; FMCSA will transmit electronically the training certification information to the SDLA as proof the applicant has completed the training prior to taking the CDL skills test, or for the H endorsement, prior to taking the knowledge test; SDLAs must modify their I/T systems to receive the certification information from FMCSA and to post that information on the applicant’s CDLIS driver record.

TRAINING PROVIDERS Theory and BTW training may be delivered by separate providers; Both of these types of providers must be listed on TPR, self-certify that they meet standards for TPR listing; and Both would submit training certification information to FMCSA.

SDLA DATA EXCHANGE REQUIREMENTS At a minimum, these additional data elements will include the training provider’s unique ID# (assigned upon initial listing on the TPR), the date the applicant completed applicable ELDT, and type of training the applicant received (Class A or B CDL, or P, S, or H endorsements); Agency intends to transmit the training certification information as soon we confirm the information is complete.

SDLA DATA EXCHANGE REQUIREMENTS Rule does not require States to separately retain the training certification info; relevant data entered directly onto the driver’s record (CDLIS); Agency will not issue paper training certificates - transmittal of ELDT certification information will be entirely electronic through CDLIS.

TRAINING PROVIDER REGISTRY TPR scheduled to be operable by February, 2020;   Will be implemented in stages prior to the official compliance date, allows training entities to register at a designated time prior to that date; Implementation issue that the Agency will be addressing through subsequent guidance.

FOR MORE INFORMATION Richard Clemente e-Mail: richard.clemente@dot.gov Selden Fritschner e-Mail: Selden.Fritschner@dot.gov