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Webinar Q&A: “Breaking Down The FMCSA's Upcoming ELDT Mandate”

Did you have a chance to attend our recent webinar, “Breaking Down The FMCSA's Upcoming ELDT Mandate”? We received more questions than we had time to answer in the allotted time, so our presenter, Brandon Wiseman, Owner and President, Trucksafe Consulting, answered them below in this Q&A-style blog post.

If you weren’t able to join the webinar live, don’t worry – you can watch it on-demand anytime!

 


Question: If I go through driving school after February 7th, 2022, and am currently working somewhere that requires a Hazmat, am I able to go get one or is there additional schooling required?

Answer: If you obtain the hazmat endorsement after February 7th, you will have to obtain the theory portion of the training to be eligible to take the knowledge test to obtain that endorsement. 

Question: Will the previous Entry Level Driver Training protocols that require carriers to train drivers with less than 1 year of experience no longer be required in lieu of this new program?

Answer: Correct. Once the new training requirement takes effect on February 7th, the burden will shift from carriers to CDL drivers themselves, meaning carriers will no longer have an obligation to provide entry-level driver training to drivers. 

Question: Does the ELDT rule only apply to entry level drivers or to all CTDs in general, regardless of experience and years worked?

Answer: The rule applies to drivers seeking to obtain a Class A or B CDL for the first time, those seeking to upgrade a Class B to Class A CDL, and those seeking to obtain a passenger (P), school bus (S), or hazmat (H) endorsement February 7th or after.  

Question: If we have an employee who will be obtaining their CDL after February 7th, 2022, do they need to do the ELDT before or after they get their CLP?

Answer: They can do so either before or after they obtain their CLP. However, if they obtain their CLP prior to February 7th, then they won’t have to take the ELDT even if their skills test is scheduled to take place after that date, so long as they don’t need to renew their CLP after that date. 

Question: Can the theory component be all computerized?

Answer: Yes, the theory component can be given online, so long as it is provided by someone who meets the minimum “instructor” qualification standards. 

Question: If a person has a CLP prior to the training date and schedules their state road test after the February 7th date, will there be any issues with them taking the test?

Answer: So long as they hold the CLP prior to February 7th, they should be able to obtain their CDL without taking the ELDT even if their skills test is scheduled for after that date. This assumes they won’t have to renew their CLP after that date. 

Question: Is the DMV training book enough to fulfill the theory portion for hazmat endorsement?

Answer: No. Those seeking a hazmat endorsement will need to obtain theory training from someone listed on the FMCSA’s Training Provider Registry and complete that training to the provider’s satisfaction before being eligible to obtain the hazmat endorsement. 

Question: Will there be a standard certificate that we will have to send to the FMCSA upon the completion of training?

Answer: There is no standard form for the certificate itself; however, training providers will be required to transmit certain information (e.g., driver name, license number, etc.) to the Training Provider Registry upon a student’s successful completion of the training.

Question: What about theory training that is provided through video services? Do you still need to have had a valid CDL?

Answer: Yes, theory-based training provided online will either need to be produced or delivered by someone who meets the minimum instructor qualifications (e.g. holding a valid CDL of the same or higher class for 2 years). 

Question: If an Instructor has CDL-A for 6 years but only Hazmat Endorsement for 1 year or less can they still train for CDL-A with Hazmat Endorsement?

Answer: The rule requires that hazmat instructors meet the following requirements: 

  1. Hold a CDL of the same (or higher) class, and with all endorsements necessary, to operate the commercial motor vehicle (CMV) for which training is to be provided.
  2. Meet all applicable State qualification requirements for CMV instructors. (Exception: This is not required if providing theory instruction exclusively.)
  3. Meet one of these:
    1. Have a minimum of two years’ experience operating a CMV requiring a CDL of the same (or higher) class, or the same endorsement; or
    2. Have previously held a CDL of the same (or higher) class; or
    3. Have a minimum of two years’ experience as a BTW CMV instructor.

Thus, it appears that an instructor who currently holds a Class A CDL with a hazmat endorsement would only be eligible to provide hazmat-specific training if he/she has at least 2 years of experience operating a CMV that required a hazmat endorsement or 2 years of experience as a BTW CMV instructor. 

Question: Does the instructor providing theory training for the hazmat endorsement-only have to hold a current Hazmat endorsement?

Answer: No, the rule allows an individual to qualify as an instructor as long as he/she has held a CDL with the required endorsements (and has met the 2 year operating or instructor requirement) in the past. See 49 CFR 380.605.

Question: We are an online only driver training software provider that carriers use as part of their driver training programs, we do have a small number of large carrier clients that have driving schools and would use some of our curriculum for that purpose. Would our course creators be exempt from holding a valid CDL as an instructor requirement?

Answer: If you are only providing training materials and not seeking to be listed on the Training Provider Registry, then your instructors would not have to meet the instructor qualifications. However, in this case, your customers would need to be listed on the Registry as training providers in their own right and would have to have qualified instructors provide the training materials to their students. 

Question: If I use a certified third-party for theory training (JJ Keller, Vertical Alliance, etc), do I, as the trainer pressing "play" on the video, or performing the in-person training, have to have a CDL? I've received mixed answers.

Answer: Someone in this relationship needs to be listed on the Training Provider Registry and meet the minimum instructor qualifications. It can be either the entity that produced the materials or that delivers them to students. So, if you are not intending to have qualified instructors deliver the materials to your students, then you need to ensure the entity that provided the materials is listed on the Registry and that the materials were produced by someone who meets the minimum instructor qualifications. 

Question: If you offer online training on theory, you won't have to meet state requirements for BTW training?

Answer:  Correct. 

 


Stay up to date on CDL trucking trends! Be sure to check out the DriverReach blog for other relevant articles and head over to our webinars page for an up-to-date list of upcoming events and on-demand recordings.

Interested in seeing DriverReach’s modern Recruiting and Compliance Management System in action? Request a demo!

Also, see more from Trucksafe Consulting here!

 

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