Though compliance with the entry-level driver training (ELDT) rule has been required for almost two years, we still receive many questions on this subject. The following are the top five we have recently fielded.

The hazmat endorsement

Question 1: I have a driver who has a Class A commercial driver’s license (CDL) and wants to add a hazmat endorsement. The driver has already completed the required background check but needs to take the hazmat endorsement knowledge test. Does the driver have to complete Class A and hazmat ELDT? Or is there a specific course the driver needs to take?

Answer 1: A driver who has a current and valid Class A CDL would need to complete hazmat specific ELDT prior to taking the hazmat endorsement knowledge test. The theory instruction (as outlined in Appendix E to Part 380) must be administered and presented by a school or entity listed on the Federal Motor Carrier Safety Administration’s (FMCSA's) Training Provider Registry (TPR).

Question 2: If a driving school is looking to provide hazmat endorsement theory instruction does the instructor need to have a hazmat endorsement?

Answer 2: Yes, a hazmat theory instructor must have the appropriate class of CDL including the hazmat endorsement. The hazmat theory instructor must have a minimum of two years of experience driving a commercial motor vehicle requiring a CDL with a hazmat endorsement.

Behind-the-wheel instruction

Question 3: How many behind the wheel hours are needed before a driver can take the Class A or Class B CDL skills test?

Answer 3: The ELDT requirements do not include a specific number of behind-the-wheel instructional hours. When it comes to behind-the-wheel instruction, all required maneuvers must be successfully completed multiple times. Proficiency is measured by the student's performance and the instructor's professional discretion.

Documentation

Question 4: What type of documentation must be submitted to the FMCSA to show a student successfully completed ELDT? Would a completion certificate with their company name be sufficient?

Answer 4: A school or entity that provides ELDT must be registered on the TPR. The TPR is what an ELDT provider uses to enter a student’s training record (including successful completion of the program).

No documents are uploaded to the TPR. All student information is entered on the TPR via fields and check boxes.

Question 5: I just hired a driver who recently completed ELDT with a driver training school and obtained a Class A CDL. What records do I need to keep showing the driver completed ELDT?

Answer 5: The valid CDL is proof of successful training. No other documentation is needed.

Key to remember: Though the ELDT requirements are almost two years old, questions about compliance remain.