Let’s not do what we usually do
Whenever there’s a new rule, the industry panics. It usually sets in during the final weeks before the new rule goes into full effect. At that point, everyone is trying to figure out how to comply, and some people realize there is a lot to be done, and no time to do it.
Someone will inevitably appeal to the Federal Motor Carrier Safety Administration (FMCSA) for a delay. Why? Because the industry and/or vendors that support the industry are not ready for the change. Many times, the delay is granted.
This cycle — everyone panicking and then expecting a delay to be granted — has led to some in the industry believing that “it’s not really going to happen.” When it does, these people are in shock and literally have no idea what to do next.
This happens no matter how long we, as an industry, have had to prepare for the change. In most cases, we have had years to prepare for an impending change.
Latest case in point
The FMCSA has stated repeatedly (as in over, and over, and over) in the last few months that the new entry-level driver training (ELDT) requirements are going to go into effect as scheduled on February 7, 2022. As the preparation for this rule is extensive, carriers that do ELDT need to be getting ready now. This means:
- Deciding you want to continue doing ELDT (based on a cost/risk/benefit analysis);
- Documenting your classroom, range, and road curriculum;
- Comparing your curriculum to the requirements in Part 380;
- Making sure your facilities (classroom and range) meet any state or local requirements;
- Making sure the equipment you want to use for training meets the federal and state requirements;
- Selecting qualified instructors;
- Training your instructors;
- Knowing and complying with any state requirements for your type of operation; and
- Registering with the FMCSA’s Training Provider Registry.
Getting ready does not mean running around asking everyone, “Are they seriously going to do this?” and hoping it is delayed.