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To comply with the ELDT regulations, drivers seeking a Class A or Class B commercial driver's license (CDL), a passenger (P) endorsement, or a school bus (S) endorsement must successfully complete applicable entry-level driver training (theory and behind-the-wheel (BTW) instruction) from a training provider listed on FMCSA’s Training Provider Registry (TPR) before taking the State-administered skills test(s). A driver seeking the hazardous materials (H) endorsement must successfully complete entry-level driver training (theory only) prior to taking the State-administered knowledge test. The State must not administer the test(s) until verifying that the applicant has completed the required entry-level driver training. The ELDT regulations also impose minimum qualification standards for training providers and instructors conducting entry-level driver training.

As discussed in the preamble to the final rule establishing ELDT requirements (81 FR 88732 (Dec. 5, 2016)), FMCSA’s ELDT regulations establish minimum training standards for entry-level drivers. The CDL regulations do not directly preempt State law. Accordingly, the Federal ELDT requirements generally do not replace or otherwise supersede State-based ELDT requirements that exceed the minimum Federal standards for entry-level drivers. A State may also impose more stringent qualification requirements for training providers and training instructors conducting entry-level driver training in that State. FMCSA noted in the preamble to the 2016 final rule that questions would likely arise concerning the relationship between Federal and State ELDT requirements and the Agency would provide post-rule guidance as necessary. Answers to frequently asked questions are set forth below.

Can a CDL applicant domiciled in State A receive entry-level driver training (BTW range and public road) and pass the skills test in State B?

Yes. In accordance with 49 CFR 383.79(a), if a driver domiciled in State A obtains training in State B and passes the skills test administered by State B, State A must accept the skills test results from State B in fulfillment of the driver’s skills testing requirement and of State A’s skills testing administration requirement.

An applicant for a Class B CDL with school bus (S) and passenger (P) endorsements, domiciled in State A, obtains entry-level driver training (BTW range and public road) for Class B and S and P endorsements and passes the skills test in State B. Can State A require the applicant to meet additional standards to obtain the S endorsement?.

Yes. For example, some States require drivers seeking the S endorsement to obtain a State-issued certification related to the operation of school buses, which may include, for example, requirements for completion of a CPR or first aid course, a minimum number of BTW training hours in a school bus, a minimum number of classroom training hours, or specified training topics that exceed the ELDT curricula requirements.

Even if the driver obtained skills training in another State (the training State) and passed the S endorsement skills test in that State, nothing in the ELDT regulations prohibits the State of domicile from requiring the driver to obtain a State-based certification for school bus drivers as a condition of receiving a CDL with the S endorsement, or meeting other requirements as a condition of receiving a CDL. In accordance with § 383.79(a), the State of domicile cannot require the driver to re-take skills tests successfully completed in the training State.

An applicant, domiciled in State A, completes BTW training and passes the skills test in State B. State A accepts the skills test results from State B, but has a State law requiring applicants to complete a minimum number of BTW training hours in order to obtain a CDL (the ELDT regulations do not impose a required minimum number of BTW hours). Can State A impose additional BTW requirements as a condition of receiving a CDL in that State?.

Yes. The State of domicile may require the applicant to meet State-based requirements, such as a minimum number of BTW training hours, prior to receiving a CDL or a P, S, or H endorsement, even if the applicant obtained ELDT in another State and passed the skills test in that State. In accordance with § 383.79(a), the State of domicile cannot require the driver to re-take skills tests successfully completed in the training State.

The ELDT regulations require BTW instructors to meet certain qualification requirements, such as having at least 2 years of experience driving a CMV for which ELDT is to be provided or 2 years of experience as a BTW training instructor. Can a State require ELDT instructors to have more than 2 years of relevant experience or more than 2 years of training experience?

Yes. The ELDT qualification requirements for instructors are minimum standards. As set forth in the definitions of “theory instructor” and “behind-the-wheel (BTW) instructor” in § 380.605, instructors must comply with State-based instructor qualification requirements. A State may therefore impose more stringent qualification requirements on instructors who provide ELDT in that State, except for online theory instructors; this exception is set forth in the definition of “theory instructor” in § 380.605.

The ELDT regulations require training providers to follow a curriculum meeting the applicable criteria set forth in 49 CFR part 380, Appendices A-E. Can a State require a training provider to offer additional training topics or impose other additional requirements on the provider?.

Yes. As provided in § 380.703(a)(5)(i), training providers must comply with additional requirements imposed by a State in which the provider offers entry-level driver training.

Last Updated : February 07, 2022

The regulations do not impose a penalty on the driver if the training provider fails to comply with the two-day reporting requirement. However, the driver may not take the applicable skills or knowledge test until the training provider has submitted the driver’s certification information to the Training Provider Registry, and the information is accessed by the licensing State.

The purpose of the two-day reporting requirement is to ensure the driver’s certification information is available to the State Driver Licensing Agencies (SDLAs) promptly, so that drivers do not experience a delay in taking their skills or knowledge test once they have ELDT. Training providers who routinely fail to comply with the requirement, may be subject to removal from the Training Provider Registry, in accordance with § 380.721(a)(1).

Last Updated : February 07, 2022

Training providers listed on the Training Provider Registry are the only entities that can provide training required by the entry-level driver training (ELDT regulations). To comply with the ELDT regulations, drivers must select a training provider from those listed in the Training Provider Registry.

Last Updated : February 07, 2022

Yes. As part of the self-certification process for listing on the Training Provider Registry, training providers must attest, under penalties of perjury, that they comply with the requirements set forth in 49 CFR part 380, subpart G. As part of this attestation, providers must confirm their compliance with applicable State-based requirements in order to be eligible for initial and continued listing on the Training Provider Registry.

Last Updated : May 20, 2020

No, individual instructors that are hired by registered training providers do not need to register in the Training Provider Registry. Additionally, training providers do not need to provide the names of their instructors when registering. However, if an individual instructor operates as a training provider (i.e., develops their own curricula, secures facilities and equipment, etc.), then the individual is required to register as a training provider and self-certify that they meet the requirements established in 49 CFR 380.703. Further, if an individual instructor also intends to act as a training provider in more than one State, they would need to register in each State where training is provided and self-certify that they meet applicable State or local requirements.

Last Updated : February 07, 2022

Training schools, educational institutions, rural electric cooperatives, motor carriers, State and local governments, school districts, joint labor-management programs, owner-operators, and individuals may be listed on the Training Provider Registry. Eligible providers may provide training either on a “for-hire” or “not-for-hire” basis. Any training provider meeting the eligibility requirements could be qualified to provide entry-level driver training, regardless of whether they fall within a category specifically identified in the regulations.

Last Updated : February 07, 2022

The following requirements are established in 49 CFR 380.605.

Theory instructors must:

  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.

Behind-the-Wheel (BTW) instructors must:

  1. Hold a CDL of the same (or higher) class, and with all endorsements necessary, to operate the CMV for which training is to be provided.
  2. Meet all applicable State qualification requirements for CMV instructors.
  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 a minimum of two years’ experience as a BTW CMV instructor.

Last Updated : February 07, 2022

No. “Live” instructors used by registered training providers may use video training aids as part of the classroom instruction without verifying that the developer or instructor of the video training tool is qualified within the meaning of 49 CFR 380.605.

On the other hand, if the entire theory curriculum is presented via online training, online providers must ensure that the training content is delivered and/or prepared by theory instructors meeting the definition of “theory instructor” set forth in 49 CFR 380.605, as discussed in the ELDT final rule [81 FR 88732, 88779, Dec. 8, 2016].

Last Updated : June 08, 2021

Yes. Under 49 CFR § 380.723(b), the Federal Motor Carrier Safety Administration (FMCSA) may initiate the process for removing a training provider by issuing a notice of proposed removal from the Training Provider Registry, setting forth the reasons for the proposed removal and any corrective actions necessary for the provider to remain listed on the Training Provider Registry. Training providers who receive a notice of proposed removal can continue to conduct training during the period in which they are undertaking the necessary corrective actions, which is generally 60 days. However, regulations require that providers who receive a notice of proposed removal must inform driver-trainees currently enrolled in training, as well as those scheduled for future training, of the proposed removal.

FMCSA will also indicate on the Training Provider Registry when it has issued a notice of proposed removal to the training provider. The Agency will remove that notation from the Training Provider Registry if it withdraws the notice. If FMCSA subsequently removes the provider from the Training Provider Registry because it did not respond to the notice of proposed removal within 30 days, or because it did not complete the required corrective actions, any training conducted after the date of removal from the Training Provider Registry is invalid.

Last Updated : February 07, 2022

To be eligible for listing on the Training Provider Registry, an entity must meet the following requirements set forth in 49 CFR § 380.703:

  • Follow a curriculum that meets the applicable criteria in Appendices A-E of Part 380;
  • Utilize facilities meeting the criteria in § 380.709;
  • Utilize vehicles meeting the criteria in § 380.711;
  • Utilize instructors meeting the criteria in § 380.713;
  • Meet recordkeeping requirements in § 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 providers must attest that they meet the specified requirements. In the event of a Federal Motor Carrier Safety Administration (FMCSA) audit or investigation of the provider, they must supply documentary evidence to verify their compliance. Training providers must continue to meet the eligibility requirements in order to stay listed on the Training Provider Registry.

Last Updated : May 22, 2020

Failure to meet State-based requirements, or falsely stating that the provider meets State-based requirements, could result in the training provider’s removal from the Training Provider Registry.

Last Updated : May 20, 2020

No. The entry-level driver training (ELDT) regulations do not require that training providers be accredited by a third-party organization as a condition of eligibility for listing on the Training Provider Registry.

Last Updated : May 20, 2020

The contents of these frequently asked questions do not have the force and effect of law and are not meant to bind the public in any way. The documents are intended only to provide clarity to the public regarding existing requirements under the law or agency policies.