ELDT: Answers to Your Questions

Though the entry-level driver training (ELDT) rule has been in place for a few years now, there are still many questions when it comes to compliance. Here are the top five we’ve recently fielded.

Endorsements?

Question 1: One of my drivers will be hauling a placardable amount of hazmat in a box truck that’s under 26,000 pounds. I was told the driver will need a Class C CDL and a hazmat endorsement. But I don’t see anything about ELDT for a Class C CDL. Is ELDT required?

Answer 1: A Class C CDL is required when operating a vehicle that does not meet the definition of a Class A or Class B vehicle but is transporting either hazardous materials or passengers in a quantity or number that require a hazmat or passenger endorsement. The Class C CDL is not included in the ELDT requirements (only Class A and Class B), but the driver must complete hazmat endorsement ELDT as outlined in Appendix E to Part 380.

This endorsement-specific course of theory instruction covers 13 topics. Instruction must be conducted by a school or entity listed on the Federal Motor Carrier Safety Administration’s (FMCSA) Training Provider Registry (TPR). Behind-the-wheel instruction is not included in the hazmat endorsement ELDT requirements.

Question 2: I have a driver who needs to add a tanker endorsement to an existing Class A CDL. I can’t find anything addressing ELDT requirements for tank endorsements. Is ELDT required?

Answer 2: No, ELDT is not required in this scenario. Though some endorsements (passenger, school bus, and hazmat) are specified in the ELDT regulations, the tank endorsement is not mentioned.

Training documentation?

Question 3: Is a carrier required to ask for and maintain documentation that a driver has completed ELDT?

Answer 3: No, as of February 7, 2022, the entry-level driver's CDL serves as proof of successful completion of ELDT.

Refresher training?

Question 4: Will a driver who successfully completes ELDT need refresher or follow-up ELDT at some point?

Answer 4: No, the ELDT rule doesn’t require refresher or follow-up instruction. ELDT is a one-time requirement.

Question 5: I just hired a new driver for a driving position with my company. The driver previously had a CDL, last valid about 5 years ago. The driver wants to reinstate the CDL. Will the driver need to complete ELDT prior to obtaining the CDL? Or is the driver exempt from ELDT because the driver previously held a CDL?

Answer 5: ELDT applies to all interstate and intrastate drivers obtaining an initial Class A or Class B CDL. Because the regulation applies to drivers obtaining an initial CDL, the regulation does not require ELDT for a driver who previously held a valid CDL.

With that said, some states are requiring ELDT for lapsed CDLs as part of state policy. You’ll need to consult with the state driver licensing agency that previously issued the driver's CDL for specifics.