BY HOLLIE REEDY, ENNIS BRITTON, CO., L.P.A.
Across the nation, the requirements of the long-delayed Entry-Level Driver Training (ELDT) will go into effect on February 7, 2022. After that date, no driver will be allowed to test with the BMV to obtain a CDL license unless they have a certificate on file from Federal Motor Carrier Safety Administration (FMCSA) noting successful completion of the ELDT curriculum offered by a registered training provider (RTP).
This requirement applies to any new driver wishing to obtain their Class A or B CDL for the first time, and to any veteran driver wishing to upgrade their CDL, or add an endorsement to their CDL, such as a passenger (P), school bus (S) or hazardous materials (H) for the first time. ELDT training is in addition to any state-level training requirements, such as the ODE requirement that school bus drivers complete pre-service training through an ODE preservice provider.
ODE requested an exemption from the nationwide ELDT requirements dated Thursday, November 18, 2021. Ohio noted that its request that the preservice training requirements meet or exceed the ELDT requirements. Comments were being accepted until December 21, 2021, and it is likely that the FMCSA will evaluate and determine whether to grant or deny the exemption in January 2021.
If the exemption is granted, then, as they say, we have no problem. Bus drivers would be trained through Ohio’s preservice program and meet the ELDT requirements at the same time. If the exemption is granted, but with conditions, ODE will have to conform its preservice training curriculum to include anything needed to meet the ELDT curriculum. This would still be a “no problem” situation.
However, if the exemption request is not granted, and the FMCSA makes that determination late in January, then the requirements are still going to go into effect on February 7, 2022. This could cause additional delays in getting new school bus drivers certified and on the road during a time when school districts are already experiencing a serious bus driver shortage as school districts try to ensure their driver candidates complete Ohio preservice training and then complete their ELDT requirements from an RTP.
What should your career-technical school district do to be ready in the event Ohio’s exemption request is not granted? Having a “plan B” will include accessing the list on FMCSA.gov to find RTP’s that your bus driver candidates may use to complete the required curriculum if needed. There are at least 185 registered training providers now, and more will become registered soon.
Any school may become a registered training provider on the FMCSA website, including a career-technical school, which already may offer driver training programs for CDL operation. Each entity that registers to become a training provider for ELDT certifies that it will offer the elements of the federal curriculum, ensure that driver trainers are qualified and certify that its CDL driver candidates successfully completed the curriculum. Successful completion means an 80% or above on the written (theory) portion of the test, and demonstrated proficiency on discrete maneuvers to the satisfaction of the training instructor.
The federal rules and regulations do not specify a length of time the curriculum: instead, drivers must demonstrate proficiency at each portion, which the RTP must certify. (FMCSA does state that it would expect the OTR portion of the training to be around 15 hours for a Class B CDL.)
Speaking of the curriculum, the federal rules and regulations set out generally what the curriculum must contain, and is not an actual packaged curriculum. It is up to the RTP to develop a curriculum meeting federal requirements. RTP’s may choose to offer only the theory portion of the curriculum or the OTR portion of the training. The OTR portion includes both the range skills and also the public road training.
In Ohio, CDL bus driver candidates complete the written portion of their skills test to obtain a CDL learner’s permit. After February 7, 2022, the Ohio BMV will not schedule a license test until a bus driver candidate has completed all the EDLT training requirements.
Action steps, for now, include staying informed about developments, developing a plan B to get driver candidates certified if Ohio’s request for an exemption is not granted, and potentially exploring whether adding an ELDT driver training component to career-tech programs by becoming a registered training provider is something to consider.