Questions remain about entry-level training, 18 months in

Posted June 13, 2023

Though the entry-level driver training (ELDT) rule is over a year old, questions remain about what’s required.

Drivers must undergo a specific course of training, from a DOT-registered provider, to obtain a Class A or B commercial driver’s license (CDL) or a passenger, school bus, or hazardous materials endorsement. The following are common questions about these requirements.

How long do I have to complete theory and behind-the-wheel instruction?

Theory and behind-the-wheel ELDT must be completed within one year of each other.

Are there exceptions when upgrading from a Class B to Class A CDL?

Yes. There is no exception to the behind-the-wheel (range and road) requirements, but fewer theory (classroom) topics need to be covered. The special “upgrade” curriculum includes 22 topics instead of the 30 topics required for a new Class A. The topics that are not required are:

  • Handling and Documenting Cargo,
  • Environmental Compliance Issues,
  • Post-Crash Procedures,
  • External Communications,
  • Whistleblower/Coercion,
  • Trip Planning,
  • Drugs/Alcohol, and
  • Medical Requirements.

Is training required if I want to remove a restriction from my CDL?

No. Removal of a restriction — such as one that restricts a driver from operating a manual transmission or driving an air-brake-equipped vehicle — does not require the completion of ELDT if the driver maintains the same class of CDL.

I hold a CDL and want to add a passenger endorsement. Do I have to take ELDT?

Yes. Drivers who already hold a valid CDL do not need to complete the CDL curriculum required to obtain a Class A or Class B CDL, but they do need to complete the passenger endorsement curriculum, as outlined in Appendix C to 49 CFR Part 380.

Do I need a CDL to provide hazmat endorsement training?

Yes. Even if you are well-versed in the Hazardous Materials Regulations, if you don’t have a CDL with a hazardous materials endorsement you may not conduct hazmat endorsement ELDT.

I completed the ELDT requirements and passed my skills test in another state but my licensing state says I need additional behind-the-wheel training to get my CDL. Can they do that?

Yes. Your “state of domicile” may require you to meet additional state-based requirements, such as a minimum number of training hours, prior to receiving a CDL or endorsement, even if you passed the skills test in another state (but they cannot require you to re-take the same skills test, per 49 CFR 383.79(a)).

Note that training providers must comply with any additional requirements imposed by the state in which the provider offers ELDT.

If we hire a driver who holds a commercial learner’s permit (CLP), can we still perform in-house training to help them get their CDL and learn to drive our vehicles?

Yes. The ELDT rule does not prohibit motor carriers from performing in-house training. However, such training does not satisfy any of the ELDT requirements unless you are a registered ELDT training provider. The driver must still obtain ELDT from a provider listed on the Training Provider Registry.

Key to remember: Entry-level training requirements are more than a year old, but questions about compliance remain. Do you know what’s required?


J. J. Keller’s online ELDT courses will help you exceed the FMCSA’s mandated theory instruction requirements. These interactive, expert-backed programs are designed to be used in tandem with our student and trainer manuals as part of a thorough program.

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