Entry-Level Driver Training and Government Entities: The Top 3 Questions

Jill Schultz, Sr. Editor - Transportation Safety 

February 28, 2022

There is an exception to the majority of the Federal Motor Carrier Safety Regulations (FMCSRs) for transportation performed by the federal government, state government, or a political subdivision of a state (§390.3(f)(2)).

Under this exception, compliance with topics, such as driver qualification (DQ) files, medical cards, hours of service, and vehicle inspection/maintenance is not required for transportation performed by a governmental entity.

While there are many areas that the exception addresses, drivers who perform this type of transportation are required to comply with the commercial driver’s license (CDL) requirements (Part 383) and the drug and alcohol testing requirements (Part 382).

And, as of February 7, 2022, compliance with the entry-level driver training (ELDT) rules is required for those who need to obtain a new Class A or Class B CDL or a new passenger, school bus, or hazmat endorsement. The following are the top three ELDT questions we have received from governmental entities.

1. Training provider

Question: Could someone employed by our city government provide this instruction?

Answer: Yes. The process is exactly the same as it would be for any other school or entity. You must meet all curriculum, instructor, vehicle, and facility requirements to apply to be listed on the Training Provider Registry (TPR). The instructors providing the training must have an appropriate class of CDL, including appropriate endorsement(s). They must also have a minimum of two years of experience:

♦ Driving a CMV requiring the CDL (including appropriate endorsement(s)) – or –

♦ As a behind-the-wheel CMV instructor.

2. Theory instruction

Question: Several of the Class A theory instruction requirements address issues that my drivers will never face while on the job (trip planning, roadside inspections, etc.). Can they skip these theory and/or behind-the-wheel requirements?

Answer: Unfortunately, no. The regulations require uniformity in instruction. All theory and behind-the-wheel requirements must be addressed.

3. Med cards

Question: Do the new requirements mean our CDL holders need to possess a valid medical exam certificate (med card)?

Answer: No. If your drivers currently fall under the government exception and are not required to possess a valid med card, this does not change. Do note though, that they will be required to self-certify as either excepted interstate or excepted intrastate as part of the CDL application process.

Talk with a Compliance Specialist today at 833-982-1236


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