Jill Schultz | J. J. Keller & Associates, Inc.

Jill Schultz

transportation safety

Jill joined J. J. Keller & Associates, Inc. in 1993 with a background in radio, television, and newspaper reporting. She has been an editor on the Transportation Publishing team since 1995.

As a Transportation Safety Editor, she specializes in both the Federal Motor Carrier Safety Regulations and state intrastate safety regulations, including driver qualification, hours of service, and alcohol and controlled substance regulations.

Jill is editor of the Transportation Safety Answer Manual, Navigating Key Transportation Topics, State & FMCSR Requirements, Transportation Safety Training Advisor Newsletter, Transportation Safety Training Advisor: Driver's Report, Driver's Guide to the FMCSRs, and Entry-Level Driver Training: Obtaining a CDL. Her work has also been published by trade magazines, including Driving Force, Big Rig Owner, NAPFTDS Learning Curve, Heavy Duty Trucking, and Industrial Safety & Hygiene News.

Have a compliance question for Jill? Send it through J. J. Keller's Expert Help feature included with all publications in the Compliance Library.

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Articles written by Jill Schultz

› California to require entry-level driver training

› California meal break exemption granted

› Training Blueprint — Winter driving: Operating in adverse conditions

FAQs answered by Jill Schultz

What types of vehicles require the driver to possess a CDL?

ANSWER:
The CDL classes are as follows (§383.91): Class A: Any combination of vehicles with a gross combination weight rating (GCWR) of 26,001 pounds or more provided the gross vehicle weight rating (GVWR) of the vehicle(s) being towed is more than 10,000 pounds.

Class B: Any single vehicle with a GVWR of 26,001 pounds or more, or any such vehicle towing a vehicle not more than 10,000 pounds GVWR.

Class C: Any single vehicle, or combination of vehicles, that meets neither the definition of Class A nor that of Class B, but that either is:

Designed to transport 16 or more passengers including the driver, or
Used in the transportation of hazardous materials as defined in §383.5.

How do I get an air brake endorsement added to my CDL?

ANSWER:
An air brake endorsement does not exist for drivers who possess a CDL. An air brake restriction is placed on a driver’s CDL if the driver either fails the air brake component of the knowledge test or performs the skills test in a vehicle that is not equipped with a full air brake system. Without a full air brake system, an air brake restriction will be placed on the driver's CDL.

Who is subject to the new entry-level driver training rule (ELDT)?

ANSWER:
As of February 7, 2020, the new ELDT rule applies to anyone:

Applying for his or her first CDL,
Upgrading his or her current CDL (from Class B to Class A), or
Obtaining a new passenger, school bus, or hazmat endorsement

This rule does not apply to individuals who had a valid and current CDL and the appropriate endorsement(s) before February 7, 2020.

I am looking for information on the Training Provider Registry (TPR) that is part of the entry-level driver training rule. I have searched FMCSA's website and other sites and cannot find this registry.

ANSWER:
FMCSA is in the process of developing the TPR. The agency expects it to be available via their website in late 2019.

Where in the FMCSRs is driver training covered? How often do I need to train ― once a quarter, twice a year?

ANSWER:
Section 390.3(e) of the FMCSRs states that drivers and employees must be instructed in and comply with the regulations, but it does not include specifics as to delivery, documentation, frequency, or time. That is left to the motor carrier's discretion.

I would like to know if we are considered interstate or intrastate.

ANSWER:
When determining whether transportation is interstate or intrastate in nature we look at two things; first the actual movement of the driver, vehicle and its contents, and second the intent and movement of the shipment. Interstate commerce includes:

Crossing state lines,
Traveling over the border into and/or from Canada or Mexico, and
Traveling between two places within a state, but the cargo is part of a trip that began or will end in another state or foreign country.

Intrastate commerce includes:

Not crossing state lines,
Not traveling over the border into and/or from Canada or Mexico, and
Traveling between two places within a state, and the cargo is not part of a trip that began or will end in another state or foreign country.

The definitions (interstate commerce and intrastate commerce) are located in §390.5 of the FMCSRs.

We only hire drivers that have their CDL already, but we do “finishing training” with them. Are we going to be impacted by the changes in the entry-level driver training rules?

ANSWER:
Yes you are, but in this situation, the rule change works in your favor. Starting February 7, 2020, you will not have to worry about verifying that someone has provided the driver with entry-level training by getting an entry-level driver training certificate. The new entry-level driver training rules require drivers getting their initial CDLs to complete training at an entity that is on the training provider registry before taking the CDL test. If all you do is “finishing training” for drivers that already have their CDL, you will have no obligations under the new rules.

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