DOT Driver Training Requirements

"Tell me about your training program. What are you doing to make sure your drivers are complying with the rules and regulations?"

This is one of the first questions enforcement asks when conducting an audit or investigation at a motor carrier's facility.

So why is enforcement asking this question so early in an audit or investigation? There are only a handful of required driver training topics in the Federal Motor Carrier Safety Regulations (FMCSRs). The few specific requirements for a motor carrier that is not hauling hazardous materials apply only to drivers of vehicles that require the driver to possess a commercial driver’s license (CDL) for operation. These training requirements address entry-level driver training, education/instruction on drug and alcohol testing requirements, and longer combination vehicle (LCV) training (if applicable).

The question posed by enforcement relates to a few simple sentences in the FMCSRs. Section 390.3(e) of the FMCSRs states that:

• Every employer must be knowledgeable of and comply with all regulations contained in the FMCSRs that are applicable to that motor carrier’s operations;
• Every driver and employee must be instructed regarding, and must comply with, all applicable regulations contained in the FMCSRs; and
• All motor vehicle equipment and accessories required by the FMCSRs must be maintained in compliance with all applicable performance and design criteria set forth in the FMCSRs.

How does a motor carrier meet these requirements? Unfortunately, there isn't a straightforward answer to this question. The regulation goes no further than what is stated. A motor carrier can work toward meeting these requirements by having a comprehensive training program that includes the required training, as well as training that meets the criteria of Section 390.3(e).