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).
~ Department of Transportation Enforcement
"Tell me about your training program. What are you doing to make sure your drivers are complying with the rules and regulations?"