As an active player in the trucking, transportation, and logistics industry, you must be aware of your driver training program at all times. You should know what to do to make sure that your drivers are compliant and are totally unaware of the rules and regulations laid down by the department of transportation and the federal motor carrier safety administration. The enforcement officers are also going to ask you the same question. Yes, they would want to know whether you are aware of those regulations or not while they conduct an audit/investigation at your motor carrier’s facility.
You must be aware of the handful of driver training topics laid down by the federal motor carrier safety regulations. Despite them being limited in number, they are quite important. If your driver does not haul any hazardous materials, they will be required to possess a commercial driver’s license at least. This falls under the umbrella of entry-level driver training requirements. It also comprises education or instructions on drug and alcohol testing requirements. If applicable, it would also entail longer combination vehicle training.
According to the FMCSRs, section 390.3(e):
- You, as an employer, should have adequate knowledge about and comply with all the rules and regulations contained in the FMCSRs applicable to the operations of your motor carrier.
- You’ll have to make sure that all your drivers and employees are instructed appropriately and must comply with all the regulations that are applicable to their job positions under the FMCSRs.
- There are certain applicable performance and design criteria that have been defined in the FMCSRs. You’ll have to ensure that all your motor vehicle equipment including all the important accessories are maintained in compliance with those requirements.
- As a motor carrier, you can meet these requirements easily if you have enrolled in a comprehensive driver training program. This should be in compliance with the criteria set under section 390.3(e).
The Required Driver Training In Detail
If as a motor carrier you are not hauling any hazardous materials, you must at least address the entry-level driver requirements in addition to drug and alcohol testing and longer combination vehicles as stated above.
Entry-Level Driver Training Requirements
The entry-level driver training requirements are mentioned under the Part 380 Subpart E of the FMCSRs. This simply applies to all the drivers who have less than 1 year of experience operating a commercial vehicle across inter-state borders requiring a commercial driver license for cross-border commerce. As an entry-level driver, your employees must receive adequate and appropriate instructions in the following areas:
Driver Qualification Requirements
Part 391
These instructions comprise medical examination procedures and medical certification applicable to the specific job. It also comprises general driver qualifications, disqualifications, and their responsibilities.
Hours Of Service
Part 395
These instructions comprise the basic elements with regards to driving and on duty and off duty hours of service. It also comprises the record of duty status which is the log preparation and exceptions to the requirements. Fatigue countermeasures and various means to avoid any mishaps or crashes are also included in these instructions.
Driver Wellness
Drivers are instructed on basic health maintenance such as diet and exercise, use of alcohol and drugs, and similar substances, and their abuse. They are also instructed about stress management and anxiety and hypertension control.
Whistleblower Protection
29 CFR 1978
Under these instructions, any employee is protected against any action that an employer might resort to taking if he questions the safety practices at the workplace. The employee should not have to deal with the fear and risk of losing their job or being subject to reprises for stating any shortcomings in the safety measures being held up by the employer at the workplace.
Upon the completion of this training module, the driver is issued a training certificate or diploma. After this, a copy of the same certification has to be included in the driver’s qualification file or personnel file. The same must be available for audit/inspection whenever it is required by the enforcement officers.
Requirements Relating To Drug And Alcohol Use And Abuse
As a motor carrier/employer, you are required under the FMCSRs section 382.601 to provide your drivers with adequate educational material related to drug and alcohol testing requirements. These reading materials must include 11 essential items. This information addresses several issues such as who will be subject to drug and alcohol regulations in the first place. It is also going to encompass specific information about driver conduct which is prohibited at the workplace and on the road. The procedures used to conduct these tests and the various consequences of any of the drivers failing to complete this alcohol and drug test. The repercussions of positive drug test results and refusal to go through with the test are also explained here.
In addition to this, the employer also has to have strict policies and procedures that address the meeting of these requirements. This training or education module should be completed before the driver is allowed to begin with any of the safety-sensitive functions that they have been assigned.
If any of your company policies, procedures, or regulations are subject to any kind of change, you will have to put your drivers and employees through a re-training program before they join their safety-sensitive positions and that includes driving responsibilities as well. After that, each one of your drivers will be required to sign a statement that will certify that they have received adequate information and reading materials with regards to all of these requirements. The original certificate will be retained by the motor carrier and a copy of the same is always provided to the driver/employees.
Coming To The Longer Combination Vehicles Training Requirements
If you have any drivers that regularly operate longer combination vehicles, for example, doubles or triples, they must be encouraged to participate in and also complete a longer combination vehicle driver training program successfully before they begin with their driver duties. This training module is going to include instructions on various general categories including safe operation practices and behind-the-wheel instructions. The driver aspiring to drive these vehicles should meet these training requirements and also obtain a certificate indicating that they have qualified to operate a longer combination vehicle. The original certificate will be with the motor carrier and a copy of the same will be maintained in the driver’s qualification file.
Understanding Non Required Training
Section 393.3 (E) of the FMCSRs states that all drivers and employees must receive vital instructions along with regulations and they must comply with them in a due manner. However, these instructions do not include any specifics with regards to any documentation or time, or delivery. A motor carrier should never miss out on any of the specific topics mentioned herein because not training their driver can have legal consequences and can result in civil penalties and fines. A lot of statistics and driver-related information will be considered including the history of their prior offenses, degree of culpability, public safety requirements, and other factors when determining these fines and penalties.
What Is Orientation?
In order to maintain a positive driver-carrier relationship, the first aspect that should be given the most amount of importance is driver orientation. Driver training programs are going to vary depending upon the carrier in question. The topics that are included will cover a lot about general company information and their policies and procedures, a review of various drug regulatory requirements, and also behind-the-wheel training. Therefore, driver orientation is more of a company-specific training that should be imparted to the driver upon joining of their safety-sensitive positions with the company.
Hazardous Materials Driver Training
Hazardous materials driver training is usually required by any driver who is responsible for transporting hazardous materials across borders. Whether it is direct or indirect, the transportation of hazardous materials has to be conducted within 90 days of hire. Only then is the driver allowed to do any unsupervised hazmat-related work. The training has to be very specific to what the employee does and should address the major concerns associated with the hazardous materials that are being transported. Hazardous material driver training instructions must include the following:
- Appropriate training on general awareness with relation to hazardous material
- Training aimed at familiarizing the driver with hazmat requirements
- Mission-specific training with relation to the job of the employee
- General safety training that enables them to prevent and deal with any incidents
- Basic security awareness
- Security training for the carrier
- Modal-specific training when hauling hazardous materials
Understanding Reasonable Suspicion Training
These training requirements are applicable to the supervisors who are in charge of the drivers and other employees in your organization. It eventually helps drivers to stay compliant with the rules and regulations laid down by the department of transportation. Under this training, the supervisor will be responsible for recognizing and documenting any signs of drug and alcohol use and misuse among the drivers. They will also be responsible for upholding company procedures and policies while conducting reasonable suspicion training and testing among the drivers.
The supervisor should be trained only once and in case they are not able to use that knowledge and skill to the benefit of the company, they might have to go through a refresher training module.
Driving Skills
All your drivers including the ones that have been working with you for more than a few years and the new entrants should go through a review of their driving skills. Poor driving habits or any incorrect skills that they might have developed over the years should be rectified as soon as possible. You will have to undertake a review of their driving techniques to understand where they are lacking so that any risk of accidents can be avoided. For instance, you should pay attention to their backing procedures and turning and other procedural issues that they might face while driving. Have a look at what their attitude is along with their course of action in adverse weather conditions and bad or low-light situations.
Maintaining Workplace Safety
Workplace safety is also a very vital aspect of dot driver training. This helps them take an active part when it comes to preventing workplace injuries. This training module is going to benefit both the carrier and the driver. There are a few occupational safety and health administration regulations that they must follow especially if your drivers are involved in material handling or working in a warehouse or other kinds of workplaces. They should also be educated and trained in the use of protective equipment such as shields, gloves, protective footwear, and the like. If they are responsible for operating any powered industrial rigs or any loading machinery, they must be made aware of how to operate them safely.
Understanding The Importance Of Implied Training Requirements
According to Part 390-393 and 395, 396, it is implied that driver training is necessary. Let’s have a look at some critical regulatory areas though:
Section 390.3(E)
Every driver and employee should be given adequate instructions and they must comply with all these applicable regulations to stay compliant and operational on the road. The driver must understand the regulations laid down by the federal motor carrier safety administration. However, there is no information about what these instructions should look like and the frequency of these instructions to the drivers.
The two critical areas that you should always be aware of are driver qualification and hours-of-service. These are two very important areas the violation of which can lead to severe consequences for your company. You and your drivers including your employees, associates, and supervisors must understand what these requirements are and how to stay compliant with them always.
Part 391
Under this part, the driver must be in a position to or trained to safely operate any vehicle that has been assigned to them. This should be ascertained by the driver either by the way of training or experience. If the driver lacks relevant experience, it is the duty of the employer to ensure that he receives proper training and is able to operate the vehicle safely before he joins the safety-sensitive position or begins his driving responsibilities.
Final Thoughts
These regulations do not demonstrate how the driver is to be trained or who must provide this training to them. The best way to make sure that your company and your drivers are 100% compliant is to document the training. Make sure that you record the previous experience of the drivers and save the same on their application after having verified it. Also, make sure that all your training modules are correctly documented.
