Do city and county employees need ELDT for a CDL?
Why public employers are not exempt
Transportation performed by a state, a city, a county or other political subdivision is generally excepted from the Federal Motor Carrier Safety Regulations (49 CFR 390.3(f)(2)). But 49 CFR 383.3(b) says those exceptions do not apply to the CDL rules, and that the employers and drivers they cover must still follow Part 383. ELDT is part of getting a CDL, so it comes with it.
The same is true of DOT drug and alcohol testing in Part 382: a public employer with CDL drivers still tests them.
Who on your crew needs ELDT
- A new hire or current employee getting a Class A or Class B CDL for the first time.
- A Class B driver upgrading to Class A.
- A CDL holder adding a Passenger (P), School Bus (S) or HAZMAT (H) endorsement for the first time.
Drivers who already held that CDL class or endorsement before February 7, 2022 do not need ELDT for it. Our page Do I need ELDT? walks through the edge cases.
The exemptions that actually exist
FMCSA says drivers who are excepted from the CDL rules are also excepted from ELDT. For public employers, that means:
- Military drivers. Every state must exempt people operating CMVs for military purposes: active duty, reserves, National Guard on active duty (including part-time training), dual-status military technicians and active duty Coast Guard. Veterans who get the military skills test waiver also skip ELDT. See ELDT for veterans.
- Firefighting and emergency vehicles. A state may exempt drivers of vehicles with audible and visual signals used to preserve life or property, such as fire trucks and ambulances.
- Snow and ice removal. A state may exempt local government employees who plow, sand or salt inside their own jurisdiction, but only when the regular licensed operator cannot drive or the employer decides a snow or ice emergency needs extra help.
The state options are state by state
The firefighter, emergency vehicle and snow removal exemptions are options. Each state decides whether to use them, and an exemption a state grants is only good in that state unless neighboring states agree to honor it. Many states also have their own firefighter license rules. Before you assume a crew is exempt, check with your state DMV.
The snow and ice exemption is not a blanket pass for plow drivers. A driver whose regular job is running a plow truck that requires a CDL still needs the CDL, and so still needs ELDT.
Behind-the-wheel is a separate piece
ELDT for Class A and B has two parts: theory, and behind-the-wheel training on a range and on public roads. Both must come from providers on the FMCSA Training Provider Registry. Many departments run behind-the-wheel training in their own trucks and register as a provider for it, then buy theory online. Our guide on theory vs behind-the-wheel explains the split.
How a department buys the theory
ELDT365 is registered on the FMCSA Training Provider Registry for Class A, Class B, B to A upgrade, HAZMAT, Passenger and School Bus theory. Class B theory is $20 per driver, and every completion is filed the same day the driver passes. Put a card on the account, buy seat codes, or get an invoice for your purchase order. Details for agencies are on our fleets page.
Questions drivers ask
Are public school bus drivers exempt from ELDT?
No. Public school bus operations are excepted from most FMCSA rules, but not from the CDL rules. A driver getting a first Passenger or School Bus endorsement needs ELDT for each one.
Does a county driver who got a CDL in 2019 need ELDT now?
No. A CDL class or endorsement issued before February 7, 2022 is not subject to ELDT. The driver only needs ELDT for a new class or a new P, S or H endorsement.
Does our department need to register on the Training Provider Registry?
Only if your department delivers part of the training itself, such as behind-the-wheel in your own trucks. If you buy theory from a registered provider, the provider files it and you do not register for that part.
Are volunteer firefighters exempt?
It depends on your state. Federal rules let each state choose whether to exempt drivers of firefighting and emergency vehicles from the CDL. If your state exempts them, ELDT does not apply. Check with your state DMV.
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