The compliance dates for the CDL Drug & Alcohol Clearinghouse and the Entry-Level Driver Training rules are January and February 2020, respectively. In fact, there’s little doubt these rules will require a significant amount of preparation by the motor carrier industry to ensure understanding and compliance by these dates. A few examples of the preparation happening across the industry:

• Hundreds of thousands of carriers and more than a million CDL drivers will need to register with the Clearinghouse later this year when it becomes operational.
• Starting in early January 2020 (less than 6 months from now), hiring fleets will need to pay a fee to check or “query” the Clearinghouse for information on all CDL driver-applicants to ensure the applicant is qualified to operate.
• Beginning in early February 2020, all truck-driver training schools must ensure their training curriculum meets new federal standards and will need to register with FMCSA’s soon-to-be established training provider registry.
• Under the new training rule, all individuals who want to obtain a CDL (or upgrade an existing class B CDL) will need to select and obtain training only from a provider listed on the provider registry prior to obtaining a CDL.

It’s fair to say these new safety-focused rules will create real challenges for fleets, drivers and training schools alike. It’s also fair to say the government - FMCSA and State CDL licensing agencies - have important roles to play for the safety benefits of the new rules to be realized.

However, despite substantial work on both rules, FMCSA recently communicated its intent to delay the compliance dates of these rules for itself and for the State licensing agencies. For the Clearinghouse, this means FMCSA will be postponing the January 2020 obligation for State licensing agencies to check the Clearinghouse for information when a driver applies for, or is renewing, his or her CDL. In other words, the State government line of defense for keeping drivers with past drug or alcohol violations off the road won’t be in place for some time due to FMCSA’s need to clarify the Clearinghouse rules for the States.

For the entry level driver training rules, the delayed compliance date for FMCSA and the State CDL licensing agencies means that FMCSA won’t be able to electronically accept training certification information on individuals from the training providers (as required in the rules) and, in turn, will be unable to electronically transmit this information to State CDL licensing agencies as they evaluate CDL applications from new drivers.

Since FMCSA won’t be ready to provide this information to the State licensing agencies in early 2020, it remains to be seen how States will obtain this training certification information. Stay tuned for more on how this important dot will be connected.