CDL requirements need to be strengthened, OOIDA says

April 3, 2024

Mark Schremmer


Driver training in the trucking industry needs to be strengthened, not weakened.

That was the Owner-Operator Independent Drivers Association’s response to the Federal Motor Carrier Safety Administration’s proposal to change its CDL requirements.

In February, FMCSA published a notice of proposed rulemaking aimed at increasing flexibility for state driver licensing agencies and applicants.

OOIDA, which refutes any claims of there being a driver shortage, says there is no justification for making it easier for unqualified truckers to possess a commercial driver’s license. The Association filed formal comments on Tuesday, April 2.

“Currently, far too many new drivers are entering the trucking industry and driving on the nation’s roads without the basic skills to safely operate a commercial vehicle,” OOIDA wrote in comments signed by President Todd Spencer. “With that in mind, we question the agency’s proposal amending CDL regulations that would weaken driver training standards and fail to improve highway safety … FMCSA should be finding ways to bolster training requirements, not dilute them.”

FMCSA’s proposed changes include:

  • Giving applicants the option to take a CDL skills test in a state that isn’t their home state
  • Allowing commercial learner’s permit holders who have passed the CDL skills test to operate commercial motor vehicles on public roads, without a qualified CDL holder in the passenger seat
  • Removing the requirement that an applicant wait at least 14 days to take the CDL skills test following the initial issuance of a commercial learner’s permit
  • Requiring third-party knowledge examiners be subject to the training, certification and record-check standards currently applicable to state knowledge examiners

OOIDA, which long advocated for the entry-level driver training rule, argues that a well-trained driver is the best way to improve highway safety.

The Association has concerns about each of the proposed changes.

On CDL skills testing for out-of-state applicants:

“FMCSA, in conjunction with the state drivers licensing agencies, must present more information about how different states are administering CDL skills tests and what information is available regarding pass/fail rates, procedures for retaking exams upon failure and other irregularities between states’ testing data,” OOIDA wrote. “While we understand the intent of alleviating CDL delays and waiting times, we must ensure all states are meeting minimum entry-level driver training standards.”

On learner’s permit holders who passed the skills test:

“The notice of proposed rulemaking fails to explain how the commercial learner’s permit holder will be adequately mentored if the CDL holder is not in the passenger seat,” OOIDA wrote. “Given the minimum nature of current entry-level driver training standards, inexperienced drivers will face countless conditions, scenarios and other challenges they had absolutely no training for during their first months and even years on the road.”

On removing the 14-day waiting period:

“The agency should only remove the 14-day waiting period if they first amend entry-level driver training requirements to include a minimum level of behind-the-wheel training,” OOIDA wrote. “Since the ELDT rule does not have a minimum number of behind-the-wheel hours, FMCSA should not weaken training opportunities by eliminating the 14-day waiting period for commercial learner’s permit holders to take the CDL skills test absent other appropriate agency actions.”

On third-party knowledge examiners and testers:

“OOIDA has historically raised concerns about the reliance and expanded use of third-party knowledge examiners and skills testers as we continue seeing instances of third-party examiner fraud and bribery,” the Association wrote. “Certainly, more oversight is warranted as more and more states increasingly utilize third-party examiners.”

Individual truckers also have been vocal about their opposition to FMCSA’s proposed changes.

According to, the agency received 644 comments. Many of the submissions came from truck drivers who echoed OOIDA’s concerns.

“For an agency that is supposed to be all about safety, I cannot understand the logic in this proposal,” Dawn Wheeler wrote. “By not requiring a CDL to be present when a permitted driver is behind the wheel is the height of foolishness. The only way to learn actual safe driving is behind the wheel with an experienced CDL driver. Who will take the brunt of an inexperienced driver except the unsuspecting public? These proposals are as foolish as putting 18- to 21-year-old drivers behind the wheel of an 80,000-pound weapon. It only profits the large companies by letting them dodge safety rules and government greed.” LL