Who is ultimately responsible for determining if a driver is qualified to operate a vehicle for the company? Most employees believe that it is the companies’ responsibility, while most employers believe it is the drivers’ responsibility. The truth is that is both the employee and the employer’s responsibility to ensure that the driver is qualified to operate the vehicle.
The next question you probably have is what does QUALIFIED mean?
If a driver is operating a tanker vehicle without a tankers endorsement then they are NOT qualified to operate that vehicle. Or if they are operating a CDL vehicle without holding a valid CDL then they are NOT qualified. Or if they are operating a non CDL (GVWR under 26,000lbs) without possessing a valid medical card, then they are NOT qualified. Or if the company does not have a valid driver file for the CMV driver that is up to date, that driver is NOT qualified. In this newsletter we will dig deeper into all of the qualifications and how to ensure your drivers meet the federal regulations.
Let’s get started with the basics
Any vehicle with a Gross Combination Weight Rating (GCWR) over 26,000lbs requires a CDL (Commercial Driver License). Unless it is an emergency response vehicle responding to or from an emergency, or a vehicle owned and operated by an agriculture producer and is within a 150 air-miles of the farms home-base.
If you are operating a Commercial Motor Vehicle (CMV) any vehicle used for commerce that has a GCWR over 10,000lbs. Then you must have a valid driver license and a valid DOT medical card. To put that into perspective if you are driving a Ford Ranger with a GVWR of 3500lbs and you hook up to a trailer with a GVWR of 7,000lbs your GCWR would be 10,500lbs. If you are trying to make money and crossing state lines then you are required to be a Commercial Driver, and your vehicle is required to have meet the Federal Motor Carrier Regulations (FMCSR’s). Crazy right!
How do I find the GVWR on a vehicle?
The best way is when you open the drivers door there is typically a tag with the VIN number on it. That is where the GVWR is listed. On a trailer it will be listed on the VIN plate. The Vin plate can be found on the neck of the trailer or on a larger trailer it can be riveted to the frame by the landing gear.
Did you know that pickups have upped their GVWR in the past 15 years? In 2005 the typical 1 ton single wheel pickup truck had a GVWR of about 9500lbs. In 2010 the GVWR was typically 10,000lbs, & in 2020 the typical GVWR is 11,500lbs. That’s over a ton difference. It’s great that vehicles are now able to haul more, its bad because if your company used to buy 1 ton pickups they weren’t DOT regulated vehicles now they are! The 1 ton duly used to be rated to 12,000lbs and now are rated at 14,000lbs or more. Why is this so important to know. Because you used to be able to hook up to a 14,000lbs trailer and not need a CDL. Now when you connect to that same trailer rated at 14,000lbs your new GCWR is now 28,000lbs and you must have a Class A CDL to operate that vehicle legally.
States have different Classes for their regular licensees, Colorado uses a Class R, Texas Class C, New Mexico Class D. There is no federal regulation for the Class of a regular driver license.
Commercial Driver License (CDL)
The CDL is required to have the same Classes no matter which state the license was issued in. There are also a few more details that you should know about the CDL. There is a maximum of 8 years that the license can be valid for by federal regulation. Some endorsements shorten the length that a license is valid. If a medical card is not uploaded into the CDLIS (Commercial Driver License Information System) then the CDL is not valid and the state must downgrade the license to a regular driver license.
CDL Class A
Any combination vehicle that has a GCWR over 26,000lbs where the trailer has a GVWR of over 10,000lbs. Let’s say that you are operating a dump truck with a GVWR of 26,000lbs & you’re pulling a trailer with a GVWR of 10,000LBS. Are you required to have a CDL? NO. Because the trailer is rated at exactly 10,000lbs and the truck is rated at 26,000lbs you do not have to have a CDL. If the trailer was rated at 10.001lbs then you would be required to have a Class A CDL.
CDL Class B
Any vehicle that is rated over 26,000lbs requires a Class B CDL. That means that if you are operating a crane that has 2 steer axles and 4 drive axles & weighs 110,000lbs would require a Class B CDL. If the boom of the crane rests on a dolly then a Class A CDL would be required, because the dolly is considered a trailer.
CDL Class C
Any vehicle under 26,000LBS where a CDL is required to operate. Examples would be buses designed to carry 16 or more passengers including the driver, or any vehicle carrying a placaradble amount of hazardous materials. A commonly mistaken vehicle is an airbrake equipped vehicle. You MAY operate a vehicle that has airbrakes WITHOUT a CDL as long as the vehicles GVWR is less than 26,000lbs.
CLP (Commercial Learners Permit)
This is given to a person who passes the CDL written exams. The CLP will be good for 6 months and can be renewed one time before the CLP holder will have to retake the written exams. When a driver holds a CLP they can not operate a CDL vehicle unless there is another person in the font seat that is properly qualified to operate the vehicle that is being operated. Example: If the vehicle requires a P endorsement both the CLP and the CDL holder must posses the P endorsement on their licenses. If it is a Class A vehicle then both the CLP must hold a Class A CLP and the CDL holder must have a Class A License.
If a vehicle is rated over 26,000lbs and meets certain criteria then a special endorsement is required to operate that vehicle.
If a vehicle is equipped with a permanently mounted tank that is over 119 gallons or tank that is 1000 gal or more and is not permanently fixed to the vehicle you are required to have a tanker endorsement on your CDL. What does permanently mounted mean? Welded to the frame of the vehicle. If the tank is bolted or if the bed is bolted to the frame then it is not considered permanently attached to the truck. Written Test Only
T (Double & Triples)
If you are pulling more than one trailer then a T endorsement will be required to operate that vehicle. Lets dig in a little deeper. Does this include a lowboy trailer with a jeep? Yes it does. Written Test Only
H (Hazardous Materials)
Anytime you are transporting a placardable amount of hazardous materials then you must have the Hazmat endorsement on your CDL. Even if the vehicle is not rated over 26,000lbs then you still need an H endorsement if moving a placardable quantity. Written Test and Background Required
X (Hazmat Tanker Combo)
An X endorsement is required when a driver is transporting a placardable amount of hazardous materials in a tank that is mounted to the vehicle. If a driver has an X endorsement then they will not have the N (tanker) or H (hazmat) endorsements listed on their CDL. This endorsement combines those 2 endorsements into one. Written Test and Background Required
If the vehicle was designed from the manufacture to transport 16 or more passengers including the driver then a P endorsement is required. The GVWR of the vehicle does not need to be over 26,000lbs to require a CDL with the P endorsement. One of the biggest questions for this one is, “What if the vehicle was originally designed to transport more than 16 people but we removed all but 5 seats from the bus and its GVWR is 16,000lbs? Do I still have to have a CDL with the P endorsement?” The answer is YES you do. The way the regulation reads is based on how the vehicle was manufactured. Written Test and Skills Test in Passenger Vehicle Required
S (School Bus)
If you are transporting students to or from school or an event then a S endorsement is required. Written Test and Skills Test in School Bus Required
Restrictions are just as important as Endorsements to look for an a CDL
C (Corrective Lenses)
The driver is required by law to have corrective lenses while operating any motor vehicle on public roadways.
E (Automatic Transmission)
When a CDL driver takes their skills test in an automatic truck then they will be issued an E restriction on their license. They will not be able to operate a vehicle requiring a CDL that has a standard transmission. To remove this restriction the drive must get their CLP and take a skills test in a vehicle equipped with a manual transmission.
A driver with a K restriction will not be able to operate a CDL vehicle outside of the state where their license was issued. For example a person with a K restriction who holds a Colorado Driver license would not be able to operate a vehicle outside of the state of Colorado. This restriction will be added to anyone who is under the age of 21, or has certain medical waivers issued by the licensing state.
L (Air Brakes)
Anytime the L restriction is listed the driver may not operate a vehicle with a GCWR over 26,000lbs that is equipped with airbrakes. To remove this restriction the drive must get their CLP and take a skills test in a vehicle equipped with airbrakes.
M (No Class A Passenger)
The M restriction limits a CDL driver from operating a Class A Passenger vehicle. What does this mean? Any vehicle pulling a trailer that is designed to transport passengers on public roadways. To remove this restriction the drive must get their CLP and take a skills test in a Class A passenger vehicle.
N (No Class B Passenger)
The N restriction limits a CDL driver from operating a Class B Passenger vehicle. To remove this restriction the drive must get their CLP and take a skills test in a Class A or B passenger vehicle.
O (No Tractor Trailer)
The O restriction limits the driver from operating a tractor trailer rig. Really what it means is that the CDL holder tested in a Class A truck and trailer that did not utilize a 5th wheel style connection. Most likely they tested in either a pickup pulling a trailer or a truck and pintle hitch setup. To remove this restriction the drive must get their CLP and take a skills test in a Class A Tractor Trailer vehicle.
P (No Passengers)
The P restriction limits a CLP driver from operating a Passenger vehicle with passengers present in the vehicle. What does this mean? They can operate vehicles equipped to transport 16 or passengers, but can not transport any passengers on said vehicle. To remove this restriction the drive must take a skills test in a passenger vehicle.
X (No Liquid in Tank)
The X restriction limits a CLP driver from operating a tanker vehicle with liquid in the tank. To remove this restriction the drive must take a skills test.
Z (Air over Hydraulic Brakes)
If you tested in an Air over hydraulic brake vehicle then you will have the Z restriction. To remove this restriction the drive must take a skills test in a full airbrake vehicle.
W (Licensed Operator Front Seat [LOFS])
This will only be found on CLP’s or permits. And only some states will have this restriction. (NM is one of those states) it is stating that the CLP holder must have a CDL holder in the front seat with them while they are operating a CDL vehicle.
Those are the facts about CDL’s. Continue to follow us for more valuable information.