​PTDI Urges FMCSA to Reconsider Behind the Wheel Time

March 2017

The Professional Truck Driver Institute (PTDI) has submitted a letter to the Federal Motor Carrier Safety Administration (FMCSA) urging it to reconsider its decision to exclude Behind the Wheel Time from its Final Rule on Minimum Training Requirements for Entry-Level Commercial Motor Vehicle Operators published on December 8, 2016.


To develop the Final Rule, the agency entered into a negotiated rulemaking process, which brought together various industry stakeholders to form an Entry-Level Driving Training Advisory Committee (ELDTAC). The consensus reached by ELDTAC, on which PTDI was a participant, included the requirement that applicants for a commercial driver’s license (CDL) receive a minimum number of hours of behind-the-wheel (BTW) instruction along with minimum competency requirements.

However, the Final Rule excluded a BTW requirement despite the consensus reached. It was very disappointing to PTDI stakeholders, and others from the ELDTAC, that FMCSA did not include BTW time in its Final Rule.

PTDI is concerned, particularly, that the apparent reasoning for omitting the BTW requirement was the Office of Management and Budget’s (OMB) determination that it would create an undue cost burden on schools. Quality training programs already require BTW time, and some states require it.

PTDI, in its minimum standards, has specified not only additional BTW hours, but provided additional requirements for specific skills:

•44 hours (60-minute hours) per student overall with 12 of those on the highway [public roads], including six hours with a 15,000-pound minimum load, and 32 hours that may be on the range, highway or a combination range/highway.The 44 hours also include a minimum of one hour of night driving practice.

•Included in the 44 BTW hours are 24 hours of Basic Operations, 17 hours of Safe Operating Practices for basic operations and three hours of Advanced Operating Practices.

The purpose of establishing entry-level training standards for commercial drivers is to reduce programs that are turning out inadequately trained and prepared drivers, who pose a risk to public safety. This has been the foremost goal of PTDI since its inception – to assure drivers are fully prepared to take on the serious responsibility of driving a heavy vehicle on our nation’s highways – and PTDI firmly believes that BTW time is critical to achieving that goal.


PTDI is an international, nonprofit organization established for the twofold purpose of developing uniform industry skill, curriculum, and certification standards for entry-level truck driver training and motor carrier driver finishing programs, and certifying entry-level truck driver training courses at public and private schools and driver finishing programs at carriers for compliance with PTDI standards. PTDI is based in Denver, Colorado.