Insights & Analysis
Commercial Driver Training & Hiring: Recent DOT Enforcement Activity – Webinar Materials
Commercial Driver Training & Hiring: Recent DOT Enforcement Activity – Webinar Materials
Recent federal enforcement actions targeting CDL training providers and testing practices are creating new considerations for carriers, brokers, shippers, public transit agencies, and CDL training providers.
In this webinar, Greg Reed, Transportation & Logistics Practice Group Leader at Hanson Bridgett, and Andrew Poliakoff, Executive Director of the Commercial Vehicle Training Association (CVTA), discuss recent DOT and FMCSA enforcement activity and the practical implications for the transportation industry.
Topics Included:
- Recent DOT and FMCSA CDL enforcement actions
- Potential exposure arising from driver hiring and training issues
- Considerations when evaluating transportation providers
- Practical steps CDL training providers and transportation companies can take to mitigate risk
Webinar Materials
Download the presentation materials from the webinar below.
| 00:00:00:15 - 00:00:29:08 | Okay! So we are going to kick off this webinar. Close on time as we possibly can. Andy and I were just having a conversation about this topic, and I think, you know, we’re just expressing how excited we are to be together today to to share our insights and talk about the latest developments in the industry to our guests and to people who have the chance to watch this as a recording after the webinar. |
| 00:00:29:10 - 00:01:03:03 | I want to welcome you to the Commercial Driver Training and Hiring webinar. What transportation companies, public transit agencies, shippers, CDL training providers, brokers, transportation stakeholders need to know in light of the recent DOT enforcement activity. I’m going to introduce my my friend, my guest, my co-host in many respects, Andy Poliakoff, who’s the executive director of the Commercial Vehicle Training Association, or CVTA. |
| 00:01:03:04 - 00:01:51:19 | He is an expert in this space with, you know, fantastic insight into how we train CDL drivers such that they can be licensed such that they are behind the wheels of the vehicles on America’s roadways and impacting the way goods are moved throughout the nation. Of course, I’m Gregory Reed, I’m a partner at Hanson Bridgett. I’m also the practice leader for our transportation and logistics practice group, and this is the latest in a series of webinars we’ve hosted to talk about CDL licensing, CDL training, and the rapidly evolving landscape, of commercial transportation as it applies to both commercial freight transportation but also as well public transit agencies. |
| 00:01:51:19 - 00:02:19:12 | And Hanson Bridgett represents many public transit agencies based in California. And, you know, they are also responsible for hiring drivers that are properly trained and properly licensed, with big implications for their operations and the American public. One of the things that I want to touch upon quickly here, before I turn it over to Andy, is, you know, it’s something we were discussing right before we went live on this webinar. |
| 00:02:19:14 - 00:02:53:13 | And that is in this environment of rapid change, it is really easy to lose sight of some of the most significant developments that nevertheless are not capturing the headlines because it’s not the big Supreme Court case, it’s not the big litigation, it’s not the big verdict. And in many respects, CDL training is at least a degree, if not multiple degrees removed from the day to day operations of trucking companies, public transit agencies, certainly brokers, certainly shippers. |
| 00:02:53:19 - 00:03:20:09 | And I think in large part that’s because, we have this intervening event where a state licensing authority issues a license, and we operate under the assumption that once that license is issued, we know that this driver is properly trained, drivers, properly behind the wheel. So we don’t think about the training aspect of it. But this is precisely why the work of KTA is so important. |
| 00:03:20:12 - 00:03:55:21 | This is precisely why the DOT and the latest enforcement initiatives on training providers is such a critical issue for everyone in that transportation network, everyone in that supply chain to understand, because it does have real implications for your risk mitigation and liability. It does have real implications for your businesses operations, and it has real implications for the future of CDL training and CDL drivers, which means the future of how goods are moved on our nation’s roadways. |
| 00:03:55:23 - 00:04:30:15 | So without further ado, I really want to turn this over to my colleague, my friend Andy, to give us some better and more complete perspective as to as to the work of CVTA and of course, the CDL training regime that operates in our country today. Great. Thank you so much for that great description and and an opening. I think it’s it’s true that this is an area that has been very much not perhaps on people’s the front of folks minds for a variety of reasons. |
| 00:04:30:17 - 00:04:51:16 | I have the unique sort of perspective of having been what I believe to be maybe one of the 10 or 11 people who knew so much about entry level driver training until about the last year or so and, and have now, you know, had the opportunity for a variety of reasons to, to really be talking about this. It is critical to understand this. |
| 00:04:51:19 - 00:05:17:14 | And whereas it may not have been at the forefront of many of the webinar listeners minds, it has certainly been at the forefront of my mind. And of the many CVTA members that have participated in these activities and been high quality training providers for decades. And so, because it’s been thrust into the national awareness and this is something you’re here you want to know about, you are in the right place. |
| 00:05:17:15 - 00:05:37:24 | Apologies in advance for loading you all up with a lot of content. We may sort of complicate this ever so slightly a bit and give you perhaps more than you wanted to know. And then we’re promised we will uncomplicated this as we continue to talk about it and give you some practical understandings and some real tips on how to proceed accordingly. |
| 00:05:37:24 - 00:06:05:13 | So we’re going to examine the entire framework of the Eld training provider concept, the training Provider registry. And we’re really going to talk a bit about the recent enforcement activities, why those have happened, what those look like. I think that’s one of the biggest things will tackle is, well, I’m I’m seeing that there’s this training provider registry and I’m reading in industry papers or maybe even in a national newspaper about removals and all of this enforcement. |
| 00:06:05:13 - 00:06:25:20 | What does that actually mean? What does that mean for me? With my operations, we really want to dig into that, unpack it, and then make sense of it with tips. And I think then, you know, Greg, I think you’re going to talk quite a bit about some of these, these other items in terms of the different liability and practical consideration components. |
| 00:06:25:22 - 00:07:00:04 | That’s right Andy. Okay. Let’s see if I can actually advance slides. You know, the amount of training I really need. Here we go. Perfect. Okay. So by way of introduction. Indeed. This is something that the Commercial Vehicle Training Association has been working on for quite some time. CVTA is the largest association of professional truck driver training programs in the United States, with members in 46 states that train upwards of 100,000 entry level commercial motor vehicle drivers each year. |
| 00:07:00:06 - 00:07:30:10 | I think a key piece of information here is that for many, many years, CVTA was working along with others to propose the creation of national training standards. This was a patchwork quilt across the states of different requirements. In many states there were no requirements. And I think that that is something that we have seen. Finally, that became enforceable federal law in 2022. |
| 00:07:30:16 - 00:08:01:09 | And since that time, CVTA and it’s at its members have anticipated really the what we call the deluge of bad actors into this training space. And we’ll talk a bit more about how and why that happened. But we have been a task force. Our LTT task force has been really pressing this issue since 2022, and it was only really in 2025 that a series of tragic crashes began to bring this to the national attention. |
| 00:08:01:11 - 00:08:26:09 | And that was really the vehicle that CVTA used to, you know, advocate vigorously for more oversight and enforcement in this space. And that has some great benefits. But it’s also created some of the challenges of understanding how this whole process works sort of more broadly. So we can hop to the next one. And so here we go. |
| 00:08:26:10 - 00:08:59:04 | And hold on. There we go. We got it. And so when we talk about LTT we’re talking about the entry level driver training final rule. This is a requirement that all individuals utilize these national training standards. It’s a 49 module curriculum. That is the same whether you’re in Hawaii or Alabama or Virginia or Nebraska. Right. I think that’s the key, is that this ELT final rule created national training standards so that we can have confidence. |
| 00:08:59:06 - 00:09:24:11 | Is the motoring public in this, in this country, that everyone is trained to the same standard. So individuals must tackle both theory portions of training and as well as behind the wheel. Proficiency activities. And they they must demonstrate those. They must demonstrate that they are proficient in those activities before advancing to actually burn and be able to take the test for their commercial driver’s license. |
| 00:09:24:11 - 00:09:49:19 | So one of the key things you’ll hear about this a lot in this conversation is the training provider registry. So all providers must be in the training provider registry. That’s all the CDL schools, all the companies, all the municipalities, everyone under the sun in the United States of America that’s teaching people to drive a truck must be on the training provider registry. |
| 00:09:49:21 - 00:10:17:09 | But here’s the wrinkle. If you get down to that fourth bullet and take a look, you will see that this is a self certification database. Let that sink in for a second. One of the benefits of this, because we we do want people to be able to, to train their employees and train others. Not everyone has to be in the professional school business in order to comply by any means with Eld. |
| 00:10:17:11 - 00:10:53:11 | But what’s really taken shape and been problematic and been the cause for so much of this enforcement is this large influx of bad actors that have begun to operate in this space and begun training the public, and what that looks like is something that in the CDL and the truck driver training community, we call CDL mills. And these are organizations that purport to train people to drive a semi in two days or three days. |
| 00:10:53:13 - 00:11:18:01 | We continually report on these sorts of bad actors to the Fmcsa, to the US Department of Transportation, that is, and they exist out there all over the place, and they are really in an immense problem. And they arose because of this self-certification database. Now that we hope is changing, and there’s a lot that’s going on in that space. |
| 00:11:18:04 - 00:11:39:20 | But that is that’s the nature of this broader framework, is that we have the training standards, we have the different skills and theory activities. We have a registry that’s good. All these things are good, but we have a self-certification registry. That’s the database that’s a big problem. No state license required. And you don’t have to submit your state license. |
| 00:11:39:20 - 00:12:06:06 | You don’t have to submit your curriculum. You don’t have to submit your course outline. None of those are required to begin training the public. Quite stunning. Often when I speak to people about this, they really can’t believe it. I’m. I’m with them. So we see these also part of this framework is the enforcement categories. And those really broadly fall into removals, which we’ll talk quite a bit more about. |
| 00:12:06:07 - 00:12:26:06 | And then obviously notices of proposed removal where you can still operate on the training provider registry. But you have been warned that you will be removed if you do not make certain changes. So a lot to talk about in that category as well, which we’ll get into, but I think we can hop perhaps to the next one, Mr. Reed. |
| 00:12:26:07 - 00:13:00:03 | We’ll we’ll do. Andy, before I jump over, just a quick question of to clarify, you know, you talk about the Eld requirements as being a standard across our, you know, 50 state or 50 state and territory regime. Is that a flaw in terms of the training requirements to can states impose a greater training requirements in order to be licensed, or is that a strict, strict standard that must be complied with without deviation or variability across across? |
| 00:13:00:04 - 00:13:24:17 | That’s a great that’s a great question. Yes, certainly states can increase the amount of skills that they want required. They can impose certain hours requirements and a variety of other things like that. But in order to comply, currently you need to teach at a at a minimum you need to be teaching these LTT concepts. Great point. Thank you Brian. |
| 00:13:24:18 - 00:13:32:18 | Appreciate that. I thought that was true, but I knew that you would be the guy to know for sure. Indeed. |
| 00:13:32:20 - 00:14:03:01 | And so what was this looking like? As as I mentioned, there are CDL mills that exist in this space and they’ve really flooded the the space in February 7th, 2022 was then when the rule took into effect and everyone realized, including the bad folks out there and the fraudsters, so to speak, that they could just register onto the TPR and begin a training. |
| 00:14:03:06 - 00:14:35:18 | So there was little to no fmcsa enforcement or oversight from about February 2022 until 2025. Believe it was August when we saw the beginnings of the awareness growing on the part of FMC and US DOT, and there were really a series of fatal truck crashes in 2025 and they’ve, you know, continued. Sure. Anyone that’s certainly reading the industry papers or even the national news has seen a variety of these crashes. |
| 00:14:35:20 - 00:15:05:09 | Drivers, you know, doing U-turns in semis on the highway and causing fatalities. And that has been ghastly. And also, and if you’re going to be dealing with a crisis like that, at a minimum, you should have the opportunity to try to create some good from that. And the good that we’ve seen is, is, is the attempt to get DOT and FM, CSA to begin tackling this issue. |
| 00:15:05:10 - 00:15:29:22 | Now, what I will say, and this is something that Greg and I were talking about earlier, is that a lot of this did ride in on the Trump administration’s executive order around English language requirements, as well as a lot of the focus on the part of the secretary on non domiciled CDL holders. That is something that USDOT was really looking at. |
| 00:15:29:23 - 00:15:55:12 | They were fighting with the states over non-dom s. They were drawing a lot of scrutiny toward English language proficiency and not just CVTA, but a lot of folks in this space said, look, you really need to take a look, even sort of passed earlier in the food chain than just the state driver’s license agencies. Please take a look at all of these really problematic. |
| 00:15:55:14 - 00:16:24:21 | Schools or training providers, I have to say schools in quotes because a CDL mill is not a school. But that is that is what began in 2025 to change this landscape. Now we see over 9000 removals from the training provider registry. Many of those were voluntary. But in the last year and a half or so, we’ve seen actual boots on the ground audits start to take shape. |
| 00:16:25:02 - 00:16:59:00 | Those being called operation driver training, one that really began the process with the boots on the ground. I think FMC tends to call those surveys more than audits, but operation driver training to was the real deal. Those are the boots on the ground audits that began in July of this year and have really brought in this large influx of notice of proposed removals, and then certainly some of the more prominent emergency removals we’ve seen that have been very much connected to the English language proficiency deficiencies. |
| 00:16:59:00 - 00:17:05:24 | And we’ll talk more about that in a bit. |
| 00:17:06:01 - 00:17:45:12 | Okay. So clean up and confusion. Let’s talk about the notice of proposed removals first. Right. The we have certainly seen emergency removals. And those have been I think it was around 110 of those in the last couple of months. A lot of fanfare about those I think a lot of importance of the English language proficiency requirements. And those emergency removals were based on locations that had allegedly trained a minimum of ten individuals, who then were subsequently removed during roadside inspections for failing English language proficiency test. |
| 00:17:45:12 - 00:18:17:08 | So that really is the predominant version of the emergency removal that we see having taken shape. Certainly, there are other fraudulent activities and other things that Fmcsa has investigated, but those emergency removals, predominantly and certainly most recently have been based on LP violations and rooted in FM. CSA having discovered that ten or more individuals were trained at a school where those individuals subsequently failed a roadside check. |
| 00:18:17:10 - 00:18:41:22 | But the notices of proposed removal have really been. I think the place CVTA and many other folks who work in this space. I will give a quick note to the National Association of Publicly Funded Truck Driver Schools and a TDs and other outstanding organization. For those of you who are looking to find great drivers. Certainly you want to be looking to see to schools. |
| 00:18:41:22 - 00:19:08:08 | And maybe I should say if you can’t find one of those, you should find a publicly funded school. So the know these notices of proposed removals, this is something that I think many in this space wanted to be really an indicator of some bad stuff, right? That you were had some clear substantive violations. And that is the case that you can have substantive violations. |
| 00:19:08:12 - 00:19:42:24 | But as we know, at CVTA, and from speaking with a lot of folks in this space. That is not how it shaked out and shook out an operation driver training to. Right. We saw numerous notices of proposed removals for really minor clerical and administrative deficiencies. A, there is a particular form that is inferred in the the final rule around having a behind the wheel trainee sign, a piece of paper. |
| 00:19:42:24 - 00:20:10:05 | It doesn’t expressly say that they need to sign a piece of paper in the rule. And so most folks were surprisingly didn’t have a piece of paper that that trainees would sign. And so if FMC, FM, CSA showed up for an audit and there would be, you know, 300 or 400 things they were looking for, and they found one thing missing, which we would argue is a borderline clerical, a, you know, infraction or what have you. |
| 00:20:10:07 - 00:20:42:24 | We would see that those folks would be removed from they would be put on this list, which is really stunning and embarrassing and troubling at a minimum for a lot of these schools. But it began even it became even a bigger problem when we were seeing that not only was an individual location that may have not had that piece of paperwork in place being removed, but every single location that was part of that company began being removed. |
| 00:20:42:24 - 00:21:07:09 | And that’s why we see this company wide know for single location, even just clerical deficiencies. That is really unique thing to see. Was a surprise to many in this space. Obviously, CBA has been pushing for greater enforcement for a long time, and to see this was was troubling. And we know that that must be confusing if it’s confusing and problematic for us. |
| 00:21:07:09 - 00:21:39:11 | I can only imagine that those of you out in the world trying to understand what’s going on in the high quality training space for hiring drivers must be even more confused. We’ve also certainly see errors in a number of these. Removal. Pending removal notices. Another big problem with that is that in this zero tolerance environment that Fmcsa has created, we’ve also seen extended timelines for being taken off the list. |
| 00:21:39:11 - 00:22:01:04 | So imagine you were missing one document at one school and you have 20 locations. Now. All of your locations are listed on that notice of proposed removal. And it’s going to take you three four weeks to be removed. Well, this is the point at which hiring carriers start calling and saying, hey, we’re not going to be able to hire from you anymore. |
| 00:22:01:05 - 00:22:41:21 | State funding agencies say, why? What are you doing on this list? What’s going on? And they start talking about pulling your funding. And even licensing agencies in those states have begun viewing that as a list, as a proxy for poor quality. There are certainly are substantive versions of. Nope, but predominantly the ones we have seen have been really based on clerical or other matters, like you are listing that you do class B training, and when the CSA shows up on on the day to your location, you, your class B truck is at another school because you actually have students there. |
| 00:22:41:21 - 00:22:54:06 | So these are typically minor elements that I’ve I’ve riffed on that for a minute there. Mr. read. We probably hop to the next one. |
| 00:22:54:08 - 00:23:16:05 | Right. So I think at the end of the day, this is really what we viewed. I’ll just speak for from CTA’s perspective, this has been sort of the best of times. In the worst of times, there’s nothing that CV members have wanted more than to see greater enforcement. I would say as a person who’s learned about a lot about this in the the many years I’ve been working on it. |
| 00:23:16:10 - 00:23:41:15 | There’s nothing that I would personally want more than to see all these bad actors removed and FM CSA to create a great system that worked reasonably and efficiently. And I appreciate the concept of a zero tolerance environment, but I think it is currently complicating this scenario. And it’s the best of times because we have enforcement. It’s the worst of times because we have hair trigger, zero tolerance enforcement. |
| 00:23:41:15 - 00:24:05:12 | That is confusing a lot of people in this space. So these zero tolerance policies, zero tolerance policies are creating that uncertainty. The differences in these and the removals are disrupting legitimate providers who for a variety of reasons. And then now we even see DHS involvement. The task force in the white House is also including the Department of Justice. |
| 00:24:05:13 - 00:24:27:21 | Again, we love enforcement. We’re just they things have got to cool down a bit. And there are indicators that that may be happening, but that’s that’s really the state of play that we’re in right now in this commercial trucking space. But we promised that was complicating things. We’ll, we’ll, we’ll get we’ll hop out on the other side providing some tips and understanding. |
| 00:24:27:23 - 00:24:50:01 | Well, I’m not sure that’s true. And if we’re going to try, and I will just say, that was some of the most informative, you know, 20 minutes that I’ve enjoyed. And I really can’t thank you enough for spending time here with me and with our, our attendees, and sharing our insights. Obviously a very important issue. |
| 00:24:50:03 - 00:25:23:24 | I’m going to try to take this incredible perspective. And inside the Andy has shown and bring it down to some real world application for particularly the companies that are hiring these drivers or the companies sort of further along the transportation chain or supply chain, who have to deal with the consequences of this enforcement initiative and also have to think about operationally, how these enforcement initiatives are going to impact their ability to continue to operate into and to mitigate and limit liability. |
| 00:25:24:01 - 00:25:48:24 | And we’re going to start with talking about these emergency removals, because, as Andy suggested, the notice of proposed removals are kind of live at times in a gray area. And there are there is some practice of practicality in addressing those. And we’ll talk a little bit more about that too. But the emergency removals are our are the, the hook. |
| 00:25:49:00 - 00:26:16:07 | It’s the uppercut you weren’t seeing coming. And suddenly now, a school that you were relying upon to train drivers that would ultimately become your employees. Get behind the wheel. The vehicles in which are contracting is no longer able to provide training and has to stop immediately. So right now, what you’re seeing on your screen is an actual emergency removal notice received by a company. |
| 00:26:16:09 - 00:26:40:05 | All the particular information of this company has been redacted so that we can talk about this a little bit more forthrightly. And what I want. And this notice was received at the end of August as part of that 110 school wave that you might have heard about in, in the trade press and maybe even in some, in some national and regional press. |
| 00:26:40:07 - 00:27:03:21 | And the important thing here again, to emphasize, and you’ll notice on the bottom, is that this is an immediate removal from the training registry, which means that this school has to immediately cease all training over the next few slides, I’m going to be talking through where the CSA gets its authority to implement or to execute such an emergency removal. |
| 00:27:04:02 - 00:27:30:06 | What actually triggers these removals in this particular enforcement wave, what a provider can do kind of afterwards from the training provider standpoint to address the emergency removal, and then how this differs from a notice of proposed removal. And from there we’ll talk a little bit more about liability landscape risk mitigation and how this impacts the other stakeholders, if you will. |
| 00:27:30:06 - 00:27:57:11 | Whether it’s the trucking company, whether it’s the shipper, whether it’s the broker, whether it’s public transit agency, how such emergency removals, impact your operations and how you want to think about these emergency rules going forward. So, the authority at the FM, CSA has implement emergency removals comes in sort of three layers. And I think it’s important to see them stacked. |
| 00:27:57:13 - 00:28:25:04 | The statute behind all this is the Eld mandate. And Andy talked about and was implemented as part of Map 21. And first, to stay on the registry at all, a provider has to keep meeting every requirement of the Federal Training Provider Registry rules, which are located in 49 CFR part 380, subpart G. That’s about as complicated. |
| 00:28:25:05 - 00:28:59:08 | I’m going to get hopefully in citing particular statutes, but I but going through those regulations can be super helpful in terms of understanding training providers. Compliance is certainly obviously necessary as a training provider. Second, the CSA can remove a provider when an audit or an investigation finds material deficiencies in the program. That’s the typical and ordinary path, and it normally runs through a notice of proposed removal, with giving the provider a chance to respond and to fix the problem. |
| 00:28:59:10 - 00:29:28:02 | But then the third sort of authority for the FMC is to take action. And this is the one that really matters right now in this enforcement moment. And is the principal focus here of this webinar, is that the. Yeah, FM, CSA can skip that process entirely, and it can remove a provider immediately for fraud, criminal behavior, or willful disregard of the regulations, or when public health, interest or safety requires immediate action. |
| 00:29:28:06 - 00:29:40:12 | And that is what drove that emergency removal that was on the prior slide. And what we’re going to talk through, talk through here. |
| 00:29:40:14 - 00:30:09:03 | Okay. So this is the heart of the emergency removal. And I want to make sure that we kind of move slowly through this so you can understand what actually happened. Some of the challenges for the providers in this circumstance given this enforcement initiative. And then of course, what that means for further downstream in the transportation network. The FMC theory here connects two different training requirements. |
| 00:30:09:07 - 00:30:46:21 | First, the Eld theory curriculum must include instruction on the English language proficiency requirement and what happens when a driver violates it. And Andy obviously already has already has focused our attention on how the English Language Proficiency Enforcement Initiative initiative has now trickled down to the two providers. Second, every trainee that’s accepted for Behind the wheel training must certify that they will comply with with the driver qualification rules in part 391, and the English language proficiency requirement is part of that. |
| 00:30:46:23 - 00:31:21:02 | Here’s how the FMC used those requirements in this particular emergency removal. It didn’t send investigators to those schools. Rather, it did something truly, I think, unique. Andy could correct me if it’s unprecedented. What it did is it ran a desk audit and it compared the registry against roadside inspection data. It looked for drivers the school had certified as having completed the LDP, who were later placed out of service at the roadside for failing an English language proficiency assessment. |
| 00:31:21:04 - 00:32:04:13 | And when it found a cluster of these English language proficiency assessment failures, it concluded that the training program itself was material, materially deficient, and that the CSA, requirements weren’t complied with. This. You can imagine this pretty surprising to a training provider, because they don’t see those results on the roadside. And even a good training provider is assuming that it’s drivers when a pass successfully through the training program and subsequently get licensed by the state, by state licensing agency, or otherwise operating lawfully. |
| 00:32:04:15 - 00:32:33:10 | But here, in this instance, this training provider suddenly receives a notice on August 31st saying that some 50 different drivers or trainees that pass through the training program, have failed roadside English language proficiency assessments and subsequently received an emergency notice for willful disregard of FMC requirements, but also in the interest of public of public safety. |
| 00:32:33:12 - 00:32:40:13 | Let me see here. And. |
| 00:32:40:15 - 00:33:17:17 | It also creates a unique challenge for the training provider. And this comes up in this particular instance because the training provider says not only did we provide proper training, but what we’re ultimately not the licensing agency. So how can we be held accountable for something that we have ultimately no control over when it comes to a driver, which not just months but potentially years later after passing through the training program, has subsequently failed to comply with the English language proficiency requirement. |
| 00:33:17:19 - 00:33:39:24 | Or alternatively, you know, there’s a temporal issue there, right? When that driver, you know, you know, prospectively certify that they can comply with all the LDP training requirements and that they were going to be compliant with the English language proficiency requirement. You know, how much time has passed and what has happened in this driver’s life that subsequently they fail? |
| 00:33:40:01 - 00:34:21:12 | What could be a subjective roadside English language proficiency evaluation that subsequently flows back to the training provider, finding them kind of at fault for not properly, properly training, training the driver. Another wrinkle here that’s particular to this notice that we’re discussing but also could play out across the country, is that this training provider was located in a state and I won’t mention the state again, to protect the identity of this training provider, in which training providing CDL training was acceptable in languages other than English. |
| 00:34:21:14 - 00:34:47:10 | And so this training provider did just that. Now, of course, it also provided training in the English language, but to accommodate drivers who have multilingual or whose English wasn’t their first language, they also provided training in other languages. Now, recently, that state has changed its requirements, and training providers can no longer provide training in languages outside of English. |
| 00:34:47:12 - 00:35:31:13 | But again, here’s an example of a training provider operating under sort of enforcement initiatives and regulations that predate the current Trump administration and predate the administration of Secretary Duffy, thinking that they’re complying with all the requisite requirements now being caught with a change in administration, a change in in policy, a change in enforcement, and having this sort of retrospective look back at the drivers that have passed through the program going back as far as 2022, who now are part of a cluster of drivers that have failed roadside English language proficiency requirements and resulted in an emergency removal from the training registry? |
| 00:35:31:15 - 00:36:01:01 | Yeah. And, Greg, if I can just hop in for a second, I think you really have highlighted sort of this funnel, how all these roads or data points or pieces of information that might be in a driver’s mind, or particularly in a schools mind that is operating in a state where they can you maybe people may have been operating in a state where the test for the commercial learner’s permit, the knowledge test, is permitted in a different language. |
| 00:36:01:06 - 00:36:21:20 | We know that the federal standards permit you really to there’s no rule against teaching in a different language. And so I think again, it’s it’s I mean, unique perspective on this because I sort of view CVTA schools not to tutor our own horn, but sort of as, as the A and A plus students that exist out in this space. |
| 00:36:21:20 - 00:36:44:22 | And so we’re, you know, hyper focused on the LDP rule. We know everything. But I mean, if you want to be sort of generous to people who are operating at a little bit of a different level, you would say, well, gosh, to anybody in this space or someone that’s hiring from schools. ET cetera. They’re going well. They permit, you know, the knowledge test in a different language. |
| 00:36:44:22 - 00:37:12:15 | They permit training in a different language. Do they really need to know English? I mean, categorically, yes they do. In order to pass the skills test in order to actually get their CDL. And they need to have been really admonished to understand that. But, you know, if you’re being generous with folks, you can see how a lot of these data points on the part of the state versus the federal requirements have coalesced to create confusion in this space that couldn’t agree more. |
| 00:37:12:15 - 00:37:40:13 | Andy. So what is this training provider to do? And there’s two paths. And you know, this is specific guidance here for our training providers out there. And I want to make sure that you understand these options and that it’s not just as easy as responding to an emergency notice, let alone a notice of a proposed removal. So first, there’s an administrative review that the provider could seek. |
| 00:37:40:15 - 00:38:00:16 | And the provider has 30 days from the effective date of the removal, which in the case of an emergency removal is the very day that they received the notice to ask the fmcsa to reconsider. And here I think it’s pulled some language from this particular emergency removal. And I want you to look closely at the bolded language. |
| 00:38:00:18 - 00:38:43:03 | Their quest must lay out every factual, legal, and procedural issue in dispute with supporting documentation, and the Fmcsa can ask for additional information or to call a conference and can dismiss the request if the provider doesn’t cooperate. And I think that’s really important because based on prior enforcement initiatives and maybe based on, you know, a provider zone instinct, you might respond very quickly, refuting that you have failed to comply with the LDP requirements or with the certification requirement, if you will, or with properly training or educating these trainees about the English language proficiency requirement. |
| 00:38:43:09 - 00:39:12:09 | But if you fail to provide all the factual, legal and procedural issues in dispute, the CSA can take a very different approach. And rather than looking at this as a review process, which in itself has its own procedural complexities that at a provider needs to be aware of, they can treat it as a request for a re admission to the registry. |
| 00:39:12:11 - 00:39:44:07 | And in that process, again, if you haven’t rectified the underlying issues that the FMC has deemed, problematic or insufficient in order to remain on the training provider registry, well, then they’re going to deny or they potentially deny that reinterpreted opposition as a request for readmission, because, again, you haven’t addressed the underlying issues with sufficient factual and legal arguments. |
| 00:39:44:13 - 00:40:23:06 | And so if you’re a training provider and you’ve received an emergency removal, it’s important to understand what is required in order to make a compelling case. You are in all effects in litigation now with the FMC, even though we talk about it in the context of it being an administrative review. And it’s important that, at least in some circumstances, it’s the Fmcsa chief strategy officer that has ordered the Office of Safety Programs to respond and produce all the evidence that relied upon, and they’ll be the ones evaluating whether or not they made the error. |
| 00:40:23:08 - 00:40:49:20 | And we’re not going to get into the complexities, complexities of administrative law here and administrative review. But when the very entity that issued you the emergency letter is reviewing your arguments of why they’re wrong, you can imagine that the bar for proving that entity wrong is going to be quite high. And so even though you even though you’ve now been subjected to an emergency removal, you can no longer operate. |
| 00:40:49:20 - 00:41:17:22 | And that obviously puts your business in jeopardy. You have to be methodical and intentional in going about the response process. And you have 30 days and and moving expeditiously but thoroughly through those 30 days is critical. In order to address an error made by the FMC or to implement corrective measures and apply for readmission after receiving an emergency notice. |
| 00:41:17:24 - 00:41:46:18 | Okay. And I’m going to quickly just highlight some of the differences here. And he’s already talked about this. But the the there’s two particular items that I want to make clear. And then it’s one in a notice of proposed removal. You providers can continue to operate. They have 30 days to respond to the notice of proposed removal and then 30 days thereafter to implement corrective measures. |
| 00:41:46:22 - 00:42:15:06 | So a total of 60 days in order to meet FMC expectations. But they do not have to shut down during that process. And that is why a notice of proposed removal, can be a, a a false signal, if you will, in terms of actual the actually the quality of the training provider. But it’s also why, it doesn’t create as much urgency when, when compared to an emergency removal. |
| 00:42:15:12 - 00:42:42:06 | But the other thing I want to focus on here in regards to a notice of proposed removal, and I’ve seen this with clients as well, is that, yes, there are certainly circumstances when there’s administrative error, you know, as a training provider, you failed to collect this document. You don’t have this record. But there’s also in my from my perspective, there can be a lot of deficiencies which, are too easily overlooked. |
| 00:42:42:08 - 00:43:03:07 | And Andy pointed to one such example. Well, you assert that you provide class B training. But your class B vehicle isn’t on the premise. Sure, sometimes that’s because that vehicles. I had a facility providing training to trainees there, but in some instances, well, you didn’t have a class B vehicle in the first place, right? And maybe you did. |
| 00:43:03:08 - 00:43:28:06 | And maybe that changed. And when that happens, you now have a significant gap between what you’re offering in terms of your training program and what you can actually provide. Another example is somewhat shocks me at times is when, a training provider provides behind the wheel training at their own facility, but they don’t have what we would call a yard or space to safely provide that behind the wheel training. |
| 00:43:28:09 - 00:44:11:23 | And instead they’re providing all that behind the wheel training on public roadways. And given that the regulations are fairly clear that you do need a secure yard that’s not a public roadway, the fact that there is this gap in compliance, although it can be remedied, can result in a notice of proposed removal. So for training providers, I would really urge you to, you know, today but also regularly go through those requirements, you know, line by line and make sure that they are true in terms of what you’ve reported to the training provider registry so that you don’t receive such a notice, but also so that we can close the gap here in terms |
| 00:44:11:23 - 00:44:25:12 | of, you know, reputable, reputable training providers and those that, again, are those CDL mills that that Andy warned about. So, |
| 00:44:25:14 - 00:45:03:17 | Okay, so what I want to highlight here, and I know we’re even kind of running out of time, which is which is not surprising given given all the things that we’ve been trying to cover in this area here. Is that in the event of an emergency removal. So we’re really thinking here from the standpoint of a motor carrier, a public transit agency, from a broker or a shipper in the event of an emergency removal, while that training provider can no longer operate, can no longer advance trainees through its program, it isn’t the case that drivers that have already passed that program no longer have a valid CDL, or can be deemed not to have |
| 00:45:03:17 - 00:45:43:24 | sufficient training. And so, just because you might come across a training provider that you have, that your drivers have utilized before, that has now been subject to an emergency removal, doesn’t mean that you need to call. You know, you need to panic such that all the drivers you might be using that have passed to that program are no longer valid, but it is an important signal to start thinking about, how your hiring practices, and think about how you’re recording information regarding training providers that are training the drivers that you’re recruiting. |
| 00:45:44:01 - 00:46:12:17 | But what but even though a emergency removal doesn’t inherently create an issue for your drivers that have passed through that training program, and even though a notice of proposed removal doesn’t create an immediate issue that you need to address from a regulatory standpoint or standpoint as a motor carrier, as a public transit agency, as a shipper, as a broker, it unfortunately does create risk from a liability standpoint. |
| 00:46:12:19 - 00:46:54:22 | And how I think about this as a defense attorney for motor carriers and for brokers and for shippers, is that a emergency removal or a notice of proposed removal is a signal to plaintiff’s attorneys that perhaps there are drivers you are utilizing, either directly as a motor carrier? Or if you’re a shipper that has its own fleet or indirectly through a broker or through contracting with a motor carrier that might not be properly trained, and the schools or the training programs that are identified for emergency removal and notice the proposed removal are all publicly, publicly obtainable. |
| 00:46:54:24 - 00:47:39:11 | And plaintiffs attorneys, in the event of an incident or an accident, are going to start looking to this registry and start assessing whether or not you’ve taken actions to ensure that the drivers that you’re utilizing are directly or indirectly, are properly trained and are properly licensed, and it will paint the negative picture. If you become aware of the fact that a training program your drivers have passed through, is subject to emergency removal and and you as the motor carrier, you as the shipper, don’t have a way to assess whether that driver was, in fact, properly trained in the first place and thus properly licensed. |
| 00:47:39:13 - 00:47:46:22 | So what does that mean for kind of the everyday operation of your business? |
| 00:47:46:24 - 00:48:15:03 | So first we have the hiring gate. And this is how are we hiring our drivers. And the fix here is pretty cheap if you will. Or it’s easy when you’re bringing a new driver, there’s a motor carrier or if you’re bringing on new drivers because you’re a shipper that have your own has his own fleet, you’re going to want to ask every applicant where they completed their eldest and check that that provider is on the registry still, and that that provider is still in good standing. |
| 00:48:15:05 - 00:48:48:02 | The application rule doesn’t require that question. So you’re going to have to take that additional step to obtain that information. If the school was emergency removed, that’s the reason to look harder at that individual driver. But it’s not a reason to reject the applicant outright. Now it gets a little bit more complicated for drivers that are already part of your fleet, or already part of your employment pool, their CDL still stands and you have no regulatory basis to pull them off. |
| 00:48:48:02 - 00:49:17:21 | If the training program they pass through is subject to an emergency removal, or it has been subject to a notice of proposed removal. But once you know that a driver came from one of these schools, doing nothing also creates that liability risk. And so what you should have as part of your dick files and as part of your routine practice is, a documented trail, a paper trail, a reevaluation such that you are monitoring this driver’s performance. |
| 00:49:18:00 - 00:49:39:18 | You’re monitoring your conduct behind the wheel, as you might anyways, for the purposes of liability and risk mitigation. But now with an eye towards whether they have the proper training and subsequently, whether their CDL is properly issued and whether or not they’re creating greater liability for your company, or if they’re creating or if they’re managing that liability effectively for you. |
| 00:49:39:20 - 00:50:29:07 | One thing you need to absolutely avoid the however, and we’ve talked about this in previous webinars here at Hanson Bridgett is avoid blanket bands of hiring drivers from certain training providers. And the reason why is that often training providers can serve certain immigrant and non-native, non-native English speaking populations. And if you were as a motor carrier, for example, to decide, well, we are not going to hire any driver from that’s been licensed, but it’s come from a particular training provider that can be interpreted as a violation of Title VII and having a disparate impact analysis such that you’re discriminating against these types of drivers because there is an association or affiliation between their, their |
| 00:50:29:07 - 00:50:41:16 | country of origin, maybe, maybe, perhaps reflected in their primary language or in or in their language status. |
| 00:50:41:18 - 00:51:08:23 | Now, the last group here I want to touch upon quickly is what does this mean for brokers and shippers who are not directly working with these drivers? Well, the first thing that I want to highlight is that even though you might have concerns now about whether the driver behind the wheel or the motor carrier with which you contracted might not be properly trained, the answer is not for you, as the broker or the shipper, to start intruding into the operation of that motor carrier. |
| 00:51:09:04 - 00:51:43:10 | That’s what opens the door to vicarious liability that opens the door to you kind of being a co employer of those individuals. Instead, what you want to do is you want to rely on good contractual language, and you want to ensure that your contracts with that motor carrier, either through the broker flowing down or directly with that motor carrier, reflect warranties and representation representations that they have engaged in the proper driver oversight, and that they know these drivers are properly trained and and are properly licensed. |
| 00:51:43:12 - 00:52:04:18 | But as much as you don’t want to get involved, I really can’t emphasize enough. I don’t believe that brokers and shippers can be in a position of absolutely ignoring this issue, particularly as the FMC continues to evolve its training provider oversight and enforcement. |
| 00:52:04:20 - 00:52:27:06 | Okay, so am I right, Andy? And my turn me back. You’re right. You’re in the you’re absolutely the right place. So I think this is the cooler heads slide. Right. I think Greg was really apt in saying that if you see that someone’s been going through the emergency removal process, then I would add a lot of scrutiny to that. |
| 00:52:27:06 - 00:53:07:09 | If you see that someone is on the notice of proposed removal, please understand, at least here at CVTA, a the largest association of these high quality training providers, the bulk of those that we have seen affecting members have been administrative and clerical deficiencies. And if you see some a school that you trust and no listed on the notice of proposed removal list, do do not, I would not personally recommend treating that as some indicator of any sort of problem other than something that is either an error or literally just a missing piece of paper. |
| 00:53:07:12 - 00:53:30:16 | And if you see them listed for three weeks, four weeks, you see all their locations listed. You’re saying, what? What on earth is going on over there? Nope. They might have had just one clerical error at one location that is now ballooned in FMC mind to the entire company wide status, and they’re not waiting because they’re having trouble remedying that deficiency. |
| 00:53:30:16 - 00:53:56:16 | They’re waiting because Fmcsa has simply not gone back and and said, yes, we accept your response. So, you know, evaluate these folks on the criteria that you have been. But certainly, I think reach out to these training providers when you see something on the tour that that gives you pause. The great schools out there, hopefully, that you’ve been hiring from to begin with, are going to respond immediately and say, look, here’s what it’s about. |
| 00:53:56:17 - 00:54:08:21 | It’ll be off very soon. This is just something we’re all going through right now as Fmcsa, really figures out how to optimize this system. |
| 00:54:08:23 - 00:54:29:21 | And then in terms of the providers, a lot of the things we heard about earlier, if you, you know, FM, CSA really wanted, wanted this training provider registry to be a place where, you know, consumers could find training. And so people listed, well, I can do a hazmat endorsement, I can do a passenger endorsement. Well, maybe that school wasn’t actually doing hazmat endorsements at that actual location. |
| 00:54:29:21 - 00:54:58:05 | So when the auditor shows up, they don’t have it in the curriculum in place, ready to provide. Boom. You’re on the list, right? So don’t advertise any program. You’re not operating. Remove any ones that you’re not operating. Run test audits with all the Vin numbers, the curriculum, the yard specifications, the student documentation files, and critically designate, if you’re a provider, designate one individual to correspond with external organizations. |
| 00:54:58:05 - 00:55:21:03 | Because if you get on the list, chances are you’re going to be on there for 3 or 4 weeks. Okay. And the chances are all of your locations are going to be on there for 3 or 4 weeks, and it’s going to be a stress test, and you’re going to be getting a lot of emails from external stakeholders, state certifying folks, the Workforce Innovation and Opportunity Act funding, state certifying boards, hiring carriers. |
| 00:55:21:05 - 00:55:51:12 | You need one point, one point of contact to that. And if there is only one thing as a training provider, you here today ensure that you collect trainees signatures on the 49 CFR 38707, a form that document that is inferred in the final rule literally is the cause for just a vast majority of people even being on the notice of proposed, removal category. |
| 00:55:51:12 - 00:56:10:08 | And boy oh boy, if you encounter an emergency removal, I would consult with an attorney immediately because that is going to be a very different battle, and you’re going to need someone who really can assemble that for you and, and be corresponding appropriately and decide what actions to take. |
| 00:56:10:10 - 00:56:36:15 | All right. So where does it go from here? Okay. So operation driver Training three. Here’s the thing. Operation Driver Training two theoretically had an end date, but they’ve they’ve kept cooking. Look, we give credit enormous credit to the secretary to FMC administrator bars for doing this enforcement, especially to all the of the outstanding career staff that is working hard at the Office of Safety Programs. |
| 00:56:36:18 - 00:57:15:02 | Also the Chief safety Officer, Steve Dowling, all these folks are really trying to make sense of this and have it work effectively so that if people are listed in this zero tolerance tolerance environment, that there is a pathway for, you know, being de-listed off of that. But also, folks, there are some really bad people out in this space, CDL mills, two day training providers that are really just trying to make a quick buck off of defrauding some poor person who not that they’re financially poor, but some some person who is really just I want to be a truck driver. |
| 00:57:15:02 - 00:57:35:07 | Remember folks, trucking is an amazing career. Shout out to my brother Mike, who’s a wonderful truck driver here in Virginia. It’s an awesome career. We want people to become truckers in the United States of America. We got to make sure that we get rid of these bad actors. So hats off to Fmcsa for working hard to optimize this. |
| 00:57:35:09 - 00:57:55:18 | But it is the case that there’s going to be some challenges. We want to see due process. We want to see some better predictability. We want to see perhaps a hierarchy of structures. Right. You’re not going to get on the know list for having some minor clerical or administrative deficiency. We really want to see states continue to play a substantive role in this. |
| 00:57:55:20 - 00:58:26:12 | But I think going forward, we’re going to see, CSA tackling third party training providers, the third party testing, excuse me, providers, folks who are, you know, imbued with the authority of the state to conduct the skills test. I think we’re going to see FMC as a go after those. I think we’re going to see FM, CSA begin to target enforcement of individuals that are listing, you know, zero to very few hours of training on their inputs into the training provider registry. |
| 00:58:26:15 - 00:58:56:11 | So these things are moving in the right direction. We just are really relying on the professionalism of the career staff and the leadership at CSA to continue to work to get it right. With with these federal rules and the enforcement regimes, we always see them taking time, but we we’d like to see them optimize this soon. And we do know that there will likely be a rulemaking to end the dreaded self-certification process onto the team that got us here. |
| 00:58:56:13 - 00:59:26:12 | So we’re looking forward to seeing that. No precise update on when that will come, but you can be you can rest assured that a and publicly funded schools are very much asking for that every time we have the chance. That’s great insight, Andy. 222 points. I want a question to you. One one a point. I know that administrator bars had set a high bar of success for himself in terms of new rule makings. |
| 00:59:26:14 - 00:59:54:12 | For 2026, I don’t know if he’ll get everything in to this year like he originally articulated, but to your point, I suspect we see that rulemaking you just mentioned soon, right? It’s not before the year is out. It’s probably, I would suspect, in early 2027, in conversations I’ve had with him, he seems very aware that his opportunity to implement important and systemic change is limited. |
| 00:59:54:15 - 01:00:29:02 | Right. And the window has, you know, one day may close. And he does seem committed to safer roadways, more reliable, safer, better stakeholders in the transportation industry. So I think you’re right to call out that proposed rule making as something we can see on the horizon. But the question to you is, do you anticipate more of these sort of desk audits, where they’re looking through the data to try to find bad, you know, training providers or maybe testing providers? |
| 01:00:29:04 - 01:01:10:01 | retrospect. Right. Versus boots on the ground surveys or audits, which seem to be the prior enforcement priority. Yeah. So if they I think so, and I think the one that I referenced in terms of if you’re inputting zero hours of behind the wheel training onto the a student that you’ve trained and putting that into the TPR, if CSA decides, as they did with ten English language proficiency violations, that that is a metric that is worthy of scrutiny, that that is in itself an indicator of a material deficiency. |
| 01:01:10:03 - 01:01:38:14 | Then certainly they could do a desk audit for every location that’s entering zeros onto the TPR. I think that the state, the third party testing probably will align a bit more with, I’m not sure there is. There’s an as easy a ready made algorithm or data point that could be funneled back into, you know, a sense of what what malfeasance was going on at a location. |
| 01:01:38:14 - 01:02:02:00 | So I think that there’ll be more boots on the ground when it comes to the third party testing. And I think it will be more a desk audit in terms of those numerical components of the hours training. That’s great, great insight. So we’ve run over time. I’m not surprised. I think I could listen to Andy talk about this topic for another hour. |
| 01:02:02:02 - 01:02:38:19 | You. Yeah, that was very kind. So let’s just kind of wrap this up here with some key takeaways and closing thoughts. Right. And the benefit and the challenges webinars. We’re talking to a very broad and diverse audience, you know from a training provider perspective. And we hope that you understand what steps you can take to prevent FM, CSA enforcement against your against your company, how to think differently about emergency removals versus notice of proposed removals, and understand the way in which FMC is pursuing this latest enforcement wave such that you can prepare your business in advance. |
| 01:02:38:20 - 01:03:06:14 | Or alternatively, you know how to respond if you are unfortunately unfortunate enough to receive such a notice as part of this latest wave, or any kind of forthcoming wave from a motor carrier standpoint, from a hiring of a driver standpoint, again, you know, you should be able to trust a trust the state licensing agencies and their processes. You aren’t in the business of second guessing whether state A, B, or C has properly licensed the driver. |
| 01:03:06:15 - 01:03:33:15 | But just because you don’t have regulatory risk doesn’t mean you don’t have a liability risk. And in this rapidly changing environment, with the rapidly changing transportation industry, you know, I sometimes, you know, say it’s hunting season for plaintiff’s attorneys. So much scrutiny has been put on each part of our transportation industry, from brokers to motor carriers to shippers. |
| 01:03:33:15 - 01:04:14:09 | And you can hear these even in the remarks of Secretary Duffy himself, when he talks about safety on the roadways and addressing and tackling, you know, cargo theft and freight fraud, that plaintiff’s attorneys are always looking for a new angle to bring your company into a matter when, unfortunately, there’s an incident and understanding where how your drivers are trained, understanding the process by which they ended up on your doorstep, and evaluating both the hiring of them, but also to supervising of them afterwards, who go a long way to protecting your business from unnecessary lawsuits and minimizing that liability and risk in the future. |
| 01:04:14:11 - 01:04:40:11 | And that also applies for brokers and shippers who might not be directly working with these drivers just because there’s an intervening company. The motor carrier, for example, doesn’t mean you can ignore the process. But this is where good contracts make good partners make clear expectations and responsibilities for your transportation partners such that you are protecting yourself from liability. |
| 01:04:40:11 - 01:05:18:08 | And of course, this applies to public transit agencies as well. The last big takeaway it’s something that Andy and I are always talking about is this is not the end. Expect more. We’ve already talked about this third enforcement initiative, but the second one is going to be ongoing. And I am confident that Secretary Duffy and administrative bars mean what they say when they are on a mission to bring safety to America’s roadways and to root out the bad actors that they think have hurt the American truck driver, have endangered the American public and have created a risk within our transportation and supply chain networks. |
| 01:05:18:10 - 01:05:40:24 | Andy, any other final thoughts or closing remarks? I think that was just a great a great summary, and I really, Greg, appreciate having had the chance. I appreciate all the conversations we we have, but it really fun and I think useful to have put our heads together for this discussion in this way. I think this output here and the conversation were outstanding. |
| 01:05:40:24 - 01:06:05:05 | And I really hope folks, you know, take a lot away from it and can proceed accordingly in this interesting environment. Well, I agree, and I can’t thank you enough for your time. I’m not sure not being as technically savvy as I should be. I’m not sure if we have any questions in the chat. Let me see if I can pull that up. |
| 01:06:05:07 - 01:06:25:04 | But, I do want to encourage everyone here who’s listening or everyone who gets a chance to listen to this after the fact that, if you have questions and if you’re interested in understanding this issue more, you know, please don’t hesitate to reach out to myself or reach out to Andy. I apologize, Andy. I just put you on blast there. |
| 01:06:25:05 - 01:06:53:10 | That’s right. Yes. Odds and end questions about this. About this? No, I’m here to help. Really? Because this is a this is a. So, it can be very confusing, very puzzling. You know, x, Y and Z. What do I do? Especially we deal with training providers all the time who are up and coming. I mean, this sort of established CVTA members themselves have been seeking this oversight for so long. |
| 01:06:53:10 - 01:07:12:20 | But there are a lot of people in this space that are not CVTA members that really need assistance. We try to to help them make sense of it. But then this whole universe of people that you engage with in with is is a whole different universe because they’re really not thinking about this stuff really on a daily basis, perhaps at all. |
| 01:07:12:24 - 01:07:38:14 | And so we can love to help them understand it as well. I think that’s right. And I think as long as people like you, Andy and myself, or as long as entities like CVTA and other stakeholders in the transportation industry understand or work together to approach the same issue from different angles, we can really help provide the clarity needed for transportation companies and consumers. |
| 01:07:38:16 - 01:08:14:13 | In navigating, you know, this rapidly changing time, this, this industry, which, you know, it’s been only some 18 months, I think, since Secretary Duffy has taken taken office. And yet we feel like we’re in a whole new world, so we can’t thank CVTA enough for it to advocacy. And thank you enough, Andy, for your time here and shedding insight and hopefully, well, hopefully and not hopefully we’ll have an opportunity to do this again to talk about the latest development and the continued improvement in the industry. |
| 01:08:14:15 - 01:08:17:01 | I look forward to it. Great. Thank you so much. |
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