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When do your Mechanics need a CDL?
sponsored by CTTS/Safety Products
The Commercial Drivers License or CDL as it is called, came about as a result of the Commercial Motor Vehicle Safety Act of 1986 passed by Congress in 1986 and fully implemented on April 1, 1992.
The primary purpose of The Act was to standardize commercial driver testing throughout the United States, prevent multiple licenses, establish better tracking of driver violations, establish disqualifications and penalties and apply them consistently from one state to another, provide for better trained drivers and to reduce accidents and injuries.
The CDL requirements pertain to ALL drivers who operate:
1.) A vehicle with a GVWR in excess of 26,000 lbs
2.) A vehicle designed to transport more than 16 or more persons including the drivers
3.) A vehicle carrying hazardous material in such a quantity that hazardous material placards are required.
Their are a few exceptions to the CDL requirement. Those exception are:
1.) Emergency personnel such as fireman when performing duties to preserve life, or property.
2.) Farmers driving their own equipment and hauling their own produce and, generally not driving more than 150 miles from the farm, and
3.) Active duty military personnel operating commercial motor vehicles for military purposes
So when does a person have to have a CDL? The requirement states under 49 CFR 383.3; "The rules in this part apply to every person who operates a commercial motor vehicle (CMV) in interstate, foreign or intrastate commerce, to all employers of such person and to all States."
So the question arises; Does a mechanic need a CDL license and, if so, when does he need it? To answer that question we need to know the DOT interpretation of "interstate" and "intrastate" commerce. According to the DOT, commerce, when applied to the CDL regulations, means any act involving the driving of a commercial motor vehicle by a company representative, when such company is regulated by the DOT, which furthers the transportation of goods involved within a state or from state to state.
So does a mechanic who has worked on a truck and then takes that truck out for a test drive need a CDL? The answer is yes provided the truck meets the definition of a commercial motor vehicle and is driven on a public roadway. The act of driving the CMV on a public roadway for the purposes of testing the vehicle, is in itself a furtherance of commerce.
What if the driver just drives across a public street in order to test the truck on a private track.....is a CDL needed then? Again, the answer is yes......the act of crossing the street caused the vehicle and the mechanic to become involved in either interstate or intrastate commerce.......even though the street was only 24 feet wide! Basically, anytime a mechanic operates a CMV on a public street or roadway he must have a CDL.
Ok.... you say, he needs a CDL.........but what type of CDL does he need..... and does he need any endorsements? The answer to those questions are determined by the type of equipment. Essentially, the regulation states that the driver (in this case the mechanic) must have the type of license and endorsements for the type of vehicle he is driving and for the material which is on the vehicle. In other words.......if the truck is a tractor-trailer, the mechanic is required to have a Class A CDL with a combination vehicle endorsement. If that vehicles happens to be loaded with Class A Explosives, the mechanic would be required to a Hazardous Material endorsement.......and, since most tractor-trailers are equipped with air brakes.........he would also have to take the air brake test and have the air brake restriction removed from his commercial drivers license. So, in this example the mechanic must take the following CDL tests before be permitted to drive this vehicle:
May not seem fair.....and some states have tried to obtain exemptions for mechanics...but in every case the DOT has denied the requests and in every State these regulations exists for mechanics.
Does a mechanic need a CDL even when he NEVER goes on a public street or roadway.....or, for that matter, what about a regular driver who drives everyday but drives only on private property...........is a CDL ever needed? The answer will surprise you and I'll cover it in my next article. See you then!
CTTS/Safety Products, Ltd.
CTTS/Safety Products produces CDL training manuals and video tapes for the transportation industry. They have been producing such material since 1989. In addition, they also produce safety training material and videos including substance abuse training and forklift training to comply with applicable DOT and OSHA regulations. They can be reached at (800) 869-3926 or on the internet at http://www.SafetyAtCTTS.com