US Transit Bus Operator Records: CDL P Endorsement, DOT Medical and FTA Testing

Three records, three rulebooks

A transit operator’s records look familiar to anyone who keeps trucking driver files. The citations are where they differ.

The licence: CDL class plus the P endorsement

Under 49 CFR Part 383, a bus is a commercial motor vehicle if its weight rating puts it in Group A or B or, below that, if it is designed to carry 16 or more passengers including the driver (383.5). Operating one takes the passenger (P) endorsement, earned with a knowledge test and a skills test (383.93). A Class A does not replace it: 383.91(c) lets a Group A holder drive Group B and C vehicles only with the requisite endorsements.

The skills test is taken in a passenger vehicle of the group the endorsement will cover (383.117(b)). Testing in a Group B bus brings a restriction against Group A passenger vehicles (383.95(e)), and testing without air brakes brings an air brake restriction (383.95(a)). A first P also requires entry-level driver training from a provider on the Training Provider Registry (383.71(e)(5)) and a commercial learner’s permit first (383.25(d)). The skills test cannot be taken in the CLP’s first 14 days, and a CLP holder with the P may not carry passengers other than examiners, auditors and inspectors, other trainees and the supervising CDL holder (383.25).

Agencies decide where the licence fits in hiring. TriMet’s bus operator page, checked October 9, 2026, says applicants need no CDL to apply and that it provides paid licence training, but an Oregon or Washington commercial learner’s permit is required before starting employment. The CDL tests belong to the state, not the employer; this guide to telling a hiring assessment from a licence test sorts out which invitation is which.

Medical certification: the standard and who it binds

The standard sits in Part 391 Subpart E. The examiner must be on the National Registry of Certified Medical Examiners (391.43(a)), and a driver is re-examined at least every 24 months, or every 12 for conditions such as insulin-treated diabetes (391.45).

Since June 23, 2025, a CDL or CLP holder with a current certificate no longer has to carry it (391.41(a)(2)(i)(B)), and where an electronic record and a paper copy disagree, the electronic record controls (391.41(a)(2)(iv)). FMCSA’s October 8, 2026 notice (91 FR 64454) says Alaska is the only state that has not implemented this change; from October 12, 2026, drivers licensed anywhere else, and their employers, can no longer rely on a paper certificate as proof for any period.

Whether Part 391 binds a given operator is a separate question. 49 CFR 390.3T(f)(2) excepts transportation performed by a state or its political subdivisions from the rules in that subchapter, Part 391 included. The CDL rules still apply (383.3(b)), and every CDL holder self-certifies an operating category to the state, from non-excepted interstate to excepted intrastate (383.71(b)(1)). The posting says whether the agency requires a medical examiner’s certificate; ask which self-certification category the job falls under.

Drug and alcohol testing: FTA Part 655 is its own program

49 CFR Part 655 covers recipients of FTA assistance under 49 U.S.C. 5307, 5309 or 5311 and their contractors (655.3), using the Part 40 procedures (655.2(b)). Coverage follows the duty, not the licence: operating a revenue service vehicle, operating a non-revenue vehicle that needs a CDL, controlling dispatch, maintaining revenue vehicles and carrying a firearm for security are all safety-sensitive (655.4). A dispatcher with no CDL can be covered; Part 382 starts from the CDL and does not apply to employers and drivers required to comply only with Part 655 (382.103(d)(1)).

Differences that show up in a file, as far as the two texts go:

• Pre-employment drug test. Both require a verified negative first. FTA also requires one before a transfer into a safety-sensitive job and after 90 consecutive days away outside the random pool (655.41). Part 382 lets an employer skip it for a driver recently in a compliant program (382.301(b)); 655.41 has no such exception.
• Pre-employment alcohol test. Optional under both, but an FTA result must be below 0.02 before the employee starts (655.42(e)), against less than 0.04 under 382.301(d)(5).
• Post-accident. After a nonfatal crash, Part 382 tests a driver only if cited for a moving violation arising from it (382.303). FTA tests the operator after any nonfatal accident unless the employer can completely discount the operator’s performance, and must document a decision not to test (655.44).
• Training. FTA requires at least 60 minutes of drug-awareness training for every covered employee (655.14); Part 382 requires educational materials for drivers (382.601).
• Clearinghouse. Drivers who perform only FTA-regulated functions are exempt from it. An FTA employer whose drivers also do FMCSA-regulated work, such as weekend charter, must query for those drivers (FMCSA Clearinghouse FAQ).

Changing jobs: how testing history follows a driver

With the employee’s written consent, a new DOT-regulated employer must ask previous DOT-regulated employers from the past two years for alcohol results of 0.04 or higher, verified positives, refusals, other violations and return-to-duty records (49 CFR 40.25). Without the answers or a documented good-faith effort, the employee must stop safety-sensitive work after 30 days.

Trucking to transit: only FMCSA-regulated employers may query the Clearinghouse, so FMCSA says a trucking carrier answering a 40.25 request from an FTA employer must release the most recent Clearinghouse query result it ran on the driver.

Transit to trucking: FTA violations are not reported to the Clearinghouse, so a motor carrier must request three years of that history directly from the transit employer (391.23(e)(4)(ii)) and keep the response in the driver investigation history file (391.53(b)(2)).

Worked example (hypothetical)

Dana, an invented driver, holds a Class A CDL with no endorsements, drove for an FMCSA-regulated carrier until last month, and applies to a city transit agency that receives FTA funds.

1. Posting: does the agency want the P before hire or train for it, and does it ask for a medical examiner’s certificate?
2. Licence: entry-level training, a CLP carrying the P, at least 14 days, then a skills test in a bus. A Group B bus adds a restriction against Group A passenger vehicles.
3. Medical: the trucking certificate may still be current; Dana checks that the self-certification category fits the transit job.
4. History: Dana consents to the 40.25 request, and the trucking carrier answers with its latest Clearinghouse query result.
5. Testing: a Part 655 pre-employment drug test with a verified negative before the first safety-sensitive duty, despite last month’s Part 382 random pool.

Records checklist for the applicant

• CDL front and back showing class, endorsements and restriction codes.
• CLP and training completion details if the P is new.
• Medical examiner’s certificate details and the self-certification category on file.
• Every DOT-regulated employer in the past three years, with addresses and dates.
• Any return-to-duty and follow-up testing documents.

For agency-specific steps, these city-by-city US bus operator guides point to each agency’s official recruitment source, and a stage-by-stage application checklist ties these documents to each hiring step.

Sources checked October 9, 2026

• 49 CFR Part 383: 383.3, 383.5, 383.25, 383.71, 383.91, 383.93, 383.95, 383.117.
• 49 CFR Part 391 Subpart E: 391.41, 391.43, 391.45; 391.23 and 391.53.
• 49 CFR 390.3T and 91 FR 64454.
• 49 CFR Part 655: 655.2, 655.3, 655.4, 655.14, 655.41, 655.42, 655.44.
• 49 CFR Part 382: 382.103, 382.301, 382.303, 382.601; 49 CFR 40.25.
• FMCSA Clearinghouse FAQ and the TriMet bus operator page.

FAQ

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