The Driver Fitness BASIC is one of seven categories in FMCSA's Safety Measurement System. It covers whether drivers are qualified to operate commercial vehicles. ELP is just one of many violation types in this category.
Let's see how ELP stacks up against its peers.
What's in the Driver Fitness BASIC
The Driver Fitness BASIC includes violations related to:
- Medical certification: Valid medical card, physical qualifications
- CDL status: Valid license, proper endorsements, restrictions
- English proficiency: ELP requirements per 391.11(b)(2)
- Driver qualifications: Age, experience, other regulatory requirements
All these violations compete for attention in the same percentile ranking that determines whether you trigger FMCSA intervention.
Comparing Violation Severity
Not all violations carry equal weight. FMCSA assigns severity points based on crash risk correlation:
| Violation Type |
Severity Weight |
OOS Rate |
| Operating without valid medical certificate |
5 |
75% |
| No valid CDL |
8 |
95% |
| CDL - Wrong class for vehicle |
5 |
90% |
| English Language Proficiency |
5 |
28% |
| Medical card expired (less than 30 days) |
2 |
15% |
| No medical card in possession |
1 |
5% |
| Improper CDL endorsement |
4 |
80% |
ELP has a moderate severity weight (5)—significant but not the highest in the category. The same weight as medical certificate violations and wrong CDL class.
ELP's Unusual OOS Pattern
Here's what's interesting about ELP: despite the moderate severity weight, its out-of-service rate (28%) is notably lower than comparable violations.
Compare to violations with similar severity:
- No valid medical certificate: 75% OOS
- Wrong CDL class: 90% OOS
- ELP violation: 28% OOS
This gap suggests that many ELP violations are borderline cases where inspectors note the concern without placing the driver OOS. But the violation still counts against your CSA score.
Frequency of Violations
Looking at how often each violation type appears nationally:
| Violation Type |
Annual Occurrences |
% of Driver Fitness |
| Medical certificate issues |
~85,000 |
52% |
| CDL violations |
~45,000 |
28% |
| ELP violations |
~26,000 |
16% |
| Other driver qualification |
~7,000 |
4% |
ELP represents about 16% of all Driver Fitness violations—less common than medical and CDL issues, but still a significant contributor to the BASIC.
Impact on BASIC Percentiles
A single ELP violation's impact on your percentile depends on:
- Your fleet size: Smaller fleets feel each violation more
- Total inspections: More inspections dilute individual violations
- Violation age: Recent violations count 3x more than old ones
- OOS status: OOS violations get an additional multiplier
For a small fleet (10-20 trucks) with limited inspection history, a single ELP OOS violation can move your Driver Fitness percentile by 10-15 points.
The Intervention Threshold
FMCSA intervention begins at specific percentile thresholds. For Driver Fitness:
- Warning letter: Above 65th percentile
- Investigation trigger: Above 80th percentile
- Prioritization for audit: Above 90th percentile
If your carrier hovers near these thresholds, even one ELP violation can push you over. Conversely, if you're well below threshold, a single violation has less immediate impact.
Prevention ROI by Violation Type
When allocating compliance resources, consider which violations offer the best prevention ROI:
Medical Certificates
Easy to prevent: Calendar reminders, tracking systems. Clear documentation. Most carriers have this under control.
CDL Violations
Easy to prevent: License verification at hire and periodic rechecks. Standard HR practice.
ELP Violations
Often overlooked: Many carriers don't have a consistent process. Assessment tools are less mature than other compliance areas. High opportunity for improvement.
Close the Gap in Your Compliance
You probably have medical card tracking handled. CDL verification too. But ELP? ELPReady fills that gap with the same rigor you apply to other driver qualifications.
Add ELP to Your Process
Strategic Implications
For Fleets with High Driver Fitness Percentiles
If you're already struggling in this BASIC, every violation type matters. But ELP may be your easiest win—it's often the area where carriers have the weakest processes in place.
For Fleets with Low Percentiles
Don't get complacent. A cluster of ELP violations (from a hiring wave of underqualified drivers, for example) can move you from safe to at-risk quickly.
For All Fleets
The best time to address ELP compliance is before you have violations on your record. Unlike medical cards that expire on predictable schedules, ELP issues surface at random—during any inspection, any time.
Key Takeaways
- ELP carries a severity weight of 5—moderate but significant
- 28% OOS rate is lower than comparable violations, suggesting many borderline cases
- ELP represents ~16% of all Driver Fitness BASIC violations
- Single violations hit small fleets harder than large ones
- ELP is often the least mature compliance area for many carriers
- Prevention ROI is high because it's frequently overlooked