2.4 Training Vehicle and Dual-Control Equipment Requirements

Two Vehicle Standards, One Fleet

Any school teaching the driver education program is subject to both regulations. COMAR 11.23.01.22 is the baseline; COMAR 11.23.02.33 layers the program-specific equipment on top.

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Required Equipment (COMAR 11.23.02.33G)

In addition to other safety laws and regulations, a training vehicle shall be equipped with:

1. Dual brake pedals;
2. Dual clutch pedals if the vehicle is not equipped with an automatic transmission;
3. Reflectors or emergency triangles; and
4. Instructor mirrors that shall:
   • (a) provide an unobstructed view of traffic conditions to the rear of the vehicle from the instructor's seat;
   • (b) be affixed inside the vehicle in a fashion that eliminates blurring due to mirror vibration and reduces the possibility of unintentional changes in mirror adjustment; and
   • (c) include a second mirror that is affixed to the right passenger side mirror housing, provides an unobstructed view of traffic to the rear and right rear from the instructor's seat, and is not affixed to the mirror surface or otherwise obstructing the driver's use of the right passenger side mirror.

Read (c) closely. The instructor's supplemental right-side mirror clips to the housing, not to the glass. A stick-on convex mirror pasted onto the student's mirror face fails the regulation because it obstructs the student's own use of that mirror.

Dual-control functionality at inspection (§C(6))

The certified school shall ensure the instructor dual brake — and the clutch, if the vehicle has a standard transmission — is:

• (a) physically in the vehicle and operational at the time of the annual Maryland State Inspection; and
• (b) operational by producing the same effect as the manufacturer installed original equipment brake or clutch when applied.

A dual brake that merely moves is not compliant. It must brake like the factory pedal.

Comfort and fit equipment (§H)

The certified school shall make available for use in all training vehicles, approved by the Administration: pedal extensions for the brake, gas, and clutch pedals, and seat cushions to ensure proper seating position. These are accessibility items — a shorter student must be able to reach the controls while seated correctly relative to the airbag.

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Fleet Administration (COMAR 11.23.02.33C-E)

The certified school shall:

1. Provide an adequate number of training vehicles to allow each course participant to complete the course;
2. Maintain motor vehicle liability insurance in the Transportation Article, §17-103 amounts;
3. Service, clean, and maintain training vehicles on a regular schedule;
4. Have all training vehicles inspected annually by a licensed State inspection station;
5. Only use a vehicle that has passed the annual Maryland State Inspection;
6. Immediately remove from service a training vehicle with any condition not in compliance with Maryland State Inspection standards;
7. Affix signs to both sides of the vehicle containing the name and telephone number of the certified school;
8. Affix to the rear of the vehicle, in letters not less than 3 inches high, the words "Student Driver"; and
9. Keep the vehicle registration card and a copy of the insurance certificate in the glove compartment at all times.

A copy of the annual State inspection certificate goes to the Administration within 1 business day and the original is filed at the school's business office. Except for a new vehicle titled in the past year from a manufacturer's certificate of origin, an uninspected vehicle may not be used for behind-the-wheel instruction (§D).

The 8-model-year limit in §F has exactly one exception: a training vehicle containing adaptive equipment for drivers with disabilities.

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The Drivers' School Baseline (COMAR 11.23.01.22)

For a school that gives driving instruction but is not delivering the driver education program, the requirements are leaner but still binding:

• Training vehicles shall be titled and registered in the name of the driving school unless §C applies or the MVA approves otherwise (§B);
• Maintain §17-103 liability insurance; service, clean, and maintain on a regular schedule; have the vehicle inspected annually; immediately remove from service any vehicle out of compliance with Maryland inspection standards; and not use a vehicle for instruction unless it has passed the annual inspection, except for a new vehicle titled in the past year from a manufacturer's certificate of origin (§C);
• Submit a copy of the annual inspection certificate to the MVA within 1 business day and file the original at the business office (§D);
• Keep the registration card and insurance certificate copy in the glove compartment (§E);
• Remove immediately, at MVA direction, any signs or other devices the Administration determines may interfere with safe operation (§F); and
• Notify the MVA in writing within 1 business day of the addition or removal of a training vehicle, providing the year, make, tag number, and VIN, plus insurance and inspection certificates if a vehicle is being added (§G).

Worked scenario

Case. A certified school buys a nine-model-year-old sedan in excellent condition, installs a professionally fitted dual brake, passes State Inspection, and letters "STUDENT DRIVER" across the rear in 4-inch characters.

Analysis. The dual brake and signage comply, but the vehicle cannot enter the driver education fleet. COMAR 11.23.02.33F bars a training vehicle more than 8 model years old unless it contains adaptive equipment for drivers with disabilities. Condition and inspection status do not cure the age limit.