Letters, Petitions and Comments
CVSA Submits Comments on ATA’s Minimum Age for Drivers Exemption Application
February 27, 2026
On Feb. 27, CVSA submitted comments on the American Trucking Associations’ (ATA) application for a five-year exemption to allow motor carriers that previously participated in FMCSA’s Safe Driver Apprenticeship Pilot program to continue onboarding and training drivers under the age of 21.
CVSA’s Requests Extension for Comment Period on Grote RCW Exemption Application
February 24, 2026
On Feb. 24, CVSA requested an exemption on the application from Grote for exemption from the requirement that exterior lighting devices on CMVs be steady burning.
CVSA and CVBMC Submit Comments on Applying the FMVSS to ADS Vehicles
February 13, 2026
On Feb. 13, CVSA, on behalf of the Commercial Vehicle Brake Manufacturers Council (CVBMC), submitted comments in response to NHTSA’s request for stakeholder feedback on its research project evaluating the FMVSS to determine how they apply to innovative vehicle designs, particularly those incorporating ADS, as well as potential challenges these vehicles may face in demonstrating conformance.
CVSA Sends Letter to FMCSA on Enforcement of the 'K' Restriction for CMV Drivers
February 3, 2026
On Feb. 3, CVSA sent a letter to FMCSA requesting enforcement guidance regarding the definition of “interstate commerce” within the context of the intrastate license (K) restriction requirements, which limit a CMV driver to intrastate-only operations.
CVSA Submits Comments on 2025 Level VI Inspection Out-of-Service Criteria Incorporation by Reference
December 17, 2025
On Dec. 17, CVSA submitted comments to FMCSA’s notice of proposed rulemaking to update the incorporation by reference of CVSA’s “North American Standard Level VI Inspection Procedures and Out-of-Service Criteria for Commercial Highway Vehicles Transporting Transuranics and Highway Route Controlled Quantities of Radioactive Materials as defined in 49 CFR Part 173.403.”
CVSA Sends Letter to FMCSA Requesting NRII Enforcement Guidance
December 5, 2025
On Dec. 5, CVSA sent a letter to FMCSA requesting that FMCSA provide guidance to CMV enforcement officials that a paper copy of a valid Medical Examiner’s Certificate is permitted to demonstrate compliance with the applicable requirements during a roadside inspection and motor carrier safety audits and investigations until all issues associated with integrating the state driver’s license administrations’ systems with the medical examiners’ systems are resolved and all states have fully complied with the requirements of FMCSA’s 2015 Medical Examiner’s Certification Integration final rule (commonly referred to as NRII).
CVSA Sends Letter Requesting FMCSA Publicly Release ELP Enforcement Guidance
November 6, 2025
On Nov. 6, CVSA sent a letter to FMCSA requesting that the agency publicly release its enforcement guidance document related to evaluating a driver’s compliance with the English language proficiency (ELP) requirements in Title 49 Code of Federal Regulations (CFR) § 391.11(b)(2), FMCSA Enforcement Policy: English Language Proficiency Under 49 CFR § 391.11(b)(2) (MC-SEE-2025-0001).
Petition to Update Operational Policy 4 Incorporation by Reference
October 28, 2025
On Oct. 26, CVSA petitioned FMCSA to amend the incorporation by reference of CVSA’s “Operational Policy 4: Inspector Training and Certification” to reflect the newest edition, which was revised on Sept. 25.
Petition to Update Level VI Out-of-Service Criteria Incorporation by Reference
October 27, 2025
On Oct. 27, CVSA petitioned FMCSA to amend the Hazardous Materials Safety Permit regulations to update the incorporation by reference of “North American Standard Level VI Inspection Procedures and Out-of-Service Criteria for Commercial Highway Vehicles Transporting Transuranics and Highway Route Controlled Quantities of Radioactive Materials as defined in 49 CFR Part 173.403” to reflect the newest edition, which will be effective April 1, 2026.
CVSA Sends Letter to FMCSA on Guidance for Documenting and Enforcing Unsafe Driving Violations
October 22, 2025
On Oct. 22, CVSA sent a letter to FMCSA requesting an update to Attachment A of Policy MC-SEE-2021-005 – Revised Guidance for Documenting and Enforcing Unsafe Driving Violations to reflect the current violation codes.