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Letters, Petitions and Comments

  • Petition to Clarify What Qualifies as a Valid CDL

    April 4, 2023

    On April 4, the Commercial Vehicle Safety Alliance (CVSA) petitioned the Federal Motor Carrier Safety Administration (FMCSA) to amend Title 49 CFR § 383.25(a)(1) to clarify what qualifies as a “valid commercial driver’s license (CDL)” for the purposes of accompanying a commercial learner’s permit (CLP) holder for behind-the-wheel training in a commercial motor vehicle (CMV).

  • Petition to FMCSA Regarding Wheel Components

    March 29, 2023

    On March 30, the Commercial Vehicle Safety Alliance (CVSA) petitioned FMCSA to amend CFR § 393.205 to clearly identify several hazardous conditions that correspond to regularly observed conditions of wheel components that result in high risk of a crash or breakdown.

  • CVSA Files Comments Regarding ADS-Equipped CMVs

    March 20, 2023

    On March 20, CVSA filed comments on FMCSA’s Supplemental Advanced Notice of Proposed Rulemaking (SANPRM) seeking input on which factors the agency should consider in amending the Federal Motor Carrier Safety Regulations to establish a regulatory framework for commercial motor vehicles (CMV) equipped with Level 4 and Level 5 automated driving systems (ADS).

  • Request for Clarification Regarding PHMSA Record Keeping Requirements Interpretation #22-0133

    February 10, 2023

    On Feb. 10, CVSA sent a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), requesting the agency reconsider its Jan. 17, 2023, interpretation #22-0133, issued to Usher Transportation...

  • Petition to Amend Title 49 CFR § 392.60 DOT Regulatory Guidance

    February 3, 2023

    On Feb. 3, CVSA submitted a petition to FMCSA asking the agency to amend the DOT Regulatory Guidance to Title 49 CFR § 392.60 – Unauthorized persons not to be transported to require written...

  • CVSA Submits Updates to 396.3(a)(1) Petition

    February 2, 2023

    On Feb. 2, CVSA submitted an update to the Alliance’s March 30, 2021, petition to FMCSA asking the agency to amend Title 49 CFR Part 393 of the FMCSRs by incorporating changes in Subparts B, C, E, F, G and J...

  • Comments to Clarification to the Applicability of Emergency Exemptions NPRM

    January 25, 2023

    On Jan. 25, CVSA submitted comments to FMCSA’s Dec. 8, 2022, notice of proposed rulemaking (NPRM) seeking to narrow the scope of regulations from which relief is provided automatically...

  • Letter Asking FMCSA to Consider Changes to New Entrant Safety Audit Program

    January 6, 2023

    On Jan. 6, CVSA sent a letter to FMCSA asking the agency to consider a number of improvements to the New Entrant Safety Audit Program, including...

  • Petition to Update Level VI OOSC Incorporation by Reference

    January 6, 2023

    On Jan. 6, CVSA submitted a petition to FMCSA requesting an amendment to the hazardous materials safety permit regulations to update the incorporation by reference of CVSA’s “North American Standard Out-of-Service Criteria (OOSC)...

  • Comments to Unique Electronic Identification of CMVs ANPRM

    November 21, 2022

    On Nov. 21, CVSA submitted comments in response to FMCSA’s ANPRM exploring whether the agency should amend the FMCSR to require every CMV operating in interstate commerce to be equipped with electronic identification technology...

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