Letters, Petitions and Comments
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.
CVSA Petitions FMCSA to Amend Requirements in § 391.11(b)(2)
October 22, 2025
On Oct. 22, CVSA petitioned FMCSA to amend the Federal Motor Carrier Safety Regulations by requiring that noncompliance with English language proficiency requirements in § 391.11(b)(2) result in a driver being placed out of service.
CVSA Submits Comments on Improvements for Special Permits and Approvals Renewals
September 2, 2025
On Sept. 2, CVSA submitted comments in response to PHMSA’s NPRM seeking stakeholder feedback on the agency’s proposal to allow a grantee to file an application to renew a special permit or approval any time before its expiration date rather than requiring the application to be filed 60 days in advance.
CVSA Submits Comments on Carrying Electronic Certificate of Registrations
September 2, 2025
On Sept. 2, CVSA submitted comments in response to PHMSA’s NPRM seeking stakeholder feedback on proposed revisions to the HMRs to allow motor and vessel carriers the option to carry their PHMSA certificate of registration in electronic form.
CVSA Submits Comments on Allowing Continued Use of Special Permit Packagings
September 2, 2025
On Sept. 2, CVSA submitted comments in response to PHMSA’s NPRM seeking stakeholder feedback on the agency’s proposal to allow for the continued use of packagings authorized under a manufacturing special permit for duration of the useful life of the package.