Interpretations Section Needed

Many of the items listed in the CVSA OOSC are being misinterpreted by inspectors and utilized differently than intended. Memos and bulletins have been issued to provide guidance and clarification on OOSC items; however, calls for clarification continue. To help alleviate confusion and prevent improper use of the criteria, there needs to be an interpretive section listed in the back of the OOSC. This section will, in the long run, also service as a means to reduce committee work on requests and changes, clarification, and guidance on the criteria due to confusion or improper interpretation.

Confusion on the proper application of certain out of service conditions is an on-going problem. Methods have been used to address this problem to include emphasizing it in course training materials, refreshers and reminders at in-service training, clarification and guidance memorandums and bulletins, and actual changes and notations add to the OOSC. However, despite these actions, confusion does not subside. A uniform criteria cannot truly exist when critical items such as tire and brake OOSC are being interpreted on varying levels and degrees. An example is dual wheel out of service conditions. While it is trained that a dual wheel set will be out of service if both tires meet the same or combination of out of service items, inspectors are reading the notation in the OOSC for dual wheels and interpreting it to mean that both tires must meet the same OOS condition.

Discussion of adding an interpretation section to the back of the criteria to be done by the appropriate committees at the Annual Conference. Upon agreement of the committees, that the section be a valuable addition to the OOSC, each committee can then appoint the key players for that committee to an ad-hoc committee to start developing and collecting interpretations on all facets of the criteria. These will then be submitted to the committees for approval to eventually be included in the back of the criteria.