Level III Inspection Procedure - Level III Hazardous Materials Inspections

This request is for the removal of certain non-driver hazardous materials inspection items from the CVSA Level III Inspection criteria. Except for the inspection of shipping papers, which are in the driver's possession, additional inspection items, such as placards and labels, are not driver-related and should not be included in a Level III Driver/Credential-only roadside inspection.

In order to eliminate confusion in conducting a CVSA Level III Driver/Credential-only roadside inspection, and to align these inspections with criteria and data collection relative to the Federal Motor Carrier Safety Administration's (FMCSA) Compliance, Safety and Accountability (CSA) Safety Measurement System (SMS), certain inspection items listed in the Level III Inspection Criteria pertaining to hazardous materials are not driver or credential-related. These items, which in many instances require an inspector to enter the cargo-carrying area of a commercial vehicle, go beyond the scope of a driver/credential inspection. Even when recorded on a Level III inspection report, violations related to these inspection items are not counted in CSA-SMS towards a motor carrier's score.

The following inspection items contained in Step 6, should be removed from the conduct of a CVSA Level III Driver/Credential-only roadside inspection: STEP 6 CHECK FOR PRESENCE OF HAZARDOUS MATERIALS / TRANSPORTATION OF DANGEROUS GOODS PLACARDS Check for presence of placards (if applicable), but use caution even if no placards are displayed. LEAKS, SPILLS AND UNSECURED CARGO When HM/TDG are present, take necessary precautions with leaks, spills or unsecured cargo. MARKINGS Check for appropriate markings on Cargo Tanks and Portable Tanks. Cargo Tanks and Portable Tanks shall display markings on an Orange Panel or Placard. They indicate the ID number of the HM/TDG. There are exceptions to this rule. LABELS When HM/TDG packages are visible, check for appropriate labels (if required). In addition, the following excerpt from Operational Policy 04 pertaining to HM/DG Inspections should be amended as follows: Hazardous Materials/Transportation of Dangerous Goods Inspection Prerequisite: Inspectors shall hold a Certificate of Proficiency for conducting at least one of the North American Standard Levels of Inspection_Delete the following: (Levels I through V); Add: (Levels I, II, V). This amendment should be consistent throughout the document.