Operational Policy 4 - Level I Certification for Certified Compliance Review Investigators and/or New Entrant Safety Audit Investigators

Ops 4 reads North American Standard Inspections – Levels I through V To maintain certification to conduct North American Standard Level I through Level V Inspections, an inspector shall in addition to the “General Maintenance of Certification” section of Operational Policy 4, perform a minimum of 32 North American Standard inspections of the inspector’s highest certified level annually, preferably 8 inspections per quarter for which the inspector alone takes credit. With more state personnel being involved in on-site safety investigations and safety audits their time to conduct roadside inspections becomes more and more limited. With issue becoming more prevalent, the current wording of Ops 4 becomes a hindrance and can effect quality of inspections as safety investigators and auditors try to cram inspections into their limited time frame away from safety investigations or audits.

With the way the maintenance of certification requirements read, these CR and NE safety investigators and auditor, who are also Level I certified, could be sacrificing quality for quantity when attempting to obtain the required number of Level I inspections to maintain certification with the limited amount of non-investigation time they have. CR or NE safety investigators review more driver qualification documents and more RODS per investigation then a roadside inspector does during a Level 1 inspection. As long as CR or NE safety investigator is verifying compliance with driver qualification and hours of service requirements along with a Level V inspection, the investigator has covered all 37 steps in the NAS Level I inspection at sometime within an on-site investigation that includes DQ files and RODS.

I would like to change Ops 4 for maintenance of certification, to read as follows. New second paragraph under “North American Standard Inspections – Levels I through V” to read. For certified compliance review investigators and/or new entrant safety audit investigators, a North American Standard Level V Inspection(s) that is conducted in conjunction with an on-site investigation which includes the investigation of driver qualification requirements and hours of service compliance, shall count towards North American Standard Level I maintenance of certification.