Operational Policy 4 - Inspector In-service/Refresher Training

I am requesting that there be a mandatory in-service/refresher training requirement for all certified inspectors. I do not believe at this time that there is a CVSA requirement that their inspectors are subject to any type of in-service/refresher training requirement after they are initially certified by their respective agency. The majority of the states do have some type of training required by their inspectors although their isn't any uniformity. What I am requesting is that there be a standardized amount of time set aside for in-service/refresher training.

It is vitally important to motor carriers that inspections be uniformily consistent from one state to another because of how the carriers are judged under CSA. Prior to CSA, the inconsistencies between states was not as critical because the carriers were judged based on the OOS criteria. The SMS methodology of scoring places point values on every aspect of the on-road performance of the driver, truck and/or truck-trailer combinations. Every carrier that operates throughout North America, understands that it is imperative that every inspector is up to date with the regulations and consistent in citing violations on Aspen inspection reports.

What I am requesting is a minimum of 32 hours per 12 month period where each CVSA/FMCSA certified inspector is subject to in-service/refresher training. As a retired FMCSA inspector, I am aware that FMCSA personnel are not certified by CVSA, but I believe that they should also be subject to the same requirements as the CVSA certified inspectors. I am also proposing that 8 hours of the 32 hour period be devoted to changes to the FMCSR, and specifically to the Electronic Logging Devices (ELDs) that are becoming more wide spread every day and mandated by the new NPRM. The ELD training should include the course that FMCSA is developing that will be completed during the summer of 2014, designed specifically for roadside inspectors. This requested in-service/refresher training should be included in the states CVSP and the cost should be covered under the states basic grant and funded by FMCSA in all likelyhood with the 80/20 split.