Operational Policy 4 - Maintenance of Certification for Basic Hazardous Materials

This issue is for both the HM and Training committees and regards Operational Policy 4, specifically the Maintenance of certification for Basic HM. There seems to be a conflict as to what constitutes maintenance of certification under Ops Policy 4 and the reference chart and its examples. HM/DG maintenance on Page 12 states that an inspector must: perform a minimum of 8 North American Standard Level I, II or V Inspections annually on vehicles containing bulk (if certified) and/or non-bulk quantities of hazardous materials/dangerous goods. The key words seem to be (if certified). To us that reads that a bulk quantity of HM would count towards the general HM certification only if the inspector were bulk/cargo tank certified. The chart and corresponding Example 16 says: Example #16: A Level I inspection on a 5 axle truck-tractor and semi-trailer vehicle combination. The semi-trailer is a specification cargo tank hauling hazardous materials/dangerous goods and is inspected by a hazardous materials/dangerous goods certified inspector with no cargo tank certification. The chart then shows that the L1 Cargo Tank inspection would count towards the HM certification, although not CT/Bulk certified.

Ops Policy 4 has a discrepancy between the maintenance Basic HM/DG requirements and the reference chart and its corresponding Examples (16). This needs rectified so that inspectors have a clear understanding of what is required to maintain their Basic HM certification The danger is that an inspector who is specifically trained to conduct non-bulk HM/DG inspections could conduct 8 Cargo Tank inspections to maintain certification and not stay conversant with the basic HM inspection procedures relating to non-bulk packages which they are specifically trained for.

We would request that the training and HM committees reach agreement on what constitutes a valid inspection for the maintenance of the Basic HM?DG certification. Either clean up the reference chart and corresponding example to show that only a cargo tank/Bulk HM by a certified CT/Bulk inspector count towards the basic HM, or change the language in the maintenance of basic HM/DG section to remove the words (if certified) and thereby allow any L1, L2, or L5 HM inspection count towards the basic HM inspection.