Operational Policy 4 - Assignment of Supervised Initial Inspections for Certification

The question is: Who gets credit for the original 32 inspections conducted by a trainee under the supervision with a coach. FMCSA's opinion is that the new inspector is not certified, and the inspections cannot be uploaded under the trainee's signature, so the coach would have to sign and receive the credit for the inspections. Because FMCSA has adopted CVSA Operational Policy 4 as the basis for its investigator/inspector/auditor certifications, the agency wants to keep the guidance to our field personnel in line with CVSA’s position. FMCSA thinks that, in order for an inspection to count and be uploaded, the inspection has to be completed by a certified inspector. Since the student is not certified, the coach needs to sign, and therefore gets the credit. With that thinking, that means that FMCSA is requiring our new investigators to perform 64 Level 1 inspections for certification: 32 with the coach and then 32 for which they can get credit. How does that compare to CVSA’s position? Or, is that decision left up to the jurisdiction?

This is an important issue that needs to be resolved, as FMCSA's performance year runs from June 1 through May 31. We would like to have this, and the sister request, resolved as quickly as possible for implementation in the new performance year. FMCSA's Q and A on this issue to its field personnel are being sent to CVSA, as instructed.

FMCSA recommends that the 32 inspections performed under the supervision of a coach be signed by and credited to the certified inspector. After completion of the initial 32, then the 32 needed for maintenance be prorated, depending on the month within the certification cycle the initial inspections are completed. For FMCSA, the recommended responses to this, and the sister request on proration of inspections, have been submitted as required, and should be part of this record.