Operational Policy 4 - Prorating of Inspections

May the number of inspections needed for maintenance of certification be prorated following completion of the 32 required inspections conducted under the supervision of a certified inspector for initial certification? It is FMCSA's position that Operational Policy 4 states under GENERAL MAINTENANCE OF CERTIFICATION: Member jurisdictions shall track the maintenance of inspector certification annually. For example, the annual period may be based upon a calendar year, federal fiscal year, state/provincial/territorial fiscal year, inspector anniversary date or another date that is convenient to the member jurisdiction. The number of annual certification inspections required to maintain certification may be prorated to allow jurisdictions to track all certified inspectors on the same anniversary date. Since maintenance of qualification requires 32 Level I inspections be performed during the performance year, the number of inspections required to be performed by a newly-certified investigator/inspector/auditor, who has completed his/her 32 Level I inspections under the direction of a certified inspector depends on the month in which he/she has completed the requisite supervised inspections.

FMCSA requests resolution of the issue as soon as possible, as the agency's performance year runs June 1 through May 31, FMCSA would like to be able to provide guidance to its field personnel for implementation in the next performance year. This issue, along with its sister issue on assignment of inspections, need to addressed concurrently in order for proper implementation of Operational Policy 4 within FMCSA.

FMCSA recommends that proration be allowed in order for new inspectors/investigators/auditors complete initial training and maintenance of certification for the current performance year in a timely and efficient manner. Please refer to FMCSA's supporting document on its recommendation to prorate within our agency.