Operational Policy 4 - Hazardous Materials/Dangerous Goods Inspection Certification (Number of Inspections)

Regarding CVSA OPS Policy 4 under Hazardous Materials/Dangerous Goods Inspection Certification: the policy states the initial 16 North American Standard Hazardous Materials/Dangerous Goods Inspections must be completed on non-bulk quantities with a certified inspector. This is an issue for probable cause states, such as Michigan, who cannot complete inspections on any and all commercial motor vehicles without cause. By changing the policy to reflect any amount of hazardous material, other than cargo tank, this would ease the burden of finding probable cause on carriers who are highly regulated and who may not require placards, making those initial 16 inspections difficult to find.

This policy creates concerns for probable cause States. Hazardous materials traffic stops (on other than cargo tanks) are difficult to find probable cause to stop and limiting the initial 16 inspections to non-bulk quantities only causes strain on these agencies. Especially when you consider a non-bulk quantity in a van box trailer may not require placards and therefore the officer has no way of knowing if hazmat is even carried. Furthermore, it puts more stress on the carriers who may be getting stopped for minimal violations (i.e. plate lamp inoperable during daylight hours). This causes a rift between our agency and the industry even when both parties have the best intentions. Additionally, under the new CVSA General Hazardous Materials course, there will be a larger portion dedicated to bulk quantities of hazmat. It would benefit the new inspectors to have a variety of inspections on both bulk and non-bulk quantities with a certified inspector.

Requesting to change CVSA OPS Policy 4 under Hazardous Materials/Dangerous Goods Inspection Certification to show "any amount other than cargo tank" as opposed to the current "non-bulk quantities" for initial certification.