Operational Policy 4 - Hazardous Materials Certification

Operational Policy 4 prohibits combining different types of inspections for initial certifications. For instance, Level I inspections cannot be combined with HM inspections, thereby needing a total of 48 inspections (32 Level I's and 16 HM) for initial certifications. Afterwards for maintenance, these inspections may be combined. For reference, see Operational Policy 4: Hazardous Materials/Dangerous Goods Inspection Certification Prerequisite: Inspectors shall hold a Certificate of Proficiency to conduct North American Standard Levels I, II or V Inspections. In order to conduct inspections involving hazardous materials/dangerous goods, the inspector shall: • Complete a CVSA- approved North American Standard Hazardous Material/Dangerous Goods Inspection Course and pass the CVSA-approved written exam with a score of 80% or higher. If an inspector fails the initial test, there may be one re-test. • In addition to the training and testing requirements above, the inspector trainee must complete at least 16 North American Standard Hazardous Materials/Dangerous Goods Inspections on non-bulk quantities with a certified inspector who will evaluate the trainee inspector for knowledge of the regulations, proficiency in the inspection process and documentation of violations. These inspections should be completed as soon as practicable, but no later than six months after passing the written exam. Inspections conducted for initial certification cannot be combined.

Upon graduation from the FMCSA academy, new Safety Investigators have completed NAS A and B and Basic HM classroom courses. They now need to perform inspections with instructors, and under the present system, they will need 48 inspections to become initially certified for CVSA Level I and HM Inspections. This appears to be redundant as combining inspection types for maintenance is allowed. So, combining inspection types for initial certifications should also be allowed for better use of personnel and resources.

FMCSA requests that the phrase: "Inspections conducted for initial certification cannot be combined" be removed from Operational Policy 4 wherever it appears.