Operational Policy 4 - Level III Certification - Passenger Carrying Vehicles

Currently, inspectors that are level III certified are not able to complete level III inspections on Passenger Carrying Vehicles without receiving training and certification as a PCVI inspector. This creates a potential loophole for OOS violations to be discovered and not able to be addressed and placed out of service without be PCVI certified. Example a motorcoach is encountered during a minor traffic crash. When examining documents the driver does not possess the proper CDL and endorsement to operate the motorcoach. If we do not possess PCVI currently we cannot complete a level III inspection and place the driver out of service.

As serious safety conditions exists with the given scenario. Given the constraints this drives inspectors to not report correctly on the vehicle being inspected and/or letting the vehicle continue on because PCVI inspectors are not available. There is a need for NAS A certified inspectors to be able to inspection PCVs as with any vehicle. This would require the applicable hours of service regulations to be address in NAS Part A but this was previously the training standard.

Request that Operational Policy 4 be revised to allow for Level III inspections to be completed on PCVs if the inspector is certified as a level III inspector by completed NAS A. This will require the addition of the PCV HOS regulations being re-added to the NAS Part A course.