Operational Policy 20 - Inspection Intervals

The CVSA Enhanced Inspection Program (EIP) began in February 2023 with the first certified inspectors trained, and since then, enforcement and industry stakeholders have worked together to refine the standard for efficiency and effectiveness. After 2+ years of inspections, it has become clear that the current 24-hour inspection mandate warrants reevaluation. Under the EIP, each Commercial Motor Vehicle (CMV) or combination change requires a full inspection (that closely mirrors a roadside level 1 inspection) every 24 hours. At scale, this frequency imposes significant operational and financial burdens while providing minimal improvement to overall safety. For Autonomous Vehicles (AVs), this requirement could create extended downtime and higher infrastructure costs, potentially slowing adoption. To put this in context: There are approximately 13 million CMVs in the U.S. FMCSA reports around 3 million roadside inspections annually, meaning the average CMV is inspected by a certified CVSA roadside inspector no more than once per year on average. One of the largest US Carriers has approximately 13,618 Power Units (FMCSA-SAFER 2/2026). This same carrier was subject to 10,550 Vehicle inspections over the past 24 months. 10,550 inspections ÷ 13,618 power units = 0.775 inspections over 24 months 0.775 inspections ÷ 2 years = 0.387 *Roughly 39% of the fleet was inspected ONCE per year, assuming even distribution *OR each truck gets inspected about once every 2.6 years on average By contrast, the current EIP would require AV trucks to undergo 365 inspections per year at the 24-hour interval by certified CVSA inspectors and still must comply with FMCSRs for Pre/Post Trip inspections. Adjusting the inspection interval can deliver multiple benefits without compromising safety: -Operational Efficiency: Reduces congestion, queueing, and scheduling bottlenecks -Labor Savings: Lowers staffing costs and inspector requirements significantly -Capital Efficiency: Reduces facility and lane footprint, minimizing infrastructure investments -Alignment with Industry Norms: Brings inspection frequency closer to conventional CMV fleet PM practices. Example: 24-Hour Interval Assumptions: -100 truck fleet dispatching from a single hub in an (8-hour shift/timeframe) -Inspection time = 0.5 hours per combination -(260) workdays per year -Each inspector will work 8-hour shift -Large carriers at times, can expect 80-150 trucks dispatched every 8-hours This requirement would: -Demand 100 inspections per 8-hour shift, totaling 18,250 annual hours -Require 11 certified inspectors to conduct inspections above 85% productivity -Require 7 dedicated inspection lanes, resulting in 12,600 sq ft of dedicated facility space -Operate at 89% daily lane utilization, creating queueing and throughput risk with any delay causing cascading dispatch issues. -Introduce high operational rigidity, as every truck must cycle through the inspection process daily Inspector Requirement: 8 hours X 0.85 time worked = 6.8 hours per day worked per inspector 6.8 hours per day X 260 working days per year = 1,768 hours per year / per inspector Labor Hours: 100 trucks per (8-hour shift) X 0.5 hours per inspection = 50 hours per shift of inspections 50 hours per shift X 365 days per year = 18,250 hours/year (For every 8-hour shift) 18,250 total hours/year ÷ 1,768 hours per year/inspector = 10.3 inspectors needed (11 inspectors minimum per shift) Lane/Bay Capacity (8-hour shift): Each inspection = 0.5 hours Each lane/bay can accommodate 16 inspections per lane per day (theoretical max) But that assumes: -Zero transition time -Zero paperwork delay -No inspector variance -No vehicle defects discovered Realistically, 85–90% utilization is the ceiling before congestion forms. Demand: 100 inspections per shift Required lanes (minimum math) 100 trucks ÷ 16 inspection per lane = 6.25 (7 lanes minimum) Capacity: 7 lanes × 16 inspection per lane = 112 inspections/day Utilization: 100 trucks ÷ 112 inspections averaged per shift = 0.89 89% utilization At this level: -Small delays cause queue buildup -Inspector sick day = immediate bottleneck -One truck needing repair stalls flow -Weather or dispatch bunching creates surge congestion -Dispatch reliability drops Bottom Line: The 24-hour inspection interval forces the fleet into a high-throughput processing model that must run near capacity every single day. Facility Space Impact: Assumption 1,500 sq ft per inspection lane & +20% for support 7 lanes/bays X 1,500 sq ft. = 10,500 sq ft. 10,500 sq ft. + 2,100 sq ft. = 12,600 sq ft. Total space needed for inspections per hub

To continue meeting industry demands without compromising safety, we are requesting an increase in the current 24-hour enhanced inspection interval to 96 hours. Extending the interval will maintain the highest safety standards for automated vehicle (AV) operations while easing operational burdens on the industry. Extending the interval to 96 hours is still effectively equivalent to conducting approximately 91 defect-free Level 1 roadside inspections per year, reinforcing a strong safety performance record. All Enhanced Inspections (EIPs) will continue to be performed by certified (CVSA) inspectors. Additionally, carriers operating AVs remain subject to pre-trip and post-trip inspections as required by the FMCSRs, ensuring ongoing vehicle condition assessments between enhanced inspections. Each vehicle component (tractor and trailer) will be inspected on its own 96-hour cycle. Any trailer that exceeds its 96-hour interval must undergo an enhanced inspection by a certified CVSA inspector prior to operation — a change that will help raise baseline trailer safety throughout the industry. Interval inspections conducted between the 96-hour enhanced inspections must be performed by personnel trained to conduct pre-trip and post-trip checks at a level comparable to FMCSA’s Entry-Level Driver Training (ELDT) found in Appendix A to Part 380—Class A—CDL Training Curriculum: Unit A1.1.3 Pre- and Post-Trip Inspections This unit must teach the driver-trainees to conduct pre-trip and post-trip inspections as specified in 392.7 and 396.11, including appropriate inspection locations. While there is no minimum number of instructional theory hours, curriculum topics must be covered and trainees must demonstrate proficiency, earning at least 80 % on assessments for relevant units such as pre- and post-trip inspections. Documentation demonstrating proficiency shall be maintained for term of employment and one year thereafter. This is similar to that of FMCSA Inspector Qualifications in 396.19 & Brake Inspector in 396.25. This requirement ensures that interval inspections are thorough, consistent with industry's best practices and remains auditable by FMCSA and the States for compliance. With an increase in the 24-hour interval, the standard will become simplified as a result by combining the different columns (in-transit & dispatch defects). This simplification will ensure that all defects found during any inspection will be recorded and repaired prior to launch and will eliminate any confusion. This will also aid in certification/in-service testing, ensuring effective and efficient implementation. This Change Will Metric 24-Hour 96-Hour Change (%) Inspections per shift 100 25 4x reduction in throughput Inspection Labor Hours 18,250 hrs. 4,563 hrs. 75% reduction Certified Inspectors Required 11 Insp. 3 Insp. 73% reduction Required Inspection Lanes 7 Lanes 2 Lanes 71% reduction Facility Footprint 12,600 sq ft 3,600 sq ft 71% reduction Daily Lane Utilization 89% 78% 11% reduction Operational Flexibility Low High ---- Safety Coverage Full Full ---- The 96-hour interval allows the fleet to operate in a stable, buffered maintenance model. This allows for carriers to: Group inspections -Ensure dispatch reliability -Reduce number of CVSA enhanced inspectors -Reduce number of lanes/bays needed -Reduce facility footprint -Decrease daily lane utilization, ensuring operational flexibility -Can fit into current PM programs Lastly, individual states like Texas have/or considered authorizations/operating authorities for AV operations. This also ensures that Pre/Post Trip Inspections as well as EIP are conducted appropriately and free from defects prior to dispatch. For Example: Texas Sec.545.459 ENFORCEMENT (a) If the department determines that an automated motor vehicle operating under an authorization issued by the department under Section 545.456 is not in safe operational condition and the operation of the vehicle on a highway or street in this state endangers the public, the department shall provide to the authorization holder for the vehicle a notice of intent to: (1) suspend, revoke, or cancel the authorization issued under this subchapter for the vehicle; or (2) impose restrictions on the operation of the vehicle.

Increase the 24-hour interval for the EIP to a 96-hour interval. This change allows for the training of interval inspectors as well as EIP inspectors. This change would also result in combining (in-transit/dispatch defects) into a single column.