Operational Policy 20 - Instruction of Enhanced Program

The CVSA Enhanced Inspection Program (EIP) is currently administered exclusively by CVSA staff or their designees. Industry stakeholders are concerned about whether this centralized model can remain effective at scale. The trucking industry operates in a dynamic, high-variability environment, characterized by: -Seasonal freight surges -Rapid workforce turnover -Accelerated hiring during demand spikes -Geographic shifts in operations These operational realities require the ability to adjust staffing and certification quickly. However, the current EIP course is offered inconsistently, with limited frequency. Compounding the issue, CVSA has not permitted on-site training at carrier facilities, forcing carriers to incur additional travel, lodging, and administrative costs. A certification system that cannot scale up or down becomes a constraint on industry responsiveness. Rigid scheduling assumes a static industry—but trucking is anything but static. When course availability is limited: -Employers cannot align certification with operational workload cycles -Inspectors may wait months for available seats -Carriers cannot forecast certification pipeline capacity -Hiring, promotion, and deployment timelines become constrained The resulting gaps create a subtle but tangible impact on inspection coverage, compliance continuity, and workforce planning. Greater delivery flexibility would preserve training integrity while improving workforce scalability and compliance continuity.

For context, one of the largest U.S. carriers operates 13,618 power units and 16,466 drivers (FMCSA-SAFER, 2/2026). It is reasonable to assume that such a carrier could require 1,000 CVSA-certified inspectors over time. As inspection demand grows and workforce volatility increases, certification delivery models must evolve. Maintaining rigorous standards while introducing modular and scalable delivery options is critical to strengthening inspection coverage, preserving enforcement capacity, and sustaining long-term safety outcomes. Proposed Solutions to Maintain Standards While Reducing Burden: 1. Blended Learning (a) Deliver theory online with in-person practical skills (or 32 inspections with another certified inspector mirroring Roadside Inspection Program), minimizing time away from active duty. 2. On-Site Delivery (a)Offer courses at carrier facilities to reduce travel, lodging, and associated costs. (b)This also allows the carrier to train more people at one time. 3. Train-the-Trainer Model (a)Certify select personnel within carriers to deliver training internally. (b)Expands training capacity, reduces travel, and accelerates onboarding while maintaining standards. 4. Flexible Scheduling (a)Publish annual course calendars, allow rolling enrollment, and offer multiple sessions to align with fluctuating operational needs (understanding that course enrollment will fluctuate according to industry needs). Strategic Benefits -Maintains rigor and uniformity of certification standards -Preserves inspection coverage by minimizing workforce downtime -Reduces travel costs and administrative burden -Supports scalability for seasonal demand and workforce volatility -Strengthens overall safety capacity at scale without compromising compliance

Considering the operational realities outlined above, we respectfully request that CVSA consider modifications to the Enhanced Inspection Program (EIP) delivery model to better align with industry needs while preserving certification integrity. Specifically, we request that CVSA: 1. Allow flexible delivery options (a)Support modular, blended, and/or on-site training to reduce travel burdens and minimize disruption to industry. 2. Implement a train-the-trainer pathway (a)Certify select carrier personnel to conduct internal training, expanding capacity and accelerating inspector onboarding without compromising standards. 3. Increase scheduling predictability and frequency (a)Publish annual course calendars, offer rolling enrollment, and provide multiple sessions to align certification availability with workforce demand and operational cycles. We urge CVSA to consider these modifications as a proactive measure to ensure that certification processes remain efficient, scalable, and responsive to the dynamic needs of the industry.