Operational Policy 5 - Post-Crash Inspections

As written, Operational Policy #5 allows an inspector to complete a post-crash inspection at levels I, II, III, or V. Still, the inspector may not be able to inspect all required components of an inspection type as a result of the collision, which contradicts other inspection level minimum requirements (i.e., If more than 20% of the brakes cannot be inspected, then the inspection would not be considered a Level I Inspection and shall be identified as a Level II Inspection). Failing to meet all required inspection requirements when selecting an inspection type during a post-crash inspection would either cause the inspector to violate other Operational Policy #5 inspection requirements and/or expose them to potential litigation if confronted about why they selected a Level I inspection but did not complete all Level I inspection requirements. If the inspector downgraded to a Level II inspection due to a lack of brake measurement, but still completed other steps, it is only required on a Level I inspection. Currently, Operational Policy #5 states that a post-crash inspection should be selected when the crash meets the definition of a crash in 390.5. There are many instances where an inspector should/may select the post-crash box when the 390.5 definition has not been met. There is currently a wide inconsistency in DVER reporting practices occurring due to a lack of guidance on what to select when the collision does not meet the definition of a crash in 390.5. An update to Operational Policy #5 would establish standardized definitions and reporting requirements for all post-crash inspections.

With inconsistent DVER reporting practices during post-crash inspections, all gathered data is skewed. Additionally, with jurisdictions using a variety of inspection software, a standardized approach to selecting inspection types in post-crash situations would assist CVSA and FMCSA in compiling reports for informational and training purposes and enable more professional, accurate data collection. The update to Operational Policy #5 would clearly define the DVER requirements for a collision that does not meet the definition of a crash in 390.5. It would also clearly outline the DVER requirements for a crash that meets the definition of 390.5. Finally, it would simply explain when an APCI (Level IX) inspection should be completed to align with the requirements of Operational Policy #4.

Recommended update to Operational Policies 5, see attached.