Operational Policy 4 - Trainee Certification

Can a Level I or Level II inspection, completed and signed by the certified inspector FTO, count towards a Trainees 32 Level III inspections as long as the trainee completes the 13 steps as outlined in the CVSA inspection procedure? This is specific for a new inspector trainee seeking a Part A only certification. Can they use a Level I or level II inspection that was completed with a certified inspector towards their required 32 inspections? Currently it appears they cannot. The Ops Policy seems to only allow Level III inspections to count. By not allowing, it has the potential of bad behavior and training. An inspector may look the other way at a violation that would only be drafted under a level I or II simply to get the new trainee an inspection.

Scenario 1: While conducting said 32 inspections, the FTO notices a violation (flat tire for example) which would otherwise require the truck to be placed out of service. Knowing the violation(s) are out of service items, the FTO changes the inspection level from a Level III to a Level II or I for the purposes of placing the truck out of service. When these inspections are upgraded to the next level, would the trainee still get credit towards their initial 32 inspections for certification for that inspection? They are still conducting all the same 13 steps as a level III and would be populating violations as such; the only difference is that the level of inspection had to change because other violations existed. Or MUST the inspections be only Level III’s and none of the other levels? Scenario 2: If the Trainee is working with an FTO, this FTO just so happens to also be working on their 32 Level 1’s for the purposes of their yearly maintenance, the Trainee completes the 13 steps for a level III inspection and while the certified inspector completes a level I, the new inspector is completing the report or simply observing, could the Trainee still receive credit towards their initial 32 level III’s having completed all the steps? Or MUST the inspections be only Level III’s and none of the other levels? This is also a great training opportunity for the trainee to learn if they are attending Part B in the future. Scenario 3: Once the trainees complete their inspections and are considered “certified”, they are likely to stop or come across HM, on their own. Trainees should be expose to these trucks, so they understand what to do or the license requirements that are needed. An HM inspection is conducted as a Level II for GHM certified inspectors. Therefore, in this case it would make the inspection a Level II. Again, could the trainee’s get credit for completing the steps for the Level III and the certified inspector would get credit for the GHM inspection. This is not to say, go out and do all GHM inspections. At some point during the training inspections the new inspectors may be asked to stop whatever truck they want. If they stop a truck with HM, should we be doing a HM inspection or simply Level III. The understanding is that a HM carrier does not get credit towards their CSA score in the HM category unless it is a level II where the HM was inspected.

Add the following paragraph to Ops policy 4 under Level III (Part A) Certification: NOTE: Any trainee seeking a Level III (Part A) certification, may count a Level I or Level II inspection, conducted with a certified inspector, towards the initial 32 required inspections as long as the trainee conducts the initial 13 steps outlined in the CVSA Level III inspection procedure. However, to obtain certification as a Level III (Part A) inspector, no more than 25% of the initial (32) certification inspections may be other than Level III (e.g., 8 of 32, may be Level I or Level II). No other level of inspection shall count towards Level III certification. Any Level I or II inspection shall have notes as to why a higher-level inspection had to be completed in lieu of the intended Level III inspection, such as any vehicle Out of service Item.