Operational Policy 4 - Definitions Clarification

This is a multi-layered issue as it pertains to the initial certification process and training for "new inspectors". The following issues all stem from unclear definitions, lack of defined terms and vague wording within the sections that follow. The issue that always presents itself with new trainees is; Who gets the “credit” for the initial (9, 16, 32) training inspections, audits or investigations? The trainee or the trainer? New inspectors who just complete the classroom portion tend to think they should receive credit under their name simply because once they complete the initial inspections, audits, or investigations they are all set. Furthermore, agency administrators are using this method as an opportunity to easily track progress of a trainee within the inspection program being used. It needs to be abundantly clear that these trainees are NOT certified and that all inspections “SHALL or MUST” be drafted under and credited to the certified inspector (Field Training Officer-FTO). The trainee will then be required to complete an additional 8, 32 inspections after the initial inspections or audits with the trainer to fulfill the maintenance requirement. Now because there is no specific training procedure outlined in the ops policy, the definition of “certificate of proficiency” or its process for obtaining doesn’t exist. This has led to subsequent issues such as; inconsistency with violations, incorrect individual interpretations, improper supervisory guidance, improper training or lack thereof and the confusion that the initial 9,16 or 32 inspections would go under the trainee’s name. There is no explanation of what the “certificate of proficiency” actually is and how it should be used or implemented. Who can determine proficiency? What level of experience should that person have? There is no guidance on how training should be conducted other than with a “certified inspector within 6 months from the written exam”. The new inspectors are given 6 months to complete 32 inspections. Well if they are completing one a week or two every three weeks or all 32 at the 5 month mark, is there really any level of training being done? There is no guidance or requirement for agencies to complete and maintain inspector training files or folders of certification.

The need is to clarify the existing definitions. Add additional definitions and terms within ops policy 4 to make it abundantly clear to "new" inspectors and their administrators that new inspectors are not "certified" until they complete all required roadside inspections or audits with a certified inspector also know as a “Field training officer (FTO)”. This to further ensure consistency, reduce the possibility of confusion among new inspectors and administrators. Confused administers results in unnecessary research.

Clarifying terms/ adding definitions of Certified Inspector Current Definition- Certified Inspector – A current enforcement official from a member jurisdiction who maintains a certificate of proficiency authorizing them to conduct CVSA North American Standard Inspections for the specific discipline. This includes, but is not limited to, local, municipal, county, state, provincial, territorial or federal government agencies. (Add: This enforcement official would also be considered a Field Training Officer (FTO) to inspectors working towards their initial 9 audits or,16 or 32 inspections) OR (Add: A current enforcement official from a member jurisdiction who received and maintains a certificate of proficiency upon completing the required initial 9 audits, 16 or 32 inspections with a Field Training Officer (FTO), authorizing them to conduct CVSA North American Standard Inspections for the specific discipline. Define- Certificate of proficiency-A document or certificate issued to a new inspector (trainee) upon the completion of all the required initial inspections (e.g. 9 audits or 16 GHM or 32 inspections). This shall only be issued by a supervisor or a certified training inspector who meets all the requirements outlined in the definition of a Field Training Officer. A supervisor who does not meet the requirements of a field training officer is not authorized to issue this certificate. The person issuing the certificate of proficiency should be a person who has not conducted any inspections or audits with the trainee during their training. This is to ensure the new inspector has received adequate training and is conducting inspections pursuant to the inspection procedures outlined by CVSA or audits according efotm. Define-Field Training Officer (FTO)- A current enforcement official from a member jurisdiction who maintains a certificate of proficiency authorizing them to conduct CVSA North American Standard Inspections for the specific discipline or audits. This person must exhibit proficiency in the respective discipline themselves for which they are training. In addition, inspectors training a trainee for a Part A or a Part A/B certification, the FTO shall exhibit at a minimum, proficiency in Parts A and B and General Hazmat. An FTO must also be a certified inspector for a minimum of 5 years in the disciplines for which they are training. (For example, the FTO must be certified in all Parts A/B and GHM for at least five 5yrs before they can be considered to train a new trainee inspector. If they are only certified in Parts A/B for five years and GHM for 2years they do not qualify). Define-Trainee: An enforcement official from a member jurisdiction who “has not obtained” a certificate of proficiency authorizing them to conduct CVSA North American Standard Inspections for the specific discipline. This includes, but is not limited to, local, municipal, county, state, provincial, territorial or federal government agencies. Define Training folders: A folder which contains a certificate of completion, certificate of proficiency for each discipline, and any continued education completed. After each certification discipline this note appears. It reads as such: NOTE: The initial (9/16/32) inspections for the trainee should be conducted and documented by the trainee in the presence of the training inspector. The inspection shall contain the name and identification number of both the trainee and the certified inspector on the report. Inspections must be signed off by a certified inspector. The following changes should be made: NOTE: The initial (9/16/32) inspections for the trainee should be conducted and documented by the trainee in the presence of the training inspector “under the training inspector’s (FTO) name.” The inspection “report” shall contain the name and identification number of both the trainee and the certified inspector. “on the report.” Inspections must be signed off by a certified inspector “only.” “All initial training inspections are credited to the certified inspector (FTO).” Establish a training program. Narrow the training window for new inspectors or require more inspections with an FTO. The focus should not be on maintenance. It should be focused on training for the first year. Establish a training folder requirement. In this folder there should be the inspectors' certificates of completion, certificates of proficiency, inspections conducted with an FTO, a list of motor carriers audits were conducted on, etc. Lastly, require participating agencies to create a training folder for each inspector.