CVSA Inspections: Understanding and Preparing for Them
The Commercial Vehicle Safety Alliance (CVSA) is a nonprofit association made up of various governmental (local, state, federal, provincial, and territorial) officials and industry representatives. The CVSA makes recommendations that are designed to provide common standards for roadside inspections in the United States, Canada, and Mexico. Those standards are used by safety inspectors. The CVSA also certifies safety inspectors.
None of us love to go through inspections of any kind, but roadside inspections benefit all of us and our safety by making sure equipment is in good working order and drivers are complying with hours-of-service regulations. Similar to an annual medical exam, this process is somewhat unpleasant, but important for long-term health.
There are eight different inspection levels. Refer to a previous blog post, How to Stay DOT Compliant, for an outline of those roadside and non-roadside inspections. Another blog post, FMCSA New Entrant Audits, describes the things all new carriers can expect during their initial audit. That is a good place to start to make sure you have a solid foundation and are prepared for future inspections.
The most common inspections are Level 1, Level 2, and Level 3. These inspections can be performed at any time and do not require advance notice.
What Leads To Inspections?
There are a variety of reasons that inspections occur. Often, there is no particular reason a certain vehicle or driver is selected to be inspected. The inspectors have a job to do, and your vehicle was in the right place at the right time (or, perhaps not) to be selected. It happens at random.
The selections do not always happen by chance, though. If an inspector notices something that does not look right, such as a broken headlight, then your vehicle can also be selected.
The Federal Motor Carrier Safety Administration (FMCSA) uses the Inspection Selection System (ISS) - a compilation of data on carriers and information in its SAFER database - to screen which carriers should be selected for an inspection. Previous inspection problems, other safety issues, or the need to get data on a carrier can all lead the ISS to flag a carrier for inspection. This means that if it has been a long time since the last inspection or if previous inspections have not gone well, the odds of another inspection occurring soon is increased.
However, whether your vehicle is chosen for a reason or by chance, the most important thing is that you're prepared.
Level 1 Inspections
The Level 1 North American Standard Inspection is very comprehensive. It includes a review of the driver's paperwork and a complete inspection of the vehicle. Any paperwork related to operating the vehicle, or any part of the vehicle itself, is subject to inspection.
This can include any or all of the following items -
Paperwork:
- Commercial Driver's License (CDL)
- Medical Examiner's Certificate
- Skill Performance Evaluation (SPE) Certificate (if applicable)
- Alcohol and drugs
- Driver's record of duty status
- Hours of service
- Vehicle inspection report(s)
Physical:
- Seat belt
- Brake systems
- Cargo securement
- Coupling devices
- Driveline/driveshaft
- Electrical cables and systems in engine and battery compartments
- Exhaust systems
- Frames
- Fuel systems
- Lighting devices (headlamps, tail lamps, stop lamps, turn signals and lamps/flags on projecting loads)
- Steering mechanisms
- Suspensions
- Tires
- Van and open-top trailer bodies
- Wheels, rims and hubs
- Windshield wipers
Below is the guidance from the CVSA for inspectors doing Level 1 inspections:
- Choose the Inspection Site
- Approach the Vehicle
- Greet and Prepare the Driver
- Interview Driver
- Collect the Driver's Documents
- Check for Presence of Hazardous Materials/Dangerous Goods
- Identify the Carrier
- Examine Driver's License or CDL
- Check Medical Examiner's Certificate and Skill Performance Evaluation (SPE) Certificate (if applicable)
- Check Record of Duty Status
- Review Driver's Daily Vehicle Inspection Report (if applicable)
- Review Periodic Inspection Report(s)
- Prepare Driver for Vehicle Inspection
- Inspect Front of Tractor
- Inspect Left Front side of Tractor
- Inspect Left Saddle Tank Area
- Inspect Trailer Front
- Inspect Left Rear Tractor Area
- Inspect Left Side of Trailer
- Inspect Left Rear Trailer Wheels
- Inspect Rear of Trailer
- Inspect Double, Triple and Full Trailers
- Inspect Right Rear Trailer Wheels
- Inspect Right Side of Trailer
- Inspect Right Rear Tractor Area
- Inspect Right Saddle Tank Area
- Inspect Right Front Side of Tractor
- Inspect Steering Axle(s)
- Inspect Axle(s) 2 and/or 3
- Inspect Axle(s) 4 and/or 5
- Prepare the Vehicle and Check Brake Adjustment
- Inspect Tractor Protection System (this procedure tests both the tractor protection system and the emergency brakes)
- Inspect Required Brake System Warning Devices
- Test Air Loss Rate
- Check Steering Wheel Lash
- Check Fifth Wheel Movement
- Complete the Inspection
The time to complete the Level 1 inspection is up to 60 minutes.
Level 2 Inspections
The Level 2 North American Standard Inspection is basically the paperwork portion of the Level 2 plus a visual (walk-around) of the equipment. The inspector does not go under the tractor or trailer. It is possible, however, that if the inspector sees something amiss (such as fluids leaking), that the inspection could be changed to become a Level 1.
The time to complete the Level 2 inspection is up to 30 minutes.
Level 3 Inspections
The Level 3 North American Standard Inspection includes reviewing the paperwork but nothing physical (except the seat belt). This is basically a "driver paperwork" review.
The time to complete the Level 3 inspection is up to 15 minutes.
CVSA Decals
Successfully completing a Level 1 inspection makes the vehicle eligible for a CVSA decal. This decal applies only to the vehicle, not the driver. The decals are valid for up to three months. The CVSA decal does not guarantee that another inspection will occur during the period it is valid, but unless it is flagged for a specific reason, it is much less likely.
Resources and Preparation
The link to the "North American Standard Roadside Inspection Vehicle Cheat Sheet" on the CVSA resources page will pull up a one-page summary with a listing of key items to check. This helpful flyer reviews common areas of concern for inspectors.
The best way to pass an inspection is to be prepared for it. Having your paperwork (or electronic equivalent) organized goes a long way to helping the inspector verify that your proverbial ducks are in a row. Inspecting and maintaining your equipment (with the paperwork to prove it) should be standard procedure.
Doing poorly on a roadside inspection can lead to a CSA intervention. The FMCSA calls its safety compliance and enforcement system the Compliance, Safety, Accountability (CSA) Program. No carrier wants to participate in an intervention because they occur when the FMCSA thinks a carrier's safety performance indicates a potential safety risk.
CSA Interventions include three categories:
- Early Contact. This involves warning letters and targeted roadside inspections.
- Investigation. This includes offsite and onsite detailed comprehensive reviews.
- Follow-On. Four basic results are most common.
- Cooperative Safety Plan (CSP). This involves a voluntary plan to address any safety issues. At this point, it is the best option.
- Notice of Violation (NOV). A formal notice but no civil penalties. Corrective actions must be taken to correct the violations.
- Notice of Claim (NOC). Violations warrant civil penalties.
- Operation Out of Service Order (OOSO). Prohibits carrier from operating, effective immediately.
- The best way to avoid any CSA Interventions is to do your due diligence on the front end as described above.
It's important to note that inspectors are people, too, just like you and me. Sometimes we experience harder days than others. A driver's attitude while working with an inspector can make the process go more smoothly.
After all, H. Jackson Brown, Jr. says, "The best preparation for tomorrow is doing your best today."
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