Operational Policy 4 - HM Inspections

See also issue request #26-060-TRN. This is a reconsideration to alleviate this issue that continues to come up across the country in multiple jurisdictions. The issues are: #1 – May an inspector who is only certified in general hazmat (GHM) conduct an inspection on a cargo tank hauling hazmat? #2 – Should the policy be amended to allow some cargo tank inspections be conducted during the initial certification process for GHM so the trainee will have some experience with different bulk packages once they are certified? #3 – Currently, CVSA Operational Policy 4 prohibits an inspector seeking GHM certification to from conducting ANY cargo tank inspections during training but allows a fully certified inspector to inspect cargo tanks to maintain their annual certification.

There is confusion nationwide about who may conduct what type of hazmat inspection roadside and a need to consider the current policy language. Jurisdictions may be erroneously allowing or prohibiting inspectors from conducting certain inspections related to the issues raised. Issue #1: An inspector who is only GHM certified received minimal bulk package instruction during the classroom portion of GHM. They were not allowed to conduct any training inspections on cargo tanks, based on Operational Policy 4 (unless the CMV also contained non-bulk hazmat or bulk packages OTHER than the cargo tank, such as an IBC). However, once certified, the same policy allows the GHM only certified inspector to conduct cargo tank inspections as long as they do not apply a CVSA decal to the cargo tank motor vehicle. (See CVSA Operational Policy 4, 04/23/2026 revision, page 8, last paragraph). Argument FOR the allowance of cargo tank inspections is that the GHM only certified inspector can still verify compliance with all other parts of the hazmat inspection (shipping papers, placards, markings, carriage by highway), and can generally verify that the specification cargo tank is authorized for the material transported, without getting deep into the regulations for a specification cargo tank. They can review Column 7 of the hazmat table for special provision and Column 8C for package authorization. Additionally, a non-specification cargo tank authorization is simply checking Column 8C to confirm the material transported may be in a non-spec tank. Argument AGAINST the allowance of cargo tank inspections is that the GHM only certified inspector has not been properly trained to fully verify that a specification cargo tank is authorized for the material transported (e.g., specification/name plate location and marking, MAWP, venting, bottom outlets, accident damage protection, etc.) Issue #2: If an inspector is going to be allowed to conduct cargo tank inspections once certified, perhaps it would be beneficial to allow them to conduct some cargo tank inspections during their training inspections. The policy could be amended to allow a certain percentage of their training inspections to be conducted on cargo tanks, such as no more than 25% (4 of the 16). Consideration should be made regarding whether these inspections may be conducted on both specification and non-specification cargo tanks or limited to only non-specification tanks. If limited to non-specification only whether issue arises once the new inspector is certified as whether they may conduct inspections on specification tanks when they are only GHM certified. Issue #3: If a GHM only certified inspector is NOT allowed to conduct an inspection on a cargo tank, this would limit the ability to remove an imminent hazard from the roadway, such as a hazmat cargo tank leaking product, not properly marked, not properly placard, unauthorized package, etc.

The request is for the training and hazmat committees is to come to a consensus on the issues raised and clarify in CVSA Operational Policy 4 exactly who may conduct what types of inspections.