Operational Policy 4 - PCVI Certification

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 issue is: #1 – May an inspector who is NOT passenger carrying vehicle inspection (PCVI) certified conduct a safety audit or compliance investigation on a passenger carrier? #2 – Currently, FMCSA is allowing auditors who are not PVCI certified through CVSA to conduct new entrant safety audits on passenger carriers. FMCSA has further stated that the auditor’s limitation is they cannot conduct the vehicle inspection. However, audits on PVCI carriers require vehicle inspections.

There is confusion across some jurisdictions as to who may conduct what types of audits or investigations. Motor carriers may be receiving audits, or investigations by inspectors who are not certified to properly conduct those activities. Jurisdictions may be erroneously allowing or prohibiting inspectors from conducting certain activities related to the issues raised. If an inspector is not PCVI certified but is conducting a safety audit or compliance investigation, they may not fully understand the different types of passenger carrier operations (for hire, private motor carrier of passenger business, and private motor carrier of passenger non-business, etc.). An inspector who is not PCVI certified has not had any training in the passenger carrier hours of service, unless they attended the NAS Part A course in the last several years, and even then, the portion of passenger carrier HOS in the old NAS Part A course was minimal.

The request is for the training, passenger carrier, and possibly driver committees to come to a consensus, in coordination with FMCSA, on the issues raised, and clarify in CVSA Operational Policy 4 exactly who may conduct what types of audits, and investigations related to passenger carriers, just as policy is clear on who may conduct roadside inspections of passenger carriers.