Letters, Petitions and Comments

On June 11, CVSA sent a letter to PHMSA requesting a letter of interpretation clarifying whether manifold cylinders with individual closures should be treated as bulk or non-bulk packages for the purposes of applying the hazardous materials marking requirements found in Part 172.

On May 19, CVSA sent a letter to the leadership of the U.S. House of Representitives Transportation and Infrastructure Committee expressing support for the Building Unrivaled Infrastructure and Long-term Development for America’s 250th Act (BUILD America 250 Act).

On May 7, CVSA submitted comments on the application for exemption from Grote Industries LLC (Grote) that would allow motor carriers to operate CMVs equipped with auxiliary rear or side lamps that flash or strobe when controlled by Grote’s Rear-End Collision Warning (RCW) system.

On April 30, CVSA submitted comments responding to PHMSA’s request for feedback on the safety risks, operational challenges and regulatory considerations associated with transporting hazardous materials using heavy-duty electric vehicles (EV) compared to internal combustion engine vehicles (i.e., gas or diesel).

On April 16, CVSA petitioned FMCSA to revise the adjudicated citations policy to allow states to deny a request for data review when it is determined that masking of an underlying unsafe driving violation has occurred, which is prohibited under § 384.226.

On March 25, CVSA petitioned FMCSA to amend Title 49 Code of Federal Regulations (CFR) § 393.87, Warning flags on projecting loads, to add language excluding rear mounted forklifts from the requirement when the item is secured to the rear of the transport vehicle and is connected to the transport vehicle with an electrical connection to activate brake, tail, hazard and turn signal lamps.

On March 20, CVSA sent a letter to FMCSA requesting that the agency provide written clarification regarding the applicability of hazardous materials safety permits (HMSP) in Part 385 Subpart E.

On March 9, CVSA submitted comments in response to FMCSA’s request for feedback on CVSA’s request that the agency allow motor carriers and drivers to rely on a paper copy of the medical examiner’s certificate as proof of the driver’s medical certification until the Medical Examiner’s Certification Integration (NRII) final rule is fully implemented.

On March 6, CVSA submitted comments on FMCSA’s NPRM seeking stakeholder input on the agency’s response to petitions for reconsideration regarding the length of the emergency relief automatically triggered subsequent to a regional declaration of emergency by a governor of a state, their authorized representative or FMCSA.

On March 4, CVSA submitted comments on the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) advance notice of proposed rulemaking (ANPRM) for potential revisions to the Hazardous Materials Regulations (HMR) to facilitate the safe transportation of hazardous materials using highly automated transportation systems.

On Feb. 27, CVSA submitted comments on the American Trucking Associations’ (ATA) application for a five-year exemption to allow motor carriers that previously participated in FMCSA’s Safe Driver Apprenticeship Pilot program to continue onboarding and training drivers under the age of 21.

On Feb. 24, CVSA requested an exemption on the application from Grote for exemption from the requirement that exterior lighting devices on CMVs be steady burning.

On Feb. 13, CVSA, on behalf of the Commercial Vehicle Brake Manufacturers Council (CVBMC), submitted comments in response to NHTSA’s request for stakeholder feedback on its research project evaluating the FMVSS to determine how they apply to innovative vehicle designs, particularly those incorporating ADS, as well as potential challenges these vehicles may face in demonstrating conformance.

On Feb. 3, CVSA sent a letter to FMCSA requesting enforcement guidance regarding the definition of “interstate commerce” within the context of the intrastate license (K) restriction requirements, which limit a CMV driver to intrastate-only operations.

On Dec. 17, CVSA submitted comments to FMCSA’s notice of proposed rulemaking to update the incorporation by reference of CVSA’s “North American Standard Level VI Inspection Procedures and Out-of-Service Criteria for Commercial Highway Vehicles Transporting Transuranics and Highway Route Controlled Quantities of Radioactive Materials as defined in 49 CFR Part 173.403.”

On Dec. 5, CVSA sent a letter to FMCSA requesting that FMCSA provide guidance to CMV enforcement officials that a paper copy of a valid Medical Examiner’s Certificate is permitted to demonstrate compliance with the applicable requirements during a roadside inspection and motor carrier safety audits and investigations until all issues associated with integrating the state driver’s license administrations’ systems with the medical examiners’ systems are resolved and all states have fully complied with the requirements of FMCSA’s 2015 Medical Examiner’s Certification Integration final rule (commonly referred to as NRII).

On Nov. 6, CVSA sent a letter to FMCSA requesting that the agency publicly release its enforcement guidance document related to evaluating a driver’s compliance with the English language proficiency (ELP) requirements in Title 49 Code of Federal Regulations (CFR) § 391.11(b)(2), FMCSA Enforcement Policy: English Language Proficiency Under 49 CFR § 391.11(b)(2) (MC-SEE-2025-0001).

On Oct. 26, CVSA petitioned FMCSA to amend the incorporation by reference of CVSA’s “Operational Policy 4: Inspector Training and Certification” to reflect the newest edition, which was revised on Sept. 25.

On Oct. 27, CVSA petitioned FMCSA to amend the Hazardous Materials Safety Permit regulations to update the incorporation by reference of “North American Standard Level VI Inspection Procedures and Out-of-Service Criteria for Commercial Highway Vehicles Transporting Transuranics and Highway Route Controlled Quantities of Radioactive Materials as defined in 49 CFR Part 173.403” to reflect the newest edition, which will be effective April 1, 2026.

On Oct. 22, CVSA sent a letter to FMCSA requesting an update to Attachment A of Policy MC-SEE-2021-005 – Revised Guidance for Documenting and Enforcing Unsafe Driving Violations to reflect the current violation codes.