Letters, Petitions and Comments

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.

On Oct. 22, CVSA petitioned FMCSA to amend the Federal Motor Carrier Safety Regulations by requiring that noncompliance with English language proficiency requirements in § 391.11(b)(2) result in a driver being placed out of service.

On Sept. 2, CVSA submitted comments in response to PHMSA’s NPRM seeking stakeholder feedback on the agency’s proposal to allow a grantee to file an application to renew a special permit or approval any time before its expiration date rather than requiring the application to be filed 60 days in advance.

On Sept. 2, CVSA submitted comments in response to PHMSA’s NPRM seeking stakeholder feedback on proposed revisions to the HMRs to allow motor and vessel carriers the option to carry their PHMSA certificate of registration in electronic form.

On Sept. 2, CVSA submitted comments in response to PHMSA’s NPRM seeking stakeholder feedback on the agency’s proposal to allow for the continued use of packagings authorized under a manufacturing special permit for duration of the useful life of the package.

On Sept. 2, CVSA submitted comments in response to FMCSA’s notice and request for comments regarding the agency’s proposed revisions to the DataQs requirements for Motor Carrier Safety Assistance Program (MCSAP) Grant funding.

On Sept. 2, CVSA submitted comments in response to PHMSA’s NPRM seeking stakeholder feedback on the agency’s proposal to amend the materials of trade (MOT) exceptions to allow for the transportation of increased quantities of lithium batteries.

On Sept. 2, CVSA submitted comments in response to PHMSA’s NPRM seeking stakeholder feedback on the agency’s proposal to revise the HMRs to remove pages contained in an appendix that repeats references listed in U.S. Environmental Protection Agency (EPA) regulations.

On Sept. 2, CVSA submitted comments in response to PHMSA’s NPRM stakeholder feedback on the agency’s proposal to adopt the provisions of DOT special permit (SP) 21478 into the HMRs.

On Sept. 2, CVSA submitted comments in response to PHMSA’s NPRM seeking stakeholder feedback on the agency’s proposal to revise the Hazardous Materials Regulations (HMRs) to provide domestic carriers the option to maintain electronic copies of emergency response information rather than requiring a hard copy printed on paper.

On Aug. 21, CVSA submitted comments in response to U.S. DOT’s RFI regarding the upcoming surface transportation reauthorization legislation.

On Aug. 15, CVSA submitted comments on the application from the National Propane Gas Association (NPGA) for an exemption from various hours-of-service (HOS) requirements.

On July 28, CVSA submitted comments on the NPRM proposing to add an exception from stopping before crossing a railroad track with an active warning device that is not in an activated state.

On July 9, CVSA submitted comments on the NPRM to remove the requirement in the Federal Motor Carrier Safety Regulations that a liquid fuel tank manufactured on or after Jan. 1, 1973, be designed and constructed so that it cannot be filled, in a normal filling operation, with a quantity of fuel that exceeds 95% of the tank’s liquid capacity.

On July 9, CVSA submitted comments on the notice of proposed rulemaking (NPRM) to rescind the requirements for retroreflective sheeting on semitrailers and trailers manufactured prior to Dec. 1, 1993.