Update on Relevant Canadian Regulations

Transport Canada Updates ‘Mirrors and Rear Visibility Systems’ Regulations
On Dec. 18, Transport Canada published amendments to the Motor Vehicle Safety Regulations related to school buses. The amendments update the regulations titled “Mirrors and Rear Visibility Systems.”

Update on Relevant U.S. Regulations

FMCSA Publishes Guidance on Rear Impact Guard Certification Label
On Dec. 10, FMCSA published guidance on illegible, incomplete or missing rear impact guard certification labels. The guidance question asks if an illegible, incomplete or missing rear impact guard certification label establishes a violation of 49 Code of Federal Regulations (CFR) 393.86(a)(6). FMCSA responded no and shared that the regulation in 49 CFR 393.86(a)(6) requires a rear impact guard to be permanently marked or labeled as required by Federal Motor Vehicle Safety Standard No. 223. Based on this guidance, the CVSA Board of Directors voted to leave existing guidance related to rear impact guards in Operational Policy 15. CVSA will be submitting a new petition on the rear impact guard certification label in 2025.

FMCSA Requests Comments on Medical Documentation for Employees Request for Reasonable Accommodation Form ICR
On Dec. 6, FMCSA requested comments on the Medical Documentation for Employees Request for Reasonable Accommodation Form information collection request (ICR). The ICR is related to the collection of certificates of medical examinations to determine whether applicants meet the Office of Personnel Management-approved medical qualification standards for certain positions. Comments are due by Feb. 4, 2025.

FMCSA Requests Comments on Waiver and Exemption Requirements ICR
On Dec. 6, FMCSA requested comments on the Waiver and Exemption Requirements ICR, which estimates the burden applicants incur to comply with the reporting tasks required for requesting waivers and exemptions. Comments are due by Feb. 4, 2025.

Update on Exemptions

FMCSA Denies 3 North LLC’s Application for Exemption
On Dec. 9, FMCSA denied 3 North LLC’s request for a five-year exemption to enable three of its commercial driver’s license holders under the age of 21, with a “K” restriction for intrastate-only operations, to drive commercial motor vehicles in intrastate operations in a state other than their state of domicile. FMCSA analyzed the application and public comments and determined that the exemption would not likely achieve a level of safety that is equivalent to, or greater than, the level that would be achieved absent such exemption.

CVSA Active Exemption Tracker
CVSA maintains a list of active exemptions issued by FMCSA. The exemption tracker can be found at www.cvsa.org under the “Inspections” tab at the top of the page.

Other Items of Interest

FMCSA Removes Two Devices from List of Registered ELDs
On Dec. 18, FMCSA removed the following electronic logging devices (ELD) from its list of registered ELDs and placed them on the revoked ELDs list due to the providers’ failure to meet the minimum requirements established in 49 CFR Part 395, Subpart B, Appendix A.

Mountain ELD by Alaska Safety Inc. (ELD Identifier: MTIA01)
XELD by XELD (ELD Identifier: AT3101)

Motor carriers and drivers were instructed to discontinue using the revoked devices listed above and revert to paper logs or other logging software to record required hours-of-service data. The revoked ELDs must be replaced with compliant ELDs from the registered ELDs list before Feb. 16, 2025.

Motor carriers and drivers that use the revoked ELDs listed above on or after Feb. 16, 2025, will be in violation of 49 CFR 395.8(a)(1) – No Record of Duty Status and will be placed out of service in accordance with CVSA’s North American Standard Out-of-Service Criteria.

FMCSA Removes Four Devices from List of Registered ELDs
On Dec. 11, FMCSA removed the following ELDs from its list of registered ELDs and placed them on the revoked ELDs list due to the providers’ failure to meet the minimum requirements established in 49 CFR Part 395, Subpart B, Appendix A.

Columbus ELD by Columbus ELD (ELD Identifier: CMB388)
Three models of MasterELD by National Transportation Partners LLC (ELD Identifiers MWLA01, MIOA01, MEPT04)

Motor carriers and drivers that use the revoked ELDs listed above on or after Feb. 9, 2025, will be in violation of 49 CFR 395.8(a)(1) – No Record of Duty Status and will be placed out of service in accordance with CVSA’s North American Standard Out-of-Service Criteria.