The CVSA Decal Policy is in dire need of either significant revision or complete repeal. At the CVSA Conference in Denver, it was noted that the policy is often not followed consistently at the national level.

There are several reasons inspectors fail to issue CVSA decals in accordance with the policy. The two primary reasons are:
• The inspector does not have decals available.
• The inspector is uncomfortable issuing a decal because violations were discovered that are not listed as “Critical Vehicle Inspection Items” or included in the “Administrative Purposes” list.

A policy requiring inspectors to place a decal on a vehicle when no critical vehicle defects are found is counterproductive to the mission of the CVSA, FMCSA, state, local, and territorial agencies that enforce the FMCSRs.

The mission of CVSA, FMCSA, state, local, and territorial partners is to prevent and reduce crashes, injuries, and fatalities involving commercial vehicles. Studies show that 80 to 90 percent of commercial vehicle crashes are driver-related. Requiring inspectors to issue decals based solely on the absence of specific vehicle defects contradicts this mission, since vehicle defects are identified as the causal factors for only 2 to 5 percent of the crashes.

Under the CVSA Decal Policy, an inspector who performs a Level I inspection and finds no “critical vehicle inspection items” must issue a decal. This vehicle is then “generally not subject to reinspection” for two to three months, depending on the date of issuance—even if the driver was arrested for DUI, had multiple false logs, suspended license, possessed controlled substances, or if evidence was discovered linking the driver and/or the carrier to human trafficking.

1. Lack of National Consistency
The CVSA Decal Policy is not consistently followed across jurisdictions. Inspectors often fail to issue decals due to either a lack of supply or discomfort with applying decals when violations are present but not classified as “Critical Vehicle Inspection Items.” This inconsistency undermines the credibility and uniformity of enforcement efforts.

2. Misalignment with Agency Mission
The mission of CVSA, FMCSA, and state enforcement agencies is to reduce crashes, injuries, and fatalities involving commercial vehicles. Research shows that approximately 80-90% of crashes are driver-related, while only 2-5% are attributed to vehicle defects. A policy that prioritizes decals based solely on vehicle condition fails to address the primary causal factors of crashes and contradicts the stated mission of these agencies.

3. Risk of Reduced Oversight
Under current policy, vehicles that receive a decal after a Level I or Level V inspection are “generally not subject to reinspection” for two to three months. This exemption applies even in cases where serious driver-related violations are present (e.g., DUI, falsified logs, possession of controlled substances, or human trafficking). Such exemptions create significant enforcement gaps and expose the public to unnecessary risk.

Given these issues, there is a clear need to revise or repeal the CVSA Decal Policy. A modernized approach should:
• Align enforcement practices with the actual causes of commercial vehicle crashes.
• Reduce unnecessary administrative costs and burdens on states.
• Ensure inspectors retain discretion to prioritize driver-related violations and broader safety concerns.
• Strengthen consistency and credibility of enforcement across jurisdictions.