Enforcement still citing "catchall" violations, when also citing for individual violations, e.g., citing 177.804(a), to an HM carrier, who also has a safety regulation violation. I previously submitted a request for action and it was closed pending Ops 14 update. Ops 14 has been updated, but it still has nothing ref. this type of "Stacking" violation

Due to the ever increasing, behind the scenes, punitive actions associated with roadside inspection violations, a policy and/or request to FMCSA, for any type of stacking or catchall violations, associated with another violation, on the same report, needs to be declared as stacking and/or the SMS point value placed at 0. This type of "stacking" does not increase safety and can add to industries frustration with enforcement. This type of violation is strictly used to add "quantity" and has nothing to do with quality.

Put into policy a prohibition for stacking and submit letter to FMCSA to either remove catch all cites from the SMS list or assign a 0 point value for such cites.

The approved the addition of the above language to Operational Policy 14.

Hazardous Materials/Dangerous Goods:
Violations relating to the hazardous materials section should be cited against the carrier or shipper/offeror in accordance with agency/department policy. Violations cited under Part 177 should include a reference to the specific section, subsection, or subparagraph.

Stacking of violations is prohibited on roadside inspections, in accordance with CVSA’s Operational Policy 17.

If the below guidance would result in a combination of an out of service violation with a non out of service violation, then each violation shall be documented separately.