Summary of Issue:
The initial certification and maintenance of certification tables for investigations, contained in CVSA Operational Policy 4, imply that all personnel conducting investigations must complete at least two investigations of the Hazardous Materials BASIC, either a full or supplemental review.

Justification or Need:
Jurisdictions have various reasons, including but not limited to, job classification restrictions and certification levels, that prohibit employees from conducting investigations that include the Hazardous Materials (HM) BASIC. When the HM BASIC requires investigation only the jurisdiction’s authorized and HM certified employees are conducting those investigations.

Request for Action:
The initial and maintenance certification investigation tables were adopted from FMCSA Certification Policy MC-SE-2022-002. I am asking CVSA to revise the language in the Hazardous Materials section of both investigation tables in CVSA Operational Policy 4, to the language below, to clarify the requirements for Hazardous Materials investigations.

Successfully completed either HM supplementals or full comprehensive HM BASIC investigations using the applicable investigation sampling procedures, as required by the employing entity to investigate HM motor carriers.

Language was added to the hazardous materials section of the initial certification Table 1 and maintenance certification investigation Table 2. The additional language clarifies that agencies have the discretion to determine which employees are required to complete investigations of the HM BASIC.

• Certification-Policy_QAs__July_2022_Final-006-highlighted.pdf
• Certification-Policy_MC_SE-2022_002_Revised_July-15-2022_Signed-005.pdf