Letters, Petitions and Comments

On Sept. 26, CVSA submitted comments in response to the notice of review of guidance from FMCSA regarding the agency’s regular review of existing guidance documents. CVSA identified several instances where the regulatory guidance needs to be updated or clarified, in addition to recommending FMCSA considers soliciting feedback on regulatory guidance on a rolling basis, by each part… Read more »

On Sept. 4, FMCSA responded to CVSA’s letter requesting clarification on the enforcement of the hours-of-service (HOS) regulations for drivers operating under the agricultural operations exemption in § 395.1(k).

On Sept. 4, FMCSA denied CVSA’s petition for rulemaking requesting that the FMCSA amend § 393.86(a)(6) to remove the rear impact guard labeling requirement.

On Sept. 4, FMCSA granted CVSA’s petition for rulemaking requesting that the agency consider amending § 393.102 and § 393.106 to make the cargo securement requirements clearer, more enforceable and compatible with the Canadian National Safety Code.

On Sept. 4, FMCSA granted CVSA’s updated petition for rulemaking to amend Part 393 to specifically identify unsafe vehicle conditions currently documented during roadside inspections under the “catch-all” provision in § 396.3(a)(1).

On Sept. 3, FMCSA granted CVSA’s petition for rulemaking requesting that the agency consider amending § 396.9(d) to remove the requirement that motor carriers return inspection reports to issuing jurisdictions.

On Aug. 26, CVSA requested a 60-day extension to the comment period for the notice of review of guidance from FMCSA regarding the agency’s regular review of existing guidance documents.

On July 30, CVSA sent a letter to FMCSA requesting formal guidance regarding appropriate enforcement action and documentation when a motor carrier is registered with FMCSA as an intrastate carrier but found to be operating interstate movements.

On July 11, CVSA requested that FMCSA provide clarification regarding the enforcement of the HOS regulations while drivers are operating under the agricultural operations exemption in § 395.1(k).

On June 10, CVSA sent a letter to FMCSA on the creation of a Beyond Compliance pilot program and framework.

On April 2, CVSA petitioned FMCSA to amend Title 49 CFR § 396.9(d)(3) to remove the requirement that motor carriers return inspection reports to the issuing agency certifying that all violations noted on the inspection report have been corrected.

On Dec. 4, CVSA petitioned FMCSA to amend the Hazardous Materials Safety Permit regulations to update the incorporation by reference of the “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, 2024.

On Dec. 4, 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. 21.

On Nov. 29, CVSA submitted comments in response to the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) advance notice of proposed rulemaking (ANPRM) seeking stakeholder feedback on initiatives PHMSA is considering that may modernize the Hazardous Materials Regulations (HMR) and improve efficiencies, while maintaining or improving a current high level of safety.

On Nov. 27, CVSA submitted comments in response to FMCSA’s ANPRM regarding the agency’s interest in developing a new methodology to determine when a motor carrier is not fit to operate commercial motor vehicles in or affecting interstate commerce.

On Nov. 13, CVSA submitted comments in response to FMCSA’s notice and request for comments regarding the agency’s proposal to develop and implement a federal appeals process for Requests for Data Review (RDRs) submitted to the agency through the DataQs system.

On Nov. 2, CVSA submitted a petition for reconsideration regarding FMCSA’s recent final rule on the applicability of emergency exemptions.

On Oct. 23, CVSA sent a letter in support of the creation of a Beyond Compliance program within FMCSA to recognize motor carriers for safe practices and to help better distinguish between carriers who are merely compliant with the Federal Motor Carrier Safety Regulations (FMCSR) and those who take additional steps to ensure not only compliance, but a higher safety culture overall.

On Oct. 6, CVSA requested a 30-day extension to the comment period for the Safety Fitness Determinations (SFD) advance notice of proposed rulemaking (ANPRM).

On Sept. 5, CVSA, on behalf of the Commercial Vehicle Brake Manufacturers Council (CVBMC), submitted comments regarding the joint notice of proposed rulemaking (NPRM) from NHTSA and FMCSA proposing automatic emergency braking (AEB) and other related requirements for heavy duty vehicles.