What does 49 CFR 396.19 (Inspector qualifications) require?

Short answer

49 CFR 396.19 requires that inspectors performing annual inspections be qualified through training, experience, or a combination of both, and that motor carriers and intermodal equipment providers retain evidence of these qualifications. Three things are required: understanding inspection criteria, knowledge of inspection methods, and capability to perform inspections.

The rule says

"Motor carriers and intermodal equipment providers must ensure that individuals performing annual inspections under 396.17(d) or (e) are qualified as follows: (1) Understand the inspection criteria set forth in part 393 and appendix A to this part and can identify defective components; (2) Are knowledgeable of and have mastered the methods, procedures, tools and equipment used when performing an inspection; and (3) Are capable of performing an inspection by reason of experience, training, or both as follows: (i) Successfully completed a Federal-or State-sponsored training program or have a certificate from a State or Canadian Province that qualifies the individuals to perform commercial motor vehicle safety inspections, or (ii) Have a combination of training or experience totaling at least 1 year." (49 CFR 396.19)

In plain English

This rule is about making sure the people who inspect trucks and trailers are competent to do the job. It's not just about checking boxes on a form - they need to actually know what they're looking for and how to use the right tools and methods. If an inspector doesn't meet these qualifications, the motor carrier or intermodal equipment provider could be in trouble during an audit.

What to do

• Ensure all inspectors meet the qualification requirements outlined in 49 CFR 396.19.
• Retain evidence of each inspector's qualifications, such as training certificates or documentation of experience.
• Keep these records for as long as the inspector is performing annual inspections and for one year after they stop.
• Make sure these records are readily available for inspection by authorized officials.