Who is qualified to perform annual inspections under 49 CFR 396.19?

Short answer

To perform annual inspections under 49 CFR 396.19, an individual must be qualified by understanding inspection criteria, being knowledgeable of inspection methods and tools, and having experience or training. Four things qualify them: completing a Federal or State training program, having a certificate from a State or Canadian Province, participating in a manufacturer-sponsored training program, or having at least 1 year of experience as a mechanic or inspector.

The rule says

"Understand the inspection criteria set forth in part 393 and appendix A to this part and can identify defective components." (49 CFR 396.19(a)(1))

"Are knowledgeable of and have mastered the methods, procedures, tools and equipment used when performing an inspection." (49 CFR 396.19(a)(2))

"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(a)(3))

In plain English

Inspectors must know what to look for and how to look for it, which means understanding the inspection criteria and being familiar with the tools and methods used in inspections. They also need to have some experience or training under their belt, whether that's through a formal program or on-the-job experience. Motor carriers and intermodal equipment providers are responsible for ensuring their inspectors meet these qualifications.

What to do

• Verify the qualifications of individuals performing annual inspections
• Ensure inspectors understand inspection criteria and can identify defective components
• Provide training or experience to inspectors who lack qualifications
• Retain evidence of inspector qualifications for the required period