CVSA Level VIII Inspection

The Commercial Vehicle Safety Alliance (CVSA) has been developing an automated inspection process that will take place when the vehicle is in motion on the highway. Development has reached a point where testing of the new Level VIII inspection has started. There are currently three states and four motor carriers participating in the test. CVSA began developing this new inspection process to ramp up inspections as the motor carrier population grows and state enforcement agencies have limited time and resources to conduct inspections.

Since the process is entirely electronic, a data exchange must take place between the truck, the on-board ELD, the on-board by-pass device (such as Drivewyze and PrePass), and the state’s inspection software. Currently, only a limited data exchange is possible and CVSA is working with ELD providers to expand the amount of data that is collected. The data currently collected includes:

• Descriptive location including GPS coordinates
• USDOT number
• Power Unit registration
• Operating authority
• Unified Carrier Registration (UCR) compliance
• FMCSA out-of-service orders

CVSA will be adding these data points once the data exchange is enhanced:

• Appropriate driver’s license class and endorsements for vehicle
• License status
• Current driver’s record of duty status
• Valid medical examiner’s certificate and skill performance evaluation certificate
• Hours of Service compliance
• Electronic validation of who is operating the vehicle.

During July, 2024, the four participating carriers in the three participating states had 30,022 Level VIII data transfers compared to 79 in-person Level I – III inspections. Another interesting statistic is that in August, 2024, there were 44,583 Level VIII inspections completed on 8,086 distinct trucks. The early data certainly indicates that the Level VIII program will certainly ramp up inspections, but how will this data ultimately be used?

During Phase 1 of the testing process CVSA is evaluating the completeness and accuracy of the data collected. They are also working with technology providers to resolve issues. Phase 2 will begin the process of automatic data processing to detect violations. This is where things start to get interesting and there are more questions than answers.

• Should the Level VIII program remain voluntary or should it become mandatory for all motor carriers, or only a subset such as new entrants and carriers on a safety improvement plan?
• How should out-of-service violations be handled?
• How will the Level VIII program affect FMCSA systems such as SMS, ISS inspection selection, and PSP the pre-employment screening program?
• Will carriers who participate in the program be compared to carriers that do not participate?
• If a vehicle is inspected multiple times in a day, which inspection(s) would be used for SMS purposes?
• Should Level VIII results be eligible for DataQs?

The transition from a small-scale test to full nationwide roll out is dependent on developing and implementing technical specifications across multiple platforms and providers. This will require a buy-in from motor carriers, CVSA, FMCSA and the states as well as the expenditure of time and funding.

“The new Level VIII Electronic Inspection is an enhancement to the data currently collected during roadside enforcement activities. It does not replace anything currently being done. It will simply mean that more roadside inspection compliance information will be captured differently,” said CVSA Executive Director Collin Mooney. “Roadside inspectors will continue to conduct all levels of commercial motor vehicle and driver inspections as applicable, in addition to the future capabilities and discoveries that will evolve with the addition and implementation of this new electronic inspection level.”

Increased use of technology is inevitable, and it is even understandable that enforcement agencies would want to tap into the ability to easily collect data. However, a dramatic increase in data could simply overwhelm the enforcement system without any clearcut impact on safety outcomes. This program has already been in development for ten years so it is not likely to roll out nationwide quickly, as CVSA and FMCSA have a lot of work to do in transforming the data into meaningful safety solutions.