Good Afternoon,
Every violation on an inspection report feeds your CSA scores, and your CSA scores feed what you pay for insurance. But not every violation written on a report is actually valid.
This month is less about new obligations and more about rules that quietly disappeared — and the one document that tells you whether a violation should have been written in the first place.
Here are a few topics worth paying attention to this month.
🔋 HazMat Geek: Placards and Markings Are the First Thing Inspectors See
CVSA runs its annual HazMat-focused enforcement blitz every year, and unlike Roadcheck, it’s unannounced — no heads-up, no advance date for carriers to prepare around. This year it ran June 8–12.
The numbers from that week:
✅ Total HM OOS rate — 13.5%
✅ Placarding violations — 27.9% of all HM OOS violations
✅ Bulk marking violations — 31.3% of all HM OOS violations
Placards and bulk markings are the public-facing side of HazMat compliance. They’re also the easiest thing for an inspector to spot from outside the cab, before the inspection even starts.
Takeaway
If placards and bulk markings aren’t already part of your pretrip routine, they need to be. Don’t hand an inspector the easiest violation to write.
🛞 OOS Corner: Don’t Let a Bad OOS Call Sit on Your Record
CVSA publishes an updated Out-of-Service Criteria every April. Without a current copy, there’s no way to verify whether an OOS violation on an inspection report was actually called correctly.
That matters more than it sounds like. Violations get marked OOS when they shouldn’t be — it happens on both sides of the clipboard, including by inspectors with decades of experience. When it does, it doesn’t just sit quietly on a report. It feeds your CSA scores, and it can affect what you pay for insurance.
The current OOS Criteria is copyrighted material available for purchase directly from CVSA — it isn’t something that can be freely passed around, but it’s worth having a copy on hand.
Action Item
Before accepting an OOS violation as valid, check it against the current CVSA OOS Criteria. If it doesn’t hold up, that’s what DataQ is for.
📱 National Focus: MCS-150 Auto-Deactivation Is Paused — Not Canceled
FMCSA has temporarily suspended the automatic inactivation of USDOT numbers for carriers who missed their biennial MCS-150 update deadline.
The pause isn’t a policy change — it’s a patch. It’s tied to technical issues in FMCSA’s system rollout, including the transition to the Motus platform and new Login.gov authentication requirements, which were blocking some carriers from completing filings or linking credentials properly.
Once those issues are resolved, automatic deactivations and the civil penalties that come with a missed MCS-150 update go right back to standard practice.
Takeaway
Don’t read this as a free pass. If your biennial update is due, get it filed. The suspension is about a broken system, not a changed requirement.
🧯 Driver Focus: Two Requirements Came Off the Books This Summer
Both effective July 22, 2026, as part of broader deregulatory changes:
Self-reporting removed. CDL drivers are no longer required to self-report motor vehicle violations to their state of domicile.
ELD operator’s manual removed. Drivers are no longer required to physically carry the ELD user manual in the vehicle.
Takeaway
The manual requirement is gone, but the underlying expectation isn’t — drivers still need to know how to transfer ELD records and handle an ELD malfunction, and still need to be able to show that during an inspection. Removing the manual doesn’t remove the knowledge requirement behind it.
💡 Vehicle Talk: Three Rule Changes Easy to Miss
All three affect what can legitimately be cited on an inspection or during a Compliance Audit:
Spare fuses — no longer required. Effective April 20, 2026, 393.95(b) was removed, ending the requirement to carry spare fuses in a commercial vehicle. If an inspector cites it anyway, a polite heads-up about the change may be all it takes — and if it still gets written up, it’s a DataQ candidate.
Tire size — no longer a vehicle file requirement. Effective July 21, 2026, tire size is no longer a required component of the vehicle maintenance file. If you were cited for missing it in a Compliance Audit after that date, that’s worth working to get removed.
Signed inspection copies — now jurisdiction-dependent. Effective July 22, 2026, whether a signed copy of a roadside inspection has to be returned is now up to the inspecting jurisdiction, and most no longer require it. Check the certification portion of the inspection report itself — that’s where it states whether a signed copy is owed.
Takeaway
Three small rules, same lesson: a requirement that’s gone can still show up on a report out of habit. Know which ones changed so you’re not complying with — or getting cited for — something that no longer exists.
🚦 Final Thought: A Violation That Shouldn’t Exist Still Counts Until You Push Back
Everything this month points at the same gap: the rulebook moves, inspection habits don’t always move with it, and a violation written against an outdated requirement still lands on your record exactly like a valid one — until someone checks it.
The CVSA OOS Criteria is how you check whether an OOS call was legitimate. DataQ is how you fix it when it wasn’t. And this month gave five examples — spare fuses, tire size, signed copies, self-reporting, the ELD manual — of rules that no longer apply but could still get written up out of habit.
None of this is about memorizing every Final Rule FMCSA publishes. It’s about not assuming a citation is valid just because an inspector wrote it down — because your CSA scores, and what you pay for coverage, don’t know the difference between a fair violation and an outdated one. You have to be the one who does.
If you’re ever unsure whether a violation on your record should have been there, that’s something we can help with — we’ll work through the CVSA criteria with you and handle the DataQ submission to get it corrected.
Need Help?
If you’d like to review your fleet’s CSA trends, discuss compliance exposures, or understand how safety performance impacts your insurance program, I’d be happy to help.
Stay Safe and God Bless,
Zach Kuder, TRS
Roark & Sutton, LLC
📞 417-830-0466
📱 417-397-4670
✉️ Zach@roarkandsutton.com
