• The annual inspection requirement can be performed on-site by the carrier’s own qualified inspector or other qualified inspector, at a commercial shop, or in a state-mandated program with standards equivalent to federal requirements.
• Carriers can qualify technicians to perform periodic inspections, but carriers must document that the technician knows the regulatory requirements and the procedures involved in performing the periodic inspections.
• The carrier must have documentation proving that the technician either successfully completed a state- or federal-sponsored inspection training program or has a combination of training and/or experience totaling at least one year.

The annual inspection requirement can be met in several ways. The vehicle can:

• Be inspected by a qualified inspector (according to the provisions of 396.19) on-site at the motor carrier’s location.
• Be inspected at the carrier’s shop by a technician qualified to perform periodic inspections.
• Be inspected by a commercial shop of some kind (shop, garage, or other third party acting as an agent for the motor carrier).
• Be inspected in one of the state-mandated programs which are equivalent to the federal requirements. States with mandatory inspection programs that have been determined to be equivalent to federal requirements include:
  • Alabama (Liquefied Petroleum Gas Board)
  • California
  • Connecticut (bus inspection program)
  • Hawaii
  • Illinois
  • Louisiana
  • Maine
  • Maryland
  • Massachusetts
  • Michigan (bus inspection program)
  • Minnesota
  • New Hampshire
  • New Jersey
  • New York
  • Ohio (church bus inspection program)
  • Pennsylvania
  • Rhode Island
  • Texas
  • Utah
  • Vermont
  • Virginia
  • Washington, D.C.
  • West Virginia
  • Wisconsin (bus inspection program)

What are the requirements? The specific items to be inspected are stated in Appendix A to Part 396 — Minimum Periodic Inspection Standards.

One key point, carriers can qualify technicians to perform periodic inspections. However, carriers must document that the individual knows the requirements of the regulations, and the procedures involved in performing the periodic inspections. The documentation must include proof that the individual either successfully completed a state- or federal-sponsored training program or has a combination of training and/or experience totaling at least one year. Such training and/or experience may consist of:

• Participation in a vehicle manufacturer-sponsored training program or similar commercial training program designed to train students in vehicle operation and maintenance.
• Experience as a mechanic or inspector in a motor carrier maintenance program.
• Experience as a mechanic or inspector at a commercial garage, fleet leasing company, or similar facility.
• Experience as a commercial vehicle inspector for a State, Provincial or Federal Government.
• The documentation must be retained for the entire time the technician is employed, and for one year after the person leaves the company.

If a carrier is based in a state that has a mandatory inspection program, the periodic (annual) inspection must be conducted in accordance with the state’s program. This includes using facilities and inspectors that are qualified, licensed, or certified by the state. If this is the case, the carrier should check with the state agency that oversees the program to determine if it can do the inspections in-house. Vehicles inspected under a state program that the Federal Motor Carrier Safety Administration (FMCSA) has determined is equivalent to the federal requirements (see the list above), can use the state inspection to satisfy the federal requirement. No separate federal inspection is required.