Qualified Vs. Certified CNG Fuel System Inspectors

Many fleet managers want to know the difference between a certified CNG fuel system inspector and a qualified CNG fuel system inspector, and how to choose which is best for their operations. To understand this, here are the most frequently asked questions and answers about training and certification.

Question #1: Is CNG fuel system inspector certification a legal or regulatory requirement?

Certification is not a federal requirement. U.S. DOT’s FMVSS 304 calls for periodic inspections of cylinders, but does not specify the qualifications for an inspector.  

In 2016 (and revised in 2022), the natural gas vehicle industry established more detailed inspection guidelines that were based on time intervals and vehicle circumstances. 

Some states, to include Texas and Oklahoma, have specific requirements for licensing and/or certification.

Question #2: What is the difference between a qualified and a certified CNG fuel system Inspector?

The difference between being qualified and certified as a CNG fuel system inspector all comes down to the level of formal recognition and validation for the individual technician’s skills, knowledge, and abilities. 

Here’s a broader overview of what we mean by that.

Qualified CNG Fuel System Inspector

• Definition: A qualified inspector is someone who has received the necessary training and has the skills and knowledge to perform inspections, but has not been officially tested or validated by a third party within the industry.
• Training: They typically complete a training program that has hands-on workshops or classroom instruction to learn how to perform the four types of fuel system inspections.
• Validation: Their competence is recognized informally, often by their employer or based on experience and internal assessments.
• Documentation: Qualification is usually internal, either noted in completion certificates or other employer documentation.
• Applicability: Being “qualified” is suitable for organizations that don’t require formal certification, or where compliance may be less regulated.
• Limitations: Inspectors lack third-party validation that may be required by some regulatory bodies or insurance providers.

Certified CNG Fuel System Inspector

• Definition: A certified inspector has undergone training and passed a standardized exam or evaluation administered by an official certification organization.
• Training and Certification: Certified inspectors must (1) complete a recognized training program, and (2) pass an exam that tests their knowledge, skills, and understanding of applicable standards (e.g. NFPA 52 and ANSI 6.1, among others).
• Validation: Their certification is awarded by a recognized third party, like AFVi or another regulatory/industry body.
• Documentation: Certified inspectors receive formal credentials — such as a certificate or ID card — which has an expiration date and requires periodic renewal.
• Applicability: Certification may be required by certain industry regulations, insurance companies, or contractual obligations.
• Advantages: Certification demonstrates competence and credibility, and can be part of an organization’s quality assurance when it comes to maintaining and promoting industry compliance. 

Question #3: Should fleet managers choose training programs that “qualify” or “certify” their technicians?

For maximum safety, liability, and risk management, certification has become the industry standard for both fleets and dealerships performing CNG fuel system inspections. Certification is also recommended by major CNG cylinder/fuel system manufacturers.  

Here are the main reasons why certification is preferable.

Safety

• Training alone ensures that inspectors are equipped with the knowledge and skills to perform inspections, whereas certification adds validation. Certified inspectors have demonstrated their competence, and are statistically less likely to make mistakes that could compromise vehicle safety.

Liability Management

• Certification demonstrates due diligence on the part of fleet managers. In the event of an incident — where all parties associated with a CNG vehicle can be held liable — having certified inspectors can offer legal and insurance protection by showing that proper precautions were taken.

Compliance

• Some state regulatory bodies and insurance companies may require inspectors to be certified rather than simply trained and qualified. Certification can be used to acknowledge that a fleet complies with any relevant safety or environmental regulations.

Credibility

• Certified inspectors enhance a fleet’s reputation for maintaining high standards. Having technicians certified by a recognized third party will also reinforce the validity of the certification for additional industry clout. 

Consistency

• Certification programs often include standardized procedures and criteria so that training and exams are consistent — and, by extension, the inspections that technicians perform once they’re certified.

Question #4: When does the certification of CNG fuel system inspectors play a role in CNG vehicle incidents and lawsuits?

CNG fuel system inspectors are often vital to lawsuits involving any CNG-related incidents. Here are the key reasons why, and how certification can be beneficial to them when the time comes.

Establishing Competence and Credibility

• Certification demonstrates that an inspector has been formally trained and tested to meet industry standards. This serves as evidence of their competence, making it harder for opposing parties to argue negligence or lack of qualifications. If an inspector is not certified, the plaintiff may argue that the inspection was performed by someone not adequately qualified, undermining the defense’s position.

Compliance With Regulations

• In cases involving regulatory violations, certification provides evidence that the inspection process adhered to relevant federal, state, or local regulations (e.g. NFPA 52 or state-specific CNG codes).
• If the inspector is certified, it indicates that the fleet manager has followed proper procedures for compliance, which may reduce liability.
• Conversely, lack of certification can be interpreted as a failure to comply with industry best practices, potentially increasing the fleet owner’s liability.

Liability Determination

• If an incident occurs and the last inspectors to review the vehicle are not certified, the employer can be held liable for failing to hire qualified personnel.
• Certified inspectors are expected to identify and address safety issues during inspections. Certification establishes a standard of care that the inspector is expected to meet. If a certified inspector misses a defect that causes an incident, their certification may be scrutinized to determine if they acted negligently.

Expert Testimony and Evidence

• Certified inspectors may be called upon as expert witnesses to defend the thoroughness and accuracy of their inspections.
• Certification strengthens the inspector’s credibility as an expert, as it shows they have met recognized standards of knowledge and skill.

Risk Mitigation

• In lawsuits, having certified inspectors demonstrates due diligence on the part of the fleet manager or company. It shows that the organization took all reasonable steps to ensure vehicle safety, which can mitigate damages or reduce the likelihood of punitive actions.
• Without certified inspectors, the plaintiff may argue that the company acted negligently by not taking reasonable precautions to avoid the circumstances of the vehicle incident.

Case Example Scenarios

• If an incident occurs despite an inspection by a certified professional, the defense can argue that reasonable care was taken because the inspector was trained and certified to industry standards.
• If an incident occurs after an inspection by a qualified technician, the plaintiff may argue that the inspection process was inherently flawed due to the inspector’s lack of formal certification.

Key Takeaways

• Certification establishes a professional standard of care, strengthens a company’s liability, and demonstrates industry compliance.
• Lack of certification can be viewed as negligence or failure to meet industry best practices, which can risk greater liability in the event of a vehicle incident.
• Fleet managers should prioritize certification for all CNG fuel system inspectors to reduce legal risks to their fleets, enhance their credibility, and adhere to all codes and standards.

Question #5: What is the cost-benefit analysis of certifying CNG fuel system inspectors?

The current standard fee for certifying CNG fuel system inspectors with AFVi is only $295 per technician. The average CNG incident lawsuit settlement in which AFVi has served as an expert witness has exceeded $2 million. In contrast, if an organization were to certify 1,000 technicians, the cost would be roughly $300,000.