{
  "slug": "who-can-perform-dot-inspection",
  "title": "Who Can Perform a DOT Annual Inspection? (49 CFR 396.19 and 396.25)",
  "description": "The federal qualification rules for annual inspectors and brake inspectors — including why ASE certification is not, by itself, the answer, and why brakes require a separate qualification.",
  "track": "regulatory",
  "kind": "article",
  "isRegulatoryAdjacent": true,
  "publishedAt": "2026-08-10",
  "updatedAt": "2026-09-01",
  "cfr": [
    "49 CFR 396.19",
    "49 CFR 396.25"
  ],
  "related": [
    "annual-dot-inspection-requirements",
    "dot-inspection-recordkeeping"
  ],
  "url": "https://shopbluecollarparts.com/kb/who-can-perform-dot-inspection",
  "markdownUrl": "https://shopbluecollarparts.com/kb/who-can-perform-dot-inspection.md",
  "body": "Two separate federal rules govern this, and **both can apply to the same inspection**:\n\n- **49 CFR 396.19** — qualifies someone to perform the annual periodic inspection\n- **49 CFR 396.25** — qualifies someone to inspect, maintain, service, or repair **brakes**\n\nA technician can be fully qualified under §396.19 and still not be permitted to perform the brake portion of the inspection. Since the brake system is the single largest category in Appendix A, this matters in practice on nearly every job.\n\n## §396.19 — annual inspector qualifications\n\nThe carrier or intermodal equipment provider must ensure the individual meets **all three** of the following. This is not a menu.\n\n**1. Understands the criteria.** The inspector understands the inspection criteria in 49 CFR Part 393 and Appendix A to Part 396, and can identify defective components.\n\n**2. Has mastered the methods.** The inspector is knowledgeable of, and has mastered, the methods, procedures, tools, and equipment used when performing an inspection.\n\n**3. Is capable by experience, training, or both.** This third prong is where you pick a path. Either:\n\n**(i)** Successfully completed a Federal- or State-sponsored training program, **or** holds a certificate from a State or Canadian Province qualifying the person to perform commercial motor vehicle safety inspections;\n\n**or (ii)** has a combination of training or experience totaling **at least one year**, consisting of:\n\n- **(A)** Participation in a commercial motor vehicle manufacturer-sponsored training program, or a similar commercial training program designed to train students in CMV operation and maintenance\n- **(B)** Experience as a mechanic or inspector in a motor carrier or intermodal equipment maintenance program\n- **(C)** Experience as a mechanic or inspector in commercial motor vehicle maintenance at a commercial garage, fleet leasing company, or similar facility\n- **(D)** Experience as a commercial motor vehicle inspector for a State, Provincial, or Federal government\n\n## About ASE certification\n\nYou will often hear \"you need to be ASE certified.\" **ASE certification is not listed in §396.19.** Neither is any other specific credential.\n\nThat doesn't make ASE irrelevant — an ASE program will very plausibly qualify as a commercial training program under §396.19(a)(3)(ii)(A). But the rule is written around **what you completed or how long you've done the work**, not around who issued your card. If you're documenting an inspector's qualification, name the statutory basis you're relying on. \"ASE certified\" on its own doesn't identify which prong of §396.19 is satisfied.\n\n## §396.25 — brake inspector qualifications\n\nThis is a separate gate, and it's stricter in one respect: it reaches **inspection, maintenance, service, and repairs**, not just inspection.\n\nA \"brake inspector\" under §396.25(b) is any employee responsible for ensuring that brake inspections, maintenance, service, or repairs on a commercial motor vehicle meet applicable Federal standards. §396.25(c) prohibits a carrier from requiring or permitting anyone who doesn't meet the qualifications to be responsible for that work.\n\nAgain, all three prongs:\n\n1. **Understands** the brake service or inspection task and can perform it\n2. Is **knowledgeable of and has mastered** the methods, procedures, tools, and equipment for the assigned brake task\n3. Is **capable by experience, training, or both**:\n\n**(i)** Successfully completed an apprenticeship program sponsored by a State, a Canadian Province, a Federal agency, or a labor union; **or** a training program approved by a State, Provincial, or Federal agency; **or** holds a certificate from a State or Canadian Province qualifying the person for the assigned task — **including passage of the Commercial Driver's License air brake tests in the case of a brake inspection**;\n\n**or (ii)** brake-related training or experience (or a combination) totaling **at least one year**:\n\n- **(A)** A training program sponsored by a brake or vehicle manufacturer, or a similar commercial program covering brake maintenance or inspection similar to the assigned task\n- **(B)** Experience performing similar brake maintenance or inspection in a motor carrier or provider maintenance program\n- **(C)** Experience performing similar brake maintenance or inspection at a commercial garage, fleet leasing company, or similar facility\n\nNote that (ii) is specifically **brake-related** training or experience. A year of general shop experience doesn't automatically carry over.\n\n## You must keep proof\n\nBoth rules require the carrier or provider to retain evidence of qualification.\n\n**§396.19(b)** — retain evidence for the period during which the individual performs annual inspections for you, **and for one year after**. Not required for inspections performed as part of a State periodic inspection program.\n\n**§396.25(e)** — retain evidence at your principal place of business, or at the location where the brake inspector is employed, for the period of employment in that capacity **and for one year after**. One exception: you don't have to keep evidence of qualification to inspect air brake systems for inspections performed by someone who passed the CDL air brake knowledge and skills test.\n\nIn practice this means an inspector's qualification file has a life of its own, outlasting their employment by a year. If you're a shop performing inspections as an agent under §396.17(e), this is a filing obligation you own.\n\n## Shops performing inspections for carriers\n\nIf you're a commercial garage, fleet leasing company, truck stop, or similar business inspecting other people's equipment under §396.17(e), two conditions attach to your business, not just to your technician:\n\n- You operate and maintain **facilities appropriate** for commercial vehicle inspections\n- You employ **qualified inspectors** as required by §396.19\n\nBoth are stated in §396.17(e) as conditions on using an agent at all.\n\n## Related\n\n- [Annual DOT inspection requirements](/kb/annual-dot-inspection-requirements) — §396.17\n- [Appendix A pass/fail standards](/kb/appendix-a-inspection-standards)\n- [Inspection recordkeeping requirements](/kb/dot-inspection-recordkeeping) — §396.21\n\n---\n\n*This page summarizes 49 CFR Part 396 as revised through the 2025 edition. It is informational only and does not constitute legal or regulatory advice. Regulations change and State requirements vary. Consult the current [eCFR](https://www.ecfr.gov/current/title-49/part-396) and your State's requirements.*",
  "license": "CC BY 4.0",
  "licenseUrl": "https://creativecommons.org/licenses/by/4.0/"
}