Surely, a vehicle dealership cannot imagine functioning without its inspection licenses. Yet, in the past year I have seen dozens of state inspection licenses (safety and emission) have suspensions imposed for sticker security concerns. Part of the reason this happens is because a first violation of inspection sticker security is a warning, so often it is not seen as a serious threat to a license. However, when that second violation occurs, the penalty is a three-month suspension of the inspection license. Now everyone is at attention.
In my many years of practicing law, I have never seen PennDOT as aggressive with sticker security issues as they are of late. If you have not done so, now would be an excellent time to review your sticker security obligations and practices, to hopefully avoid even the first offense for sticker security concerns. The law requires licensed inspection stations to do the following relative to sticker security:
- A record must be kept of every inspection sticker issued – the sticker number issued for a vehicle should be noted both on the customer repair order and in the station’s inspection log (MV-431).
- Retain certificate of inspection requisition forms for each campaign – retain these for a minimum of three years.
- Upon receipt of stickers from PennDOT, audit the order against what was received. Report any errors, no matter how slight, to PennDOT’s Vehicle Control Division.
- Retain the old sticker when replacing a sticker – typically, this will still be affixed to the portion of the windshield cut out when replacing the windshield. The Quality Assurance Officer (“QAO”) will ask to see these old stickers during each audit visit. We recommend retaining these under lock and key so that they are easily available when the QAO conducts the station audit.
- All inspection certificates and temporary inspection approval indicators must be kept under lock and key in a safe place.
- Retain all unused certificates of inspection; they will be reviewed during the QAO audit.
During a QAO audit, the station must be able to account for every sticker it was issued. If a station cannot do this, the high likelihood is that PennDOT will assert a sticker security violation. To ensure the highest level of sticker security compliance possible, we recommend the following steps:
- Retain all inspection stickers (unused, current campaign, voided, replaced) in a locked safe, accessible only by several people, typically management level or service advisors.
- Require technicians to request a sticker only upon completion of an inspection and provide technicians with only one sticker at a time.
- Audit records routinely, preferably every day but no less than once per week, to ensure that all stickers can be accounted for and that the records of all stickers issued are complete.
- Retain sticker requisition forms and sticker order receipts under lock and key.
- Audit all stickers received, to be sure you received what was ordered and not less than or more than was ordered. Report any concerns regarding stickers received (or not received) to PennDOT’s Vehicle Control Division immediately.
- Report any concerns regarding missing stickers or sticker security generally to your QAO upon discovery.
- In the event any stickers go missing, we recommend an immediate internal investigation be conducted. If it is believed stickers have been stolen, law enforcement should be contacted – retain all police and internal investigation reports.
You cannot be too vigilant with inspection sticker security. Even doing so, you may have stickers go missing or for which you cannot account during an audit. However, the likelihood of that happening is lessened with good accountability on the front end, which can also mitigate penalties in the event there is a breakdown in sticker security.