They
seem to have snuck past us with hardly any notice. In addition to the implementation
of the hours-of-service rule changes in January, a new set of cargo-securement
rules came into effect in the U.S. at the same time. They were issued on September
27, 2002, but haven't had as much press as the new HOS regime. Though carriers
and drivers were encouraged to adopt the new standards as soon as possible,
enforcement didn't begin until the beginning of this year.
Most of the rule changes aren't that dramatic, which is probably what led to
an apparent lack of awareness about them. Still, there are some changes you
should be aware of, and there are now some pretty specific directives on securing
various bits of cargo such as crushed cars, steel coils, and cargo hauled inside
a van body. These rules aren't just for flat-deckers. And, of course, Canadians
are expected to comply with the new American standards while operating south
of the border.Before we get to the must-know stuff, it's worth mentioning that
some confusion exists over certain wording of the new rules. The U.S. Federal
Motor Carrier Safety Administration (FMCSA) has acknowledged the ambiguities,
but says the present policies will remain in effect until it can resolve those
issues.
Working Load Limits
A term you'll read often in the cargo-securement rules is 'working load
limit' or 'WLL'. It's the maximum load that may be applied to a component
of a cargo securement system during normal service, usually assigned by
the component's manufacturer. In determining the minimum requirements
for securing a particular article, officials look at the aggregate WLL
or restraining capacity of all devices used to secure an article of cargo
on a vehicle.
The aggregate WLL of any securement system used to hold an article against
movement must be at least half the article's weight. The aggregate WLL
is the sum of:
(1) One-half of the WLL of each associated connector or attachment mechanism
used to secure a part of the article of cargo to the vehicle; and
(2) One-half of the WLL for each end section of a tiedown that's attached
to an anchor point.
One bit of ambiguity concerns the way cargo in trailers is secured. According
to some in the industry, the wording of the rule can lead to inconsistent enforcement.
The agency made it clear that cargo in a trailer can be properly secured simply
by loading it so that it won't tip, provided that the trailer walls are strong
enough. Not everyone seems to realize that.
Another problem arises from language prohibiting the use of damaged securement
devices. The agency acknowledges that the wording here could be interpreted
to prohibit all cracks and cuts in both the securement device and the vehicle's
structure, whether or not they affect performance. The agency said that is not
its intent, and referenced the Commercial Vehicle Safety Alliance's policy on
cargo tie-down as an enforcement guideline.
Of the many things FMCSA has done right this time around, it outlined very
specific procedures for so-called problem commodities. During public meetings
concerning the development of the model regulations, participants said that
these commodities cause the most disagreement between industry and enforcement
agencies as to what is required for proper securement. Among them: logs; dressed
lumber; metal coils; paper rolls; concrete pipe; intermodal containers; automobiles,
light trucks and vans; heavy vehicles, equipment and machinery; flattened or
crushed vehicles; roll-on/roll-off containers; and large boulders.
FMCSA has detailed proper securement procedures for these and other commodities.
For detailed descriptions of the new tiedown procedures, please see sections
§393.100 to §393.136 of the load-securement regulations 49 CFR 392
and 393.
Among the more common mistakes is the securement of intermodal cargo containers.
Here's what you need to do:
Securement of loaded intermodal containers transported on vehicles other
than container chassis vehicle(s).
(1) All lower corners of the container must rest upon the vehicle, or
the corners must be supported by a structure capable of bearing the weight of
the container and that support structure must be independently secured to the
motor vehicle. (2) Each container must be secured to the vehicle by: (i) chains, wire ropes, or integral devices which are fixed to all lower
corners; or (ii) crossed chains which are fixed to all upper corners; and, (3) the front and rear of the container must be secured independently.
Each chain, wire rope, or integral locking device must be attached to the container
in a manner that prevents it from being unintentionally unfastened.
Not including the cargo-specific tiedown requirements outlined in the
regulations (§393.100 to §393.136), the minimum number of tiedowns
required to secure an article depends on its length. When an article is
not blocked or positioned to prevent forward movement, it must be secured
by at least:
(1) One tiedown for articles five ft or less in length, and 1100
lb or less in weight;
(2) Two tiedowns if the article is:
(i) five ft or less in length, but more than 1100 lb in weight;
or (ii) Longer than five ft but less than 10 ft in length, regardless
of the weight.
(3) Two tiedowns if the article is longer than 10 ft, with one
additional tiedown for every 10 ft of length, or fraction thereof, beyond
the first 10 ft (an article 12 ft long would require three tiedowns).
Securement of empty intermodal containers transported on vehicles other
than container chassis vehicle(s).
Empty containers transported on vehicles other than container chassis vehicles
do not have to have all lower corners resting upon the vehicle, or have all
lower corners supported by a structure capable of bearing the weight of the
empty container, provided:
(1) the empty container is balanced and positioned on the vehicle in
a manner such that the container is stable before the addition of tiedowns or
other securement equipment; and, (2) the amount of overhang does not exceed five feet on either the front
or rear of the trailer; (3) the empty container must not interfere with the vehicle's maneuverability;
and, (4) the empty container is secured to prevent lateral, longitudinal,
or vertical shifting.
And there's a ton of other must-know stuff as well, of course. Such as...
Inspection of Cargo and Securement Devices
FMCSA has revised § 392.9, requiring drivers to inspect the cargo and the
securement devices within the first 50 miles, up from the previous requirement
that drivers conduct an inspection within the first 25 miles. The FMCSA believes
conditions which would require the driver to make readjustments are more likely
to occur after the vehicle has been driven between 25 and 50 miles, rather than
within the first 25.
Use of Tiedowns
• Tiedowns and securing devices must not contain knots.
• If a tiedown is repaired, it must be repaired in accordance with the
applicable standards or the manufacturer's instructions.
• Each tiedown must be attached and secured in a manner that prevents it
from becoming loose, unfastening, opening, or releasing while the vehicle is
in transit.
• All tiedowns and other components of a cargo-securement system used to
secure loads on a trailer equipped with rub rails, must be located inboard of
the rub rails whenever practicable.
• Edge protection must be used whenever a tiedown would be subject to abrasion
or cutting at the point where it touches an article of cargo. The edge protection
must resist abrasion, cutting and crushing.
Use of Unmarked Tiedowns
The new rules do not prohibit the use of unmarked (unrated) tiedown devices.
Due to concerns about the quality or strength of such devices, and the potential
safety hazards of motor carriers misidentifying unmarked tiedowns, FMCSA has
decided that unmarked welded steel chain is considered to have a WLL equal to
that of grade 30 proof coil, and other types of unmarked tiedowns are considered
to have a WLL equal to the lowest rating for that type in the WLL table (see
below).
The working load limit of a tiedown assembly is the lowest WLL of any of its
components, including the tensioner, or the WLL of the anchor points to which
it's attached, whichever is less. If, for example, the assembly includes a chain
and tensioner, each rated at 4700 lb, and one unmarked grab hook, the entire
assembly will be downrated to the WWL of that unmarked hook.
Of course there's much more to the new U.S. cargo-securement rules than you
see here, but this should give you a good place to start. All the detail you
need is on the FMCSA website section called Rules & Regulations, www.fmcsa.dot.gov/rulesregs/fmcsrhome.htm,
or you can download a copy of the Final Rule, containing the information, from
the highwaySTAR website www.highwaystarmagazine.com.
The information presented in this article is general in nature, and not intended
to serve as regulatory guidance. Please consult the Code of Federal Regulations,
Chapter 49, sections 392 and 393 for exact requirements and interpretations.
They
seem to have snuck past us with hardly any notice. In addition to the implementation
of the hours-of-service rule changes in January, a new set of cargo-securement
rules came into effect in the U.S. at the same time. They were issued on September
27, 2002, but haven't had as much press as the new HOS regime. Though carriers
and drivers were encouraged to adopt the new standards as soon as possible,
enforcement didn't begin until the beginning of this year.
