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IMPERIAL OIL

We’re Almost There

by Jim Park
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The new North American Cargo Securement Standards are with us now officially in most jurisdictions. They are in full force in the U.S. - having passed into law in January 2004 - and subject to full enforcement. But in typical Canadian fashion, the provinces are phasing in implementation and enforcement of the rules one jurisdiction at a time - each with its own timeframe. Canadian inspectors are stopping non-compliant trucks, but aren't handing out tickets at this point.

Loads that don't meet even the previous standards are being ticketed and placed out-of-service, but our inspectors are working with drivers who are still missing some of the finer points of the new rules. They're not issuing tickets but handing out written warnings of the inconsistency. Full enforcement of the new rules will begin in Ontario in July, with other provinces following suit later in the year.

Overall, the reports from the scales are good with the jurisdictions we spoke to, indicating most drivers are securing cargo in accordance with the new rules. Inspectors are seeing fairly consistent errors, however. Here's a list of the most common violations as reported by several Canadian scale inspectors and supervisors.

Minimum Number of Tiedowns

Jeff Hudebine, an Enforcement Coordinator with MTO's Kingston district office, says the issue that arises most often at Ontario scales is the number of tiedowns in use. The standard requires that the securement system have an aggregate working load limit (AWLL) equal to or greater than 50% of the weight of the cargo. That means if the cargo weighs 30,000 lb, there must be at least 15,000 lb worth of working load limit (WLL) to the securement devices. Generally, that's being complied with, Hudebine says.

"But the new legislation often goes further," he points out. "For example, cargo that's not blocked from forward movement will need at least two straps within the first five ft, and then whatever else may be necessary to meet the 50% WLL requirement."

Hudebine says most drivers are complying with the weight and length demands, but often miss the additional requirements for forward blocking. Or, where cargo is loaded in tiers totaling more than 6 ft in height above the deck, drivers are required to secure the lower tiers (up to 6 ft off the trailer deck) independently in addition to securing the upper tiers. This is referred to as belly strapping.

The minimum requirements (without forward blocking) are:
n 1 strap for anything 5 ft in length or less, weighing less than 500 kg;
n 2 straps for anything 5 ft in length or less, weighing more than 500 kg;
n 2 straps for anything up to 10 ft in length or less, regardless of weight; and as above, one additional strap for any length in excess of 10 ft (an article 11 ft long would require three straps).
--reference NSC 10 Part 1, division 4 - Tiedowns, subsections 21, 22; and Part 2, division 2 - Dressed Lumber, subsections 45, 46, and 47.

Equipment and Machinery
Drivers hauling road building or construction equipment are required to use an appropriate number of properly rated tiedowns as required by the weight of the cargo, and Hudebine says generally drivers are managing that.
"They're using enough tiedowns to cover the weight requirements, but what's changed is a requirement that at least four of the tiedowns have a WLL of at least 2268 kg (5,000 lb)," he says. "In the past, they may have used six tiedowns with an 1,800 kg rating, and that would have met the weight requirement, but the new legislation is quite specific about the ratings of at least four devices."
More tiedowns can be used as per the weight of the cargo, but must at least be properly rated for 5,000 lb WLL.
--reference NSC 10 Part 2, division 7 - Vehicles as Cargo, subsection 89 (4a).

Crushed Vehicles
The weakness in compliance with this section lies in covering the cargo to prevent loose parts from falling off the truck. Hudebine says drivers are not using a suitable material - that term is not precisely defined - that won't rip or tear, or is full of holes. Based on his observations, Hudebine says drivers using sideboards are fine, but the ones who use a covering such as a mesh tarp aren't meeting the new requirements if the material is incapable of restraining falling parts.
-- reference NSC 10 Part 2, division - Vehicles as Cargo, subsection 93 (1&2).

Filling the Voids
Articles of cargo placed side by side must be in full contact and secured by side-to-side tiedowns to prevent them from shifting towards each other, thus loosening the tiedown. Inspectors are looking for voids between articles of cargo, such as lifts of lumber.

This applies to dry vans as well, especially with certain loads, such as rolls of paper or small pallets. DOT inspectors do have to authority to open vans, even sealed ones, to inspect cargo. They will replace the seals and make a notation on the bill of lading.
-reference NSC 10 Part 1, division 3 - Requirements for Cargo Securement Systems, subsection 17 (a,b).

Intermodal Containers
Inspectors in Kamloops, B.C. told highwaySTAR they see a lot of empty containers fastened correctly to a trailer, but extending beyond 1.5M (5 ft) from the rear of the vehicle, particularly in the case of dropdeck or lowboy trailers.
-reference NSC 10 Part 1, division 6 - Intermodal Containers, subsection 86 (3b)

Worth a Mention
The following requirements were mentioned in passing by inspectors and carriers and probably deserve a bit more attention from drivers.
Logging trucks, side stakes that are not permanently attached to the vehicle must have a secondary attachment point that prevents it from falling from the vehicle, such as a chain or cable.
--reference NSC 10 Part 2, division 1 - Logs, subsection 29 (3).

The DOT Wrap is not permitted in Ontario, says Hudebine. That's the practice of wrapping strap around a rubrail. In fact, wherever practicable, the rules say straps should be routed inside the rail. While it is accepted in the U.S., it isn't in many parts of Canada - this requirement is currently under review, and we'll report on the outcome as soon as the policy is made clear.
--reference NSC 10 Part 1, division 3 - Requirements for Cargo Securement Systems, subsection 15.

Belly Strapping is often required with multiple tiers of cargo, particularly dressed lumber. The exact requirements are complex and subject to several variables, but the scale people continue to see lots of multi-tiered loads not properly secured. Basically, any cargo stacked up to 6 ft above the deck needs one set of straps, with additional straps required for tiers stacked above 6 ft. Please check the Standard for precise requirements.
--reference NSC 10 Part 2, division 2 - Dressed Lumber, subsection 46 (1b), 47.

Hay Bales
The provinces of Alberta, Saskatchewan, and Manitoba have developed particular standards for the transport of hay bales not found in the North American standard. These requirements - much abbreviated here - were adopted and published in March 2005.

All bales must be adequately restrained against movement to prevent bales from becoming unstable and falling from the vehicle. Bales must be loaded without space between them as vibration can close the gap, causing the tiedowns to loosen. All tiedowns must be tensioned as tightly as possible, and must be checked at least once within the first 80 km, and at least every three hours or every 240 km - whichever occurs first - after that.


Round Bales loaded crosswise can only be transported if the bottom tier is secured against rolling by a front- and rear-end structure that is either part of the vehicle structure or firmly mounted to the vehicle, or another securing device that prevents the cargo from rolling is used. Transverse tiedowns are required for the second tier, whether or not a front- or rear-end structure is in place. The second tier should be loaded consecutively in the well(s) formed by the bales in the tier beneath.
Rectangular Bales should be loaded so they interlock within tiers - using different patterns for consecutive tiers - with the largest face of the bale down. Tiedowns should run over V-boards that capture each bale in the top tier. The load should also be secured with transverse tiedowns.

For a complete summary of the above, please reference Manitoba Regulation 37/2005, and the North American Cargo Securement Standard, available at www.gov.mb.ca/tgs/alerts/index.html


What the Yanks are Seeing

Officials at the Federal Motor Carrier Safety Administration (FMCSA) report a good level of compliance, too, but they told us that even after more than a year, they still see many of the same violations driving by the scale house windows over and over again. Here are the top five American violations.
Using damaged securement devices. The most common violation is drivers using damaged or weakened tiedown devices. This includes torn strapping, chains with kinked or opened links, trailers with damaged anchor points, etc. --reference FMCSR 393.104 (b)

Articles not blocked to prevent forward movement. Additional tie downs are required for articles not blocked or positioned against a headerboard, bulkhead, or other cargo. In most cases, at least one extra tiedown may be required.
--reference FMCSR 393.110(b)

Tiedown devices positioned outside the rubrails.

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. --reference FMCSR 393.104 (f)(4)

Prevention against loss of load. Each commercial motor vehicle must, when transporting cargo on public roads, be loaded and equipped, and the cargo secured to prevent the cargo from leaking, spilling, blowing, or falling from the motor vehicle. In other words, this is the violation recorded following a loss of cargo from the vehicle. --reference FMCSR 393.100 (b)

Securing heavy vehicles, equipment and machinery. Drivers hauling heavy equipment or machinery are often found in violation of some part of this section. Equipment must be properly prepared for transport, which includes stowing and securing accessory equipment such as shovels, blades, etc. Crawler tracks or wheels must be restrained against movement in the lateral, forward, rearward, and vertical direction using a minimum of four properly rated tiedowns.
--reference FMCSR 393.130 (all)


 


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