By Sandra Brakstad, President of Midwest Compliance Inc.,
Sauk Rapids Minnesota
800-656-1396
http://www.midwestcompliance.com/

To be compliant with DOT regulations, drivers and motor carriers must ensure that their vehicles and securement devices meet the required performance standards. All vehicle structures, systems, parts, and components used to secure cargo must be in proper working order. The use of damaged, weakened, cut or cracked components – or any condition that would adversely impact the performance of the securement components is prohibited.

Vehicle structures must also meet required performance criteria, (see §393.104 FMCSR). Make sure the vehicle floors, walls, decks, tiedown anchor points, header boards, bulkheads, stakes, posts and mounting pockets, and the vehicle structure itself are strong enough to support your cargo.

Tiedowns may not contain knots. If a tiedown is repaired, it must be done according to the manufacturer’s instructions. Each tiedown must be attached and secured in a manner that prevents it from becoming loose, or from 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 inside of the rub rails, whenever practicable. Edge protection must be used whenever a tiedown could be subject to abrasion or cutting at the point where it touches the cargo. The edge protection itself must resist abrasion, cutting and crushing.

Cargo must be firmly immobilized or secured on or within a vehicle by structures of adequate strength, dunnage or dunnage bags, shoring bars, tiedowns or a combination of these. Articles of cargo that are likely to roll must be restrained by chocks, wedges, a cradle or other equivalent means. Make certain chocks or wedges, etc., cannot become unfastened or loose while the vehicle is moving.

The Working Load Limit (WLL) is the maximum load that may be applied to a component of a cargo securement system during normal use. For instance, the WLL of a tiedown is the lowest WLL of any of its components (including tensioner), or the WLL of the anchor points to which it is attached, whichever is less; and the WLL of tiedowns may be determined by using either the tiedown manufacturer’s markings or the standard specifications the manufacturer is required to comply with for testing.

The manufacturing standards that all tiedown assemblies must meet are available from the manufacturer, or information and copies may be obtained by writing to: Underwriters Laboratories, Inc., 333 Pfingsten Road, Northbrook, Illinois 60062.

For steel strapping contact the American Society for Testing and Materials, 100 Barr Harbor Drive, West Conshohocken, Pennsylvania 19428, and ask for the ASTM D3953-97 specs. If steel strapping is not marked by the manufacturer with a WLL, it will be considered to have a WLL equal to one-fourth of the breaking strength listed in ASTM D3953-97. One inch or wider steel strapping must have at least two pairs of crimps in each seal and, when an end-over-end joint is formed, must be sealed with at least two seals.

For chains, information may be obtained from the National Association of Chain Manufacturers, P.O. Box 22681, Lehigh Valley, Pennsylvania 18002. Welded steel chain, which is not marked shall be considered to have a WLL equal to that for grade 30 proof coil chain.

Information on Synthetic Webbing is available from the Web Sling and Tiedown Association, Inc., 5024-R Campbell Boulevard, Baltimore, Maryland 21236.

Wire rope, which is not marked by the manufacturer with a WLL shall be considered to have a WLL equal to one-fourth of the minimum strength listed in the manual. Wire Rope information can be obtained from the Wire Rope Technical Committee, P.O. Box 849, Stevensville, Maryland 21666.

Manilla, polypropylene fiber, polyester fiber or, nylon rope information is available from the Cordage Institute, 350 Lincoln Street, 115, Hingham, Massachusetts 02043. Synthetic cordage, which is not marked or labeled to enable identification of its composition or WLL shall be considered to have a WLL equal to that for polypropylene fiber rope.

How many tiedowns should you use? The Feds have determined that the majority of cargo-securement related accidents involve either an inadequate number of tiedowns or the improper placement of tiedowns. The minimum number of tiedowns required to secure an article or group of articles against movement depends on the length and weight of the article(s). When cargo is not blocked or positioned to prevent forward direction movement by a header board, bulkhead, or other blocking devices, (including other cargo), it must be secured by tiedowns as follows:
One tiedown for articles five feet or less in length, and 1,100 pounds or less in weight;

Two tiedowns for articles five feet or less in length and more than 1,100 pounds; or longer than five feet, but less than or equal to ten feet in length regardless of the weight.

Two tiedowns are also required if the article is longer than ten feet. Plus, there must be one additional tiedown for every ten feet of article length, or fraction thereof, beyond the first ten feet of length.

Exceptions to the above guideline: The above tiedown requirements do not apply to vehicles transporting one or more articles of cargo such as, but not limited to, machinery or fabricated structural items such as steel or concrete beams, cranes, booms, girders, and trusses, which because of their design, size, shape, or weight, must be fastened by special methods.

If you have additional questions regarding the performance criteria for cargo securement devices and systems, refer to FMCSR §393.102, under the rules and regulations tab on the Federal Motor Carrier Safety Administration’s website http://www.fmcsa.dot.gov/. The WLL tables can be found in §393.108 at the same web address. Specific securement requirements by commodity type are located in §393.116 – 136.

Next month we should have details regarding Minnesota’s new guidelines for commercial drivers license disqualifications. Until then, take it one load at a time!

Sandra Brakstad
http://www.midwestcompliance.com/
800-656-1396