3 Easy Ways to Prevent Cargo Securement Violations
TORONTO – What you don’t know will hurt you. That bit of generally good advice can be applied to things like bull fighting, firearms and cooking. And cargo securement too, it seems.
For years, the most pervasive law governing cargo securement was good old-fashioned common sense. That’s no longer good enough, and in fact may cause you even more problems. What may seem intuitive to most could be an infraction to the trained eye of an inspector. It’s as often incorrect procedures that will get you into trouble as inadequate tools.
Regulations governing cargo securement are among the most complex of all the rules we have to follow. In many cases, specific rules govern specific types of cargo. And where no specific rules can be made to apply, inspectors refer to a combination of several other rules that your best efforts will be judged against at roadside-or sometimes, it seems, they just make up the rules as they go. Flat-decking is nerve-wracking.
In all of 2012, Commercial Vehicle Safety Alliance (CVSA) inspectors conducted about two million vehicle inspections across North America. In the cargo-securement sphere, the most common violation found during roadside inspections was “failure to prevent shifting cargo” which accounted for 16,345 citations and a corresponding number of points added to fleets’ safety scores.
Next was “leaking/spilling/blowing/falling cargo” with 10,872 charges. With fines ranging from $250 to over $400 per violation, something in the order of $8.8 million in fines (an estimate using averages) was paid by fleets and drivers.
“Those two cover a multitude of sins,” says Will Schaefer, director of vehicle programs at CVSA. “They are easy for an inspector to spot, and while the officer could get specific about a citation, failure to prevent shifting cargo generally implies the driver hasn’t taken all the steps necessary to properly secure an article of cargo. The other is often related to loose material on the deck of a trailer or cargo box, or material blowing out of the top of a dump box with poor tarps.”
So, those are the two one-size-fits-all citations that will get a driver just about every time. But Schaefer also shared the remaining three most-commonly cited violations in North America. Other violations might top a different list drawn up in northern Alberta where a lot of heavy equipment is hauled around, or in central New Brunswick where logging predominates.
These three will get you almost every time.
1) Damaged Securement Systems (13,151 violations in 2012)
49 CFR 393.104(b) & NSC Sec. 4, subsection 1-3.
“The statistics tell us that damaged or defective tie-downs, loose or unfastened tie-downs, and simply not having the required number of tie-downs are the most common violations we find at roadside,” says Keith Kerns, an investigator with the Public Utilities Commission of Ohio and a member of CVSA’s International Safety Team.
Damaged straps could be downgraded or zero-rated, depending on the extent of the damage, as determined by the strapping defect table in CVSA’s Out-of-Service Criteria handbook. This issue dovetails with item 3 below, failure to meet minimum tie-down requirements.
2) Loose/unfastened tie-downs (8,036)
49 CFR 393.104(f)(3) & NSC Sec. 4, subsection 3 and Sec. 19, subsection 1-5.
Regulations in both countries are specific about the driver’s obligation to maintain tension on cargo securement devises. This usually involves an inspection shortly after getting under way, and regular checks throughout the trip to ensure nothing has moved or worked loose. It’s important to load cargo so that no gaps exist between items that could close up as cargo shifts with movement of the truck.
The regulation requires cargo to be braced against another bit of cargo, so there’s a possible citation there if it hasn’t been loaded properly. As well, gaps can close causing straps and chains to loosen. Chain binders are required to be secured to prevent them from opening.
3) Failure to meet minimum tie-down requirements (2,531)
49 CFR 393.110 & NSC Div. 4, Sec. 22 subsection 1-4.
“The biggest issues related specifically to drivers are calculating the weight of the cargo plus any length requirements that might exist when determining the correct number of tie-downs required,” Kerns says.
He points out, for example, a 5/16-in. grade-70 transport chain has a working load limit (WLL) of 4,700 pounds, but if it’s not marked as such, or the markings are not legible, an inspector in the U.S. would downgrade it to the equivalent of Grade 30 chain, which has a WLL of just 1,900 lb.
In Canada, a rule change in January 2010 zeroes out unmarked securement devices as well as ones with illegible markings. If a driver correctly calculates the aggregate working load limits but uses sub-standard, un- or under-rated equipment, he or she could still be cited, because the WLL might be below minimums. That could result in one of several citations being issued, such as damaged securement systems, insufficient tie-downs or even cargo not immobilized or secured.
“When using chains with binders and hooks, the ‘weakest link’ theory applies,” says Kearns. “The component with the lowest WLL in the assembly dictates the strength of the device. If you have a 4,700-lb chain with a 3,000-lb hook, the chain is only as good as the hook.”
Similarly, unmarked webbed cargo straps in good condition are minimum-rated at 1,000 lb WLL per inch of width south of the border. A properly marked 4-in. strap could be rated as high as 5,400 lbs. If that 5,400-lb strap were downgraded to 4,000 lb because the label or marking was missing or not legible, or zeroed right out of the calculation as it would be in Canada-as if the strap wasn’t even there-the driver could come up short in meeting the minimum aggregate WLL for the cargo.
The driver has to consider the length as well as the weight of the article(s) of cargo and use the correct number of proper tie-downs.
“We’re looking for a minimum of one strap for every 10 feet and fraction thereof in length, with a minimum of two tie-downs for anything longer than five feet,” says Kearns. “For example, an article that is 21 feet long and up against a header board would need a minimum of three straps based on its length and position on the trailer. If it’s not against a header board or in contact with the cargo in front of it, it would need one additional strap. Drivers used to call this the penalty strap.”
Kerns stressed that even if it were just 10 ft 1 in. in length, it would require an additional strap to satisfy the length requirements, as above.
There are tons of little traps in cargo securement. Things like not inspecting your equipment for wear or degradation can catch you high and dry at a scale. A strap or chain may be perfectly good, but if it’s not marked, or the marking has worn off, it’s worth nothing. Mathematically, taking one device out of your cargo securement calculations means you now have an unsecure load. And you’re not going anywhere until the problem is resolved.
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