You can’t get away with much when you pull a flatdeck. Unlike van drivers who can usually hide their sins behind closed doors, your skill and expertise at tying loads down is on display for all the world to see. Motorists and other drivers can cast a quick eye over your handiwork as you drive by. And who hasn’t?
We’ve all noticed the good loads going by, wrapped so tight you could bounce a quarter off the tarp. We notice the other ones too. Tarps billowing in the wind, loose straps, slack chains, and even boards working their way out of lumber bundles because they’re not clamped down tight enough. Scarier still are the 40,000-lb steel coils with only a pair of chains keeping them in place.
Don’t think for even a second that the cops don’t notice this stuff, too.
The recently released Ontario Auditor General’s report on enforcement efforts in that province declared "insecure loads" to be the top mechanical out-of-service "defect" for 2007. Similarly, CVSA reports that load/cargo securement violations accounted for more than 422,000 recorded violations across North America for the same year.
That’s a staggering number when you consider how remote the possibility is of getting pulled around back for an inspection. Of the 4.9 million violations noted by CVSA in 2007 — in 323 categories, nearly 10 percent were load-securement related.
You’ll be surprised to hear what the "Top 5" violations were. We polled CVSA (Commercial Vehicle Safety Alliance) and three provinces, looking for that short list. While everyone said there really was no official list, anecdotally, no one had any difficulty describing the more common problems noticed by inspectors at roadside.
In Nova Scotia, for example, melt water running out of trailers hauling loads of fish contained in tote bins is of particular concern, as are dump truck loads of crushed limestone running around without dust tarps, loads of crushed cars covered with improper mesh, and improperly secured loads of modular homes.
"The problems we see tend to be location specific," notes Don Evans, Commercial Vehicle Compliance manager with Nova Scotia’s Department of Transportation and Infrastructure Renewal. "We really notice the melt water at the scales located at the Canso Causeway, especially when my guys have to climb down into the scale pit to perform maintenance."
North American Cargo Securement regs have been in development since 1993, yet we still don’t have universal agreement on enforcement.
John Mead of Saskatchewan’s Transport Compliance Branch told us loose material laying on the deck of the trailer or somewhere on the chassis is a real concern, as are, again, untarped dump truck loads.
"I’ve seen hammers, bars, and lots of junk and debris like big chunks of dirt or rocks from the track of a Cat, for example," he says. "And then there are the loads of gravel that spray from dump trucks onto passing cars."
Ontario has a broad manufacturing base, and consequently, a variety of problems in different areas of the province, notes Warren Reynolds, the Ministry of transportation‘s (MTO) senior enforcement advisor and provincial training coordinator. He notes "predictable" types of violations in areas where, for example, steel hauling or logging predominate.
Reynolds also says MTO is beginning to make more observations of van trailer interiors, but isn’t taking aggressive action — yet.
"We’ve seen a few loads that demanded action, but mostly we’re just looking," he says. "One of the worst I’ve seen was a load of steel auto parts bins loaded down the centre of the van with no blocking or securement devices of any kind to keep the bins in place. The floor was like a skating rink from all the oil dripping from the parts. You could push those bins around the trailer floor by hand. I asked the driver if he had ever had a problem with a load like this, and he said, ‘no, I just take it easy going around corners.’"
Colin Mooney, director of Enforcement Programs, at CVSA’s Washington, D.C., office said in addition to unsecured roll-off containers, inadequate scrap car coverings, and loose articles on the truck body, the most serious concerns stem from damaged or inadequate tiedowns and anchor points.
"I’d have to say we’ve still got some real work to do in getting operators to inspect their tiedown equipment more regularly," Mooney says. "When you add up the number of violations stemming from inadequate or improper tiedowns, it suggests there’s still — after all these years — a great deal of misunderstanding out there."
And that point was echoed in varying degrees by all the others too.
The Sum of the Parts:
According to MTO’s Reynolds, drivers are for the most part using the correct number of tiedowns and they are putting them on properly. "But," he notes, "often the device is damaged — even in some minor way — and that compromises not only the integrity of the tiedown, but its working load limit (WWL), which is something we check when determining the aggregate WWL of the package of tiedowns."
For example, a length of 5/16 Grade 70 Transport chain has a WWL of 4,700 lb. If any of the links in the chain was damaged (bent, cracked, twisted, gouged, opened, etc.) that chain’s WWL as calculated by the inspectors would automatically be downgraded to zero. In addition, if a component of the chain assembly, say the grabhook, were not the same grade as the chain, or if the grade could not be determined, the entire assembly would be downgraded to what they call Grade 30 Proof Coil, which has a WWL of only 1,300 lb.
Strapping outside the rub rail is now permitted by the U.S. Some Canadian jurisdictions still do not permit this, though.
If an article of cargo requires two chains with a 4,700-lb WWL, and one was damaged or unrated, the aggregate WWL of the tiedown assembly would be reduced accordingly. You now have an insecure load — and a ticket.
The same thinking applies to webbed strapping, although the outcome in this case is less precise and subject to more interpretation. For example, most jurisdictions will permit cuts or damage in 4-in. webbed strapping totaling up to 3/4 in. If more than one cut exists, the sum of the cuts is applied. Anything exceeding 3/4 in. anywhere along the length of the strap would zero it out, which could compromise the aggregate WWL of the tiedowns used on an article of cargo.
Knotted straps are not permitted, and have a WWL of zero. Strapping that "appears" to be worn out due to age and exposure, or straps that have been repaired are presently under scrutiny. Inspectors are suspicious of some of the rattier looking straps, but so far have no grounds to disqualify them — unless they’re damaged.
Ralph Abato, director of sales and marketing at Ancra International — a leading webbed strapping supplier — says there is a proposal on the table at the Web Sling & Tie Down Association that would set standards for web quality, stitching patterns, and general physical condition requirements for webbed straps.
WSTDA is currently preparing to do widespread testing to determine empirically just what degradation there is from UV rays, and cuts and abrasion at certain levels.
"We need this testing to support our claim that any damage is significant," Abato says. "To quantify by arbitrary dimensions as CVSA does now, is without support. The association is hard pressed to support the CVSA’s Out of Service Criteria for damaged straps."
Abato also cautions that repairing damaged strapping is not a good idea.
"No repairs to webbing can be deemed safe," he claims. "If it looks old and worn, it probably is. You would be surprised how badly deteriorated straps can become with little damage or cuts. It’s best to err on the side of safety and replace old-looking or damaged cargo straps."
WSTDA is also proposing a ban on repaired straps.
While there are dozens of separate requirements, one could easily run afoul of the North American Cargo Securement Standard Model Regulations — and dozens more where local interpretations differ from the North American standard — the non-cargo-specific errors drivers make are relatively easy to fix.
Expensive and time-consuming in some cases, but solutions to what officials told us are the common problems aren’t rocket science — except maybe what to do about leaking fish juice, but that too is a cargo-securement issue.
Several publications are available as training aids and resources for drivers. Some are free, some come at a modest price, but even a single violation would be 10 times the cost of the most expensive book we could find.