With the continued success of the North American Free Trade Agreement (NAFTA) and the continued growth of cross-border transport of products, members of The Maintenance Council (TMC) discussed how they should comply and provide fleet maintenance under the new North American Cargo Securement Standard (NACSS). Shippers, transporters, and trailer manufacturers discussed the implications of the proposed law and maintenance issues at the 1999 Fall Meeting in Tampa, Florida.
Trailer and body manufacturers realize their manufacturing designs will play a role in the operator's ability to use the equipment for specified applications. TMC members discussed the role of manufacturers in promoting designs that will allow for easier maintenance of trailer and body equipment.
Manufacturers' Role in Securement "Manufacturers will have an important role because this proposal will require trailer builders and the fleet managers who set the specifications to really look at their hardware selections and where they locate anchor points," said Roger Ohman, vice-president of The Crosby Group.
His words were echoed during the TMC meeting as trailer and body manufacturers addressed concerns focusing on the labeling and location of anchor points for both platform trailers and dry freight bodies.
A specific area of concern centers on not only the location of the anchor points, but the question of acceptable testing practices for the anchor fixtures. Manufacturers will be required to design, test, and build the product in a form that empowers the carriers to comply with enforcement guidelines. However, NACSS currently does not stipulate specific manufacturing guidelines for the hardware selection, strength, or placement on or inside a trailer or van body.
Under the proposed NACSS regulation, anchor point strength is a critical factor to be considered in the construction of van trailers and platform bodies. NACSS does not stipulate the methodology to be used in the testing. It only stipulates the required benchmarks of the minimum strength requirements.
G-Force Requirements NACSS draft language currently states that cargo securement systems must withstand the forces that result when a loaded vehicle is tested by the following:
*0.8 g deceleration in a forward direction;
*0.5 g deceleration in a rearward direction;
*0.5 g acceleration in either lateral direction.
Additionally, if the cargo is not fully contained by the structure of the vehicle, the securement system also must provide securement for a downward force equivalent to not less than 20% of the weight of the cargo.
Bulkheads and van sidewalls must be able to withstand the g-force requirements that the regulation mandates, and labeling plates would be used to disclose bulkhead and van sidewall strength capacities.
Trailer and body manufacturers are asking what strength of hardware should the manufacturer install to work in conjunction with the other tools used in the load containment effort. This issue then becomes part of a greater overall question.
TMC and other industry bodies are trying to determine how the transportation inspectors will audit anchor point locations and strength ratings. This may prove to be a thorny issue for some carriers of coiled steel and other highly visible commodities that have been involved in, or may have inadvertently caused catastrophic damage during a major accident.
Trailer manufacturers along with the chain, webbing, and binder manufacturers presented information that will be used in the proposed Recommended Practice (RP). TMC will issue the RP on cargo securement and its maintenance once NACSS is fully implemented.
The Truck Trailer Manufacturers Association (TTMA) has proposed several procedures that will provide a unified and recognized testing methodology for the trailer manufacturers. "We want to make certain there is agreement in the testing procedures of anchor points, bulkheads, and other components by introducing RP#47-99 (Issued June 1999)," said Dave Bixler of Fontaine Trailer at a TTMA meeting in 1999. "RP #47-99 will set the tone for anchor point testing in trailers and van bodies."
TMC is interested in how trailer manufacturers will follow RP#47-99,because the installation of these anchor points will be an ingredient in the proposed maintenance RP that TMC will present. TMC will review this information and may incorporate the testing methodology when drafting the RP for maintaining the securement systems.
TMC members additionally highlighted several suggestions for the trailer manufacturer's help in making certain that the labeling systems remain readable after the trailers have been in use for several years. Further consideration will be given in the RP draft to instruct trailer operators on how to relabel the trailers, bulkheads, chains, load binders, and other parts of the cargo securement system after normal wear of the equipment.
Stake Pockets Provide Correct Load Angles TMC members also reviewed the importance of properly specing the equipment. Fleet managers will have to provide information to the trailer manufacturer about required load-securement pockets or inside van body securement systems and their locations.
Although the regulation does not specify the number of tie-downs per trailer, van body, or platform body, requirements based on the type of cargo carried would require the tie-downs to be in place to comply with the proposed regulation.
Some TMC members also voiced concern because of the special needs of their particular transported products. These transporters asked trailer industry executives to explore any remedies for bringing their cargo containment practices into compliance.
An example of an industry looking at containment issues can be found in the poultry shippers. A group of poultry shippers indicated that due to the width of the poultry cages, the loads extended beyond the outside of the platform trailers. Under the proposed form of NACSS, no load may extend beyond the side of a platform trailer and be considered in compliance. At this time it is unclear if this specific situation may be remedied by some form of exclusionary provision or by some other form of permit exemption.
A prime component of the securement issue is the understanding of load binders and how they achieve mechanical advantage to secure a load. Binder manufacturers are recommending that the RP include the operation of load binders, the mechanical principles involved in them, and their maintenance issues.
Areas that warrant instruction include when to use a handle extender to load-down on a load binder and what to look for when inspecting a binder. Also, be cautious and understand the dangers involved in exposing a binder to a side load. The Crosby Group, a manufacturer of load binding equipment, suggests that load binders not be put under a side load.
TMC members were reminded that the proposed regulation indicates that behind-cab protectors and rub rails are not considered part of the cargo securement or anchor devices.
Harmonize In 1993, work began on drafting a Canadian National Safety Code standard for load securement. The Canadian Council of Motor Transit identified the need for more current research into the mechanics of load securement systems. As the Canadian study progressed, and with the advent of NAFTA, US transportation experts realized the importance of having a standardized agreement for the practical purposes of enforcement as transporters increase the border crossing activities.
A harmonization group was assembled representing Canada, Mexico, and the United States. This group composed of industry and governmental safety officials is studying the proposed draft regulations of the various countries involved in order to assure a standardized rule structure for transportation inspectors to follow.
Currently in the US, NACSS is at the Proposed Rule Stage and is being reviewed by the Federal Highway Administration and the Department of Transportation.