Transportation industry professionals hold many opinions about load securement, but only one set of regulations governs the industry. Those regulations can be found under 49 CFR Part 392 and Part 393.
The Federal Motor Carrier Safety Administration (FMCSA) has continually evolved over the last few years to provide performance- based regulations across a wide spectrum of industries that transport goods and products. Plain and simple, the FMCSA regulations are intended to reduce commercial motor vehicle (CMV) accidents.
Improperly secured loads can carry some pretty severe consequences, including:
Commercial motor carrier enforcement officials say that proper load securement is a simple concept. In any expected situation, from a hard turn on a steep mountain grade to a sud- den hard stop in rush-hour traffic, a load must not move on the deck. The only circumstance that should ever affect a load’s securement is a crash. Even then, a properly secured load should remain intact with the deck. Many rollover acci-dents do, in fact, end with the load still secured on the vehicle’s deck.
The FMCSA enforcement program, initiated in December 2010, is known in the industry as CSA (Compliance, Safety, Accountability). CSA has seven measurement categories called BASICS. Most DOT violations fall under one of the BASIC categories.
The BASICs include:
Most people who transport equipment for a company in the equipment or crane rental industries come under the CSA enforcement program, and likely have a company-specific CSA safety rating score.
CSA assigns penalty points (“severity scores”) to violations issued by law enforcement. FMCSA says that severity scores reflect the potential risk that a violation can cause an accident, although many in this industry question the methodology and penalty scores assigned to numerous violation types. The CSA program also includes a time-weighting factor, which is higher for the first six months after a violation occurs, and decreases over 24 months.
CSA safety ratings are ranked on a scale from 0 to 100, with higher scores often indicating compliance issues involving a particular BASIC category. Load securement violations, for example, can push a company’s BASIC in vehicle maintenance higher. Motor carrier BASIC scores are monitored on a two-year snapshot, so violations under each BASIC category will be measured for two years from the time of issue.
Drivers are also subject to the CSA enforcement program. Violations issued directly to a driver by CMV enforcement will attach to his or her CSA profile for three years. The FMCSA computer system lets the enforcement community see any DOT inspection or violation a driver has had within 36 months, so drivers with a heavy trail of violations may find themselves being inspected more thoroughly.
A driver’s crash history is visible for five years under the CSA program. As silly as it sounds, Crash BASIC scores are posted against a company regardless of any fault of the driver or motor carrier.
Load securement violations fall under the Vehicle Maintenance BASIC. These violations carry one of the highest severity ratings for drivers and carriers, ranging from 8 to 10 points per violation. Companies and drivers that are careless about proper load securement may find themselves on the FMCSA radar for an on-site compliance review, in which a compliance officer comes into the company’s headquarters and spends a few days poring over vehicle inspections, driver performance, maintenance records, and more. A focused FMCSA inspection will not be among a safety professional’s better days.
There are about 100 violations purely related to proper securement of a load on a vehicle. As I noted earlier, many of these violations carry a heavy severity point rating of 10, the top severity rating of all DOT violations. If the violation meets the CSA’s out-of-service criteria, the severity/penalty points will be multiplied by three. A 10-point load securement violation that meets the out-of-service criteria will likely carry a total severity score of 30 points. It’s silly for a driver to rack up that many points by carelessly rolling down the road with loose chains on the trailer deck.
The CSA enforcement program now monitors trucking companies electronically, so just a few load securement violations can quickly put a company or driver in the harsh glare of the enforcement spotlight.
Typically, FMCSA will send a spotlighted company an intervention letter, notifying the company that its safety performance on the road is unacceptable. The letter encourages the company to immediately address the violations and to engage the drivers whose poor behaviors led to the violations. Being in the enforcement spotlight increases the company’s inspection rates on the highways. Motor carrier enforcement officers can instantly view a company’s CSA ratings, along with the inspection selection system (ISS), which clearly highlights safety areas in which the company has performed poorly.
In short, FMCSA is keeping a strong eye on motor carrier safety, and modern electronic data management is making it easier for them to target companies that don’t do well at it.
Securement specifics
CFR Part 393 requires that cargo be con- tained, immobilized, or secured to prevent:
The most frequent violations seen in the rental business include:
The most critical pieces of a load securement assembly are the securement devices—chains, nylon straps, binders, and steel strapping. Each device’s working load limit (WLL) must meet the reg- ulations’ requirements. One often overlooked area is the truck or trailer’s side pockets, deck slots, and tie-down lugs that anchor the binders, chains, and straps. I see flatbed trailers with cracked welds on the side pockets or decks with side lips that are cracked from excessive force used to secure binders.
How to eliminate violations
Drivers who don’t know—and follow—the rules for properly securing equipment are put- ting their licenses on the line. Here are a few best practices that will help you operate safely.
For companies in the equipment rental business, the stakes are higher than ever for understanding your CSA ratings and the impact a load-securement violation can have on your compliance rating. Following proper securement will help you transport equipment safely and effectively while avoiding accidents and violations that can hurt your business.