1 North American Cargo Securement Standard Report to the Vehicle Safety and Inspection Committee August 2001

2 Towards A Uniform North American Cargo Securement Standard Goal: a performance based cargo securement standard which can be uniformly implemented and applied throughout North America Process: joint effort, open discussion and collaboration between governments and stakeholders from Canada and United States

3 So what’s the problem?

4 Background Research program to address problems with cargo securement developed by Ontario MTO in early ‘90’s Research conducted under sponsorship and direction of joint Canada - U.S., public-private partnership Research & testing completed in early 1997 Findings delivered to joint Canada/United States committee to support development of new regulations

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6 Standard Development - Organization North American Standard Harmonization Committee Membership: Open to all public & private stakeholders and other interested parties Canada Council of Deputy Ministers of Transportation CCMTA United States Federal Motor Carrier Safety Administration CVSA Mexico Secretaria de Comunicaciones Y Transportes

7 Standards Harmonization Committee open membership nine meetings held from 1996 to spring 1999 broad participation from both governments and industry –federal, state and provincial governments –trucking industry –shippers –equipment manufacturers

8 Meeting Results Performance Criteria ~ the fundamental basis for cargo securement requirements Format of standard ~ review of existing regulations and models used in other countries Evolutionary process ~ variety of expectations –simple standard: clear, usable and enforceable –practical guide: advice based on research and testing results

9 Meeting Results Convergence to consensus –agreement on scope and application of standard –agreement on performance criteria –agreement on framework for standard: general requirements which apply to all cargo specific requirements for commodities which pose high risk or challenges to securement –agreement on list of specific commodities

10 North American Standard development of a “model” regulation which can be implemented throughout North America ultimate vision of standard in two parts: –“Model Regulation” ~ the regulatory aspects of the proposed standard –“The Guide” ~ elaboration on the regulations, what’s required, what’s good practice, basis for training programs

11 Standard Development - Milestones Standards Harmonization Committee formed Research program completed Agreement on format of standard; first draft model regulation tabled Model Regulation Draft 3 completed; Canadian stakeholder consultation Draft Model Regulation completed & committee disbanded FMCSA issues Notice of Proposed Rulemaking Spring 1996: December 1997: May 1998: January 1999: May 1999: December 2000:

12 Standard Development - Milestones CVSA/CCMTA convene meeting of US stakeholders Deadline for comments on Proposed Rulemaking Final rule expected to be issued by FMCSA with implementation 1 year later February 2001: March 2001: Fall 2001:

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14 Guiding Principle public safety requires that cargo being transported on the highway system must remain on or within the transporting vehicle under all conditions which could reasonably be expected to occur in normal driving and when a driver is responding to emergency situations, short of a crash.

15 Performance Criteria Forward (braking) Rearward (accelerating, braking in reverse) Vertical (bumps, rough roads) Sideways (cornering)

16 Performance Criteria - Implications - the cargo must be secured in a manner which prevents it from falling from, or shifting on, the vehicle when subjected to the forces which would occur with the “performance criteria” - vehicle structures and attachments must be strong enough to supply the necessary restraining forces ~ bulkheads, walls, floors, anchor points etc - the securing equipment must be strong enough to supply the necessary restraining forces ~ tiedowns, chains, ratchets, binders, etc

17 Securement Approaches

18 Contained Cargo Cargo is contained and secured by the vehicle structure, additional securing devices not needed: ~ liquids in tankers, ~ bulk solids in tankers or dump boxes, ~ general freight in van trailers or containers

19 Blocked Cargo Cargo is restrained against movement in at least one direction by vehicle structures, such as headboards or bulkheads, or other cargo.

20 Attached Cargo - Direct Tiedowns Cargo is restrained by tie-downs which are attached to both the vehicle and the cargo.

21 Attached Cargo - Direct Attachment Cargo is attached to vehicle by locking devices, twist locks other integral locking systems. Friction between the load and the loading deck is not relied upon for cargo restraint.

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23 Model Regulation - Outline Part 1 -Application and Objectives Part 2 - General Provisions and Requirements Part 3 - Specific Securement Requirements by Commodity Type Part 4 - Definitions Part 5 - Referenced Standards Part 6 - Default Working Load Limits

24 Part 1 - Application and Objectives Applies to any motor vehicle in excess of 4500 kg (10,000 lb) Cargo must be secured or contained so that it: –will not, leak, spill, blow, fall from, fall through or otherwise become dislodged from the vehicle; or –shift upon or shift within the vehicle to such an extent that the vehicle's stability is adversely affected.

25 Part 2 - General Provisions and Requirements Context: Foundation of standard - requirements that apply to all cargo Establishes basic principles for compliance with standard: –use appropriate equipment to transport and secure cargo –contain or immobilize cargo to prevent shifting or tipping

26 General Requirements Applies to all types of cargo, including those specifically identified in Part 3 –if additional requirements are specified in Part 3, these take precedence Need to satisfy one of three conditions: 1. fully contained by structures of adequate strength, or 2. immobilized by structures of adequate strength to prevent shifting or tipping, or 3. immobilized on or within a vehicle by appropriate means to prevent shifting or tipping

27 General Provisions vehicle structures, floors, anchor points, headboards, bulkheads, stakes, posts, pockets must be strong enough must use a securement method suited to the type, size and shape of cargo tiedowns must be capable of being tightened by driver tiedowns must be inside rub-rails edge protection needed if tiedown could be cut or abraded

28 Part 3 - Specific Commodities Specific additional securement requirements which take precedence over the general requirements: Logs Dressed Lumber Metal Coils Paper Rolls Concrete Pipe Intermodal Containers Automobiles, Light Trucks & Vans Heavy Vehicles, Equipment & Machinery Crushed Vehicles Roll-on/Roll-off Containers Large Boulders

29 Securement System Strength Rating Default WLL Values Chain Synthetic Webbing Wire rope Manila Rope Synthetic Cordage Steel Strapping Friction Mats * –A friction mat shall be considered to provide resistance to horizontal movement equal to 50% of the weight of the cargo resting upon the mat.

30 FMCSA Proposed Rule Includes majority of principles and requirements of Model Regulation Docket Number 2289 at Key differences: structure and format differs from Model Regulation ~ rewritten and recast as amendments to existing US regulations; rules for specific commodities proposed in “question and answer” format does not include minimum or maximum acceptable angles for tiedowns does not propose to require testing and marking of strength of anchor points, tiedowns or other securement or blocking devices

31 US Stakeholder Meeting - February 2001 Consensus: Significance of proposed uniform North American Standard and the unprecedented international government/industry cooperation Importance of maintaining ongoing cooperative mechanism for interpretation, maintenance and amendments to standard Need to ensure an orderly and adequate implementation strategy Need to eliminate the distinction between direct and indirect tiedowns and to provide clear guidance on determining aggregate working load limit of tiedown systems Need to recognize and accept conditions under which movement of cargo (shifting) does not compromise public safety Need to continue development of a orderly strategy to eliminate default working load limits for unmarked components of cargo securement systems

32 Comments to Docket - US Rulemaking Approximately 100 submissions received by March 19 deadline Reaction mixed ~ general support for uniformity Major concerns: –difficulty in distinguishing between direct and indirect tiedowns (fear of inconsistent interpretation) –language in NPRM implying cargo cannot shift under any circumstances –implementation date - propose 18 to 24 months delay to allow for implementation and training

33 Implications for Canada NPRM indicates that form and content of Model Regulation cannot be adopted by US FMCSA NPRM represents new proposed North American Standard if uniformity to be achieved, but Final form of proposal will not be known until FMCSA responds to comments with Final Rulemaking –final rule is “final” ~ cannot be changed without restarting rulemaking process Canadian jurisdictions and stakeholders will have to judge acceptability of US proposal when issued later this year Implementation date - most likely 2002

34 Next Steps Wait for final rule to be issued by Federal Motor Carrier Safety Administration Canadian Provinces will –consider acceptability of US rule for adoption in Canada –develop implementation strategy to coincide with US –Consider options if final US rule not acceptable

35 Training Program - Background Fall Training Committee formed; funding assembled Spring Terms of Reference for training program completed Summer Request for proposals issued & consultant selected Winter 2000/01 - Training program developed based on requirements of Model Regulation

36 Training Program Funding 23 agencies or organizations contributed funding for training (13 Canadian, 10 United States) Assembled to date ~ $180,000 (Canadian) Expenditures to date ~ $ 135,000

37 Training Program Structure: Based on Model Regulation - May 1999 Focus on development of a training course (2 days) comprising: –instructors manual –participants manual –slides to accompany instructors manual –video to accompany/supplement training materials –driver handbook

38 Organization - Modular Module #1: Fundamentals of Cargo Securement Module #3: Logs Module #2: Standard Application, General Provisions and Requirements Module #4: Dressed Lumber Module #5: Metal Coils Module #6: Paper Rolls Module #7: Concrete Pipe Module #8: Intermodal Containers Module #9: Automobiles, Trucks & Vans Module #10: Heavy Vehicles, Equipment and Machinery Module #11: Flattened or Crushed Vehicles Module #12: Roll-on/Roll-off Containers Module #13: Large Boulders North American Cargo Securement Training General Securement Requirement Commodity Specific Requirement

39 Status Drafts completed: –instructor manual –accompanying slides –participant manual –driver handbook Initial draft script for accompanying video –video shooting not yet initiated

40 Training Program Status: –work on hold pending final rulemaking by FMCSA –revisions may be necessary to all draft materials, depending upon content of final rule –review required by Steering Committee and industry experts

41 Next Steps Review training program materials to identify necessary changes –complete training materials and video (~ 3- 4 months)

42 Conclusions Proposed standard represents significant departure from format of most current requirements: –broader scope –greater precision –less interpretation required Proposed requirements do not imply major changes for most commodities: –clarification of general requirements