Development of A Uniform North American Cargo

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North American Cargo
Securement Standard
www.ab.org/ccmta/ccmta.htm
Report to the Vehicle Safety and
Inspection Committee
August 2001
1
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
2
So what’s the problem?
3
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
4
5
Standard Development - Organization
Canada
United States
Mexico
Council of Deputy
Ministers of
Transportation
Federal Motor
Carrier Safety
Administration
Secretaria de
Comunicaciones Y
Transportes
CCMTA
CVSA
North American Standard Harmonization Committee
Membership:
Open to all public & private stakeholders
and other interested parties
6
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
7
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
8
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
9
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
10
Standard Development - Milestones
• Standards Harmonization Committee
formed
December 1997: • Research program completed
May 1998:
• Agreement on format of standard; first
draft model regulation tabled
January 1999: • Model Regulation Draft 3 completed;
Canadian stakeholder consultation
May 1999:
• Draft Model Regulation completed &
committee disbanded
December 2000: • FMCSA issues Notice of Proposed
Rulemaking
Spring 1996:
11
Standard Development - Milestones
February 2001: • CVSA/CCMTA convene meeting of
March 2001:
Fall 2001:
US stakeholders
• Deadline for comments on Proposed
Rulemaking
• Final rule expected to be issued by
FMCSA with implementation 1 year
later
12
13
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.
14
Performance Criteria
Vertical
(bumps, rough roads)
Rearward
(accelerating,
braking in reverse)
Forward
(braking)
Sideways
(cornering)
15
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
16
Securement Approaches
Contained
Van Bodies, Tankers,
Dump Boxes
Blocked
Direct
Headboards, Sides,
Tailgates, Blocking &
Bracing
Attached
Twist locks, Direct Tiedowns
Friction
Indirect
Weight of load + Tiedowns
17
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
18
Blocked Cargo
Cargo is restrained against movement in at least one
direction by vehicle structures, such as headboards or
bulkheads, or other cargo.
19
Attached Cargo - Direct Tiedowns
Cargo is restrained by tie-downs which are attached
to both the vehicle and the cargo.
20
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.
21
22
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
23
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.
24
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
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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
26
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
27
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
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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.
29
FMCSA Proposed Rule
• Includes majority of principles and requirements of
Model Regulation
• Docket Number 2289 at http://dms.dot.gov
• 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
30
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
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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
32
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
33
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
34
Training Program - Background
• Fall 1999 - Training Committee formed; funding
assembled
• Spring 2000 - Terms of Reference for training
program completed
• Summer 2000 - Request for proposals issued &
consultant selected
• Winter 2000/01 - Training program developed based
on requirements of Model Regulation
35
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
36
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
37
Organization - Modular
North American
Cargo Securement Training
Module #1: Fundamentals of Cargo
Securement
Module #2: Standard Application,
General Provisions and Requirements
Module #3: Logs
General
Securement
Requirement
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
Commodity
Specific
Requirement
Module #11: Flattened or Crushed
Vehicles
Module #12: Roll-on/Roll-off Containers
Module #13: Large Boulders
38
Status
• Drafts completed:
– instructor manual
– accompanying slides
– participant manual
– driver handbook
• Initial draft script for accompanying video
– video shooting not yet initiated
39
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
40
Next Steps
• Review training program materials to identify
necessary changes
– complete training materials and video (~ 3- 4
months)
41
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
42
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