c) Mexico
Mr. Alfredo
Peniche (SCT) reported that Mexico would be reviewing the prospect
of adoption of the North American Cargo Securement Standard, and
would provide a status report at the next meeting.
4. Presentation
and Discussion: Ongoing Management and Interpretation of
the North American Cargo Securement Standard
Mr. Clarke
provided an overview of the process which had been endorsed by
the US and Canada for ongoing coordination and management of the
North American Standard. (Attachment 3). He noted that Mr. Minor
and Mr. Pearson would serve as the technical coordinators for
issues to be considered by each country.
5. Issues
Arising to Date
a) Introduction
- Proposed format and approach for discussions
Mr. Clarke
outlined the proposed approach to addressing issues and concerns,
noting that the agenda was structured to follow the format of
the North American Standard. He invited participants to raise
issues or concerns on subjects in the order they arise in the
standard.
b) General
Cargo Securement Requirements
i) Performance
criteria for cargo securement
There was
a discussion of the performance criteria included in the North
American Standard, and the enforcement policy issued by FMCSA
in a memorandum dated December 31, 2003. It was noted that the
enforcement policy had reduced the maximum deceleration forces
in the forward direction from 0.8 to 0.4 g and in the lateral
directions from 0.5 to 0.25 g.
Mr. Minor
explained that the standard called for cargo securement systems
capable of withstanding the forces which occur in normal driving,
and indicated that FMCSA did not consider a braking maneuver which
produced 0.8 g deceleration to be a normal stop.
Mr. Pearson
expressed concern that the performance criteria in the standard
were intended to address both normal driving as well emergency
maneuvers up to but excluding a crash. He noted that, while the
occurrences may be rare, vehicles are capable of producing braking
forces of 0.8 g deceleration. He suggested that the Working Load
Limit of securement systems should not be exceeded when this occurs,
as the driver would likely continue his trip without replacing
the securement system. He noted that under the approach proposed
by FMCSA, vehicles could be operating on the highway with tiedown
systems which had experienced forces two times greater than their
rated WLL.
It was agreed
that a Task Force would be formed to explore these issues further
and to provide a report prior to the next meeting. It was agreed
that membership would include Messrs Minor (FMCSA), Pearson (CCMTA),
Nguyen (ATA), Abato (WSTDA), and Reynolds (NACM).
Action:
Task Force
Note: A Terms
of Reference will be provided by the co-chairs
ii) Tiedowns and rubrails
Mr. Minor
reported that a number of problems had arisen with interpretation
of the provision in the standard that tiedowns be located inboard
of rubrails "where practicable". He noted that consideration
was being given to removing this requirement from the standard.
In discussion,
concern was raised with removing this requirement, as the rubrail
protects the tiedown from damage. Others raised concern with the
difficulty of ensuring consistent interpretation of "practicable",
and the consequences for uniformity of enforcement between jurisdictions.
A poll of
participants indicated that a majority (four opposed) were in
favor of removing this requirement from the standard. It was noted
that rubrails are not mandatory equipment on vehicles, and the
change proposed would promote greater uniformity.
Co-chairs
recommend to Mr. Pearson and Mr. Minor, that the standard and
Regulation in Canada and the U.S. delete requirement to have tiedowns
within the rubrails.
Action:
Co-Chairs
iii) Rating
and marking securement devices with Working Load Limits
It was noted
that Canada had included provision the National Safety Code which
would introduce mandatory rating and marking of WLL on tiedown
equipment in 2010. It was noted that rubrails are commonly used
as anchor points, even though they do not generally have rated
Working Load Limits. It was also noted that the 5 year phase in
was determined in order to allow carriers a reasonable period
to phase out existing tiedowns equipment and thereby minimize
the economic impact.
It was agreed
that the Co-Chairs would follow up with NHTSA, TTMA and Transport
Canada to explore the issues of rating and marking the strength
of devices used for cargo securement.
Action:
Co-Chairs
iv) Friction
mats
The absence
of manufacturing, testing and rating standards for friction mats
was discussed at length. The manufacturers present provided insight
to the test procedures developed by the Association of American
Railroads (AAR), noting that these are commonly used to establish
the coefficient of friction ratings provided on recycled rubber
mats.
It was agreed
that CVSA would work with representatives of the friction mat
industry to explore the prospects of developing suitable standards.
Action:
CVSA, NRI, Allegheny
Note: A Terms
of Reference will be provided by the co-chairs
6. Other
issues
A number of
other issues regarding the General section of the standard were
raised and discussed.
a) Logs
i) Aggregate
working load limit of tiedowns
Mr. Minor
that several provisions had been inadvertently omitted from FMCSA's
Final Rule in this section, most notably the provision that the
WLL of tiedowns should be at least 1/6 the weight of the logs
(rather than 50%, as in the general requirements). He reported
that corrections would be included in the upcoming NPRM.
ii) Automatic
tiedown tensioning devices
Mr. Pearson
reported that the Canadian standard called for mandatory use of
automatic tiedown tensioning devices on loads of shortwood logs
loaded crosswise as of January 1, 2010.
A number of
other issues were raised and discussed regarding securement of
logs.
It was agreed
that clarification and advice was needed from the forestry industry
representatives who had participated in drafting this section.
It was agreed that Messrs. Minor and Pearson would seek clarification
from these representatives and provide a report for the next meeting.
Action: Minor, Pearson
b) Dressed
Lumber and Similar Building Materials
A number of
issues and questions were raised regarding securement of bundles
of building products. In particular it was noted that large stacks
of drywall are commonly moved without being "unitized"
or bundled, which would allow securement to follow the "general"
section of the standard, rather than the commodity specific section.
It was agreed
that a Task Force be formed to reflect on the Dressed Lumber and
Similar Building Products section of the standard to propose clarifications
and potential improvements in the language. It was agreed that
membership on the Task Force would initially include Messrs. Vander
Zwaag (OTA), Desrosiers (MTQ), Merchus (?), and Church (FPAC).
It was noted that participation would also be open to any other
interested parties.
Action:
Task Force
Note: A Terms
of Reference will be provided by the co-chairs
c) Metal
Coils
A number of
issues were raised and discussed regarding securement of Metal
Coils. Mr. Minor noted that questions and concerns had been raised
with the definition of metal coils, and whether spools of wire
should be included in this section. He reported that the NPRM
would offer clarification.
d) Paper
Rolls
A number of
questions and concerns were raised in this section, particularly
regarding the use of friction mats (number required, size, placement
etc)
It was noted
that larger sizes of paper rolls are becoming more common, and
the section needed revising to include securement requirements
for these rolls. It was agreed that a Task Force would be formed
to review the section and propose amendments. Membership would
initially include Messrs. Nied (?), Church (FPAC), and Downing
(NRI).
Action: Task Force
Note: A Terms
of Reference will be provided by the co-chairs
e) Concrete
Pipe
No comments
or questions were raised with this section.
f) Intermodal
Containers.
No comments
or questions were raised with this section.
g) Automobiles,
Light Trucks, and Vans
i) Transportation
in closed vans
A number of
questions and concerns were raised in this section, particularly
regarding securement requirements for automobiles transported
in closed van trailers. It was agreed that descriptions of specific
scenarios for which clarification is needed, accompanied by pictures
if possible, should be provided to CVSA for distribution.
Action: All members
Provide to
Collin Mooney of CVSA
h) Heavy
Vehicles, Equipment, and Machinery
i) Securement
of auxiliary equipment
Mr. Pete Trimble
(Keen Transport) provided a presentation (Attachment 4) on a number
of securement issues which had arisen with transportation of heavy
equipment and machinery. Of particular concern was the interpretation
of the requirement that "accessory equipment, such as hydraulic
shovels, must be completely lowered and secured to the vehicle".
It was agreed
that a Task Force would be formed to consider the issues raised
and develop proposals for changes to the regulatory language.
Membership on the Task Force would initially include Ed Luna,
Sean McAlister, Guy Desrosiers, Pete Trimble, Doug Elliot, Peter
Krenz, Karen Proctor and a representative from PSAC.
Action:
Task Force
Note: A Terms
of Reference will be provided by the co-chairs
i) Flattened
or Crushed Vehicles
i) Cars
crushed into "logs"
Mr. Eric Harris
(Institute of Scrap Recycling Industries) provided a brief presentation
(Attachment 5) on the different processes used to flatten or crush
cars for transport, including the technique referred to as "logging".
Mr. Mike Mattia (Recycling Risk Management) also spoke to this
item, and suggested that the vehicles which were "baled"
or "logged" greatly reduced the probability of having
loose parts, and should not be required to comply with the commodity
specific securement regulation for flattened or crushed vehicles.
Following
a brief discussion, it was agreed that additional information
and pictures of logged and baled crushed cars would be helpful
to assist participants in understanding the differences between
the different approaches, particularly as related to containment
of loose parts. Messrs. Harris and Mattia agreed to provide additional
information to the committee.
Action:
Harris, Mattia
Provide to
Collin Mooney of CVSA
ii) Synthetic
web tiedowns
The acceptability
of having a short section of synthetic webbing at the end of chains
or cables to allow ratchet binders to be used for tensioning was
raised. In discussion, concerns were expressed with the potential
for the synthetic webbing section to be cut or damaged by sharp
objects or metal edges.
j) Roll-on/Roll-off
and Hook Lift Containers
No comments
or questions were raised with this section.
k) Large
Boulders
Mr. Evans
(NS) noted that some carriers used trailers with metal decks to
transport large boulders, which presents difficulties complying
with the requirement that cribbing used to stabilize boulders
be attached to the deck. He agreed to provide pictures of the
trailers and the securement approach being used.
Action:
Mr. Evans
Provide to
Collin Mooney of CVSA
7. Proposals
for Additional Sections to the Standard
In introducing
this item, Mr. Clarke explained that any proposed additional sections
to the North American Cargo Securement Standard should follow
the format used for commodity specific requirements, and should
satisfy the guiding principles adopted for a "Performance
Based" standard.
a) Hay
Bales
Mr. Taylor
Stack and Ms. Valarie Furtado (Nevada Motor Transport Association
and Nevada Hay Industry Committee) provided a presentation on
issues and concerns regarding securement of hay bales (Attachment
6).
In discussion,
there was general support for developing a new section for the
standard to address securement of hay and straw bales. It was
agreed that a Task Force be formed to develop the section, to
be Co-Chaired by Mr. Alvin Moroz (Alberta) and Mr. Taylor Stack
(Nevada Motor Transport Association). It was agreed that the Task
Force should include representation from both governments and
industry. It was expected that British Columbia, Alberta, Saskatchewan,
Nevada, Oregon, Washington and California would be interested
in participating.
Action: Task Force
Note: A Terms
of Reference will be provided by the co-chairs
b) Metal
Pipe and Sheet Metal
In discussion
it was agreed that a Task Force would be formed to develop a new
section for the North American Cargo Securement Standard to address
securement of metal pipe and sheet metal.
Action:
Co-chairs request volunteers to develop this change, contact Collin
Mooney, CVSA
c) Paper
Bales
In discussion
it was agreed that a Task Force would be formed, to be led by
the Forest Products Association of Canada, to develop a new section
for the North American Cargo Securement Standard to address securement
of Paper Bales and Wood Pulp.
Action:
FPAC
d) Fish
Boxes
It was noted
that several eastern Canadian provinces had proposed adding a
section to the standard to address securement of large boxes used
to transport fish.
Action: John Pearson to Organize Task Group
Note: A Terms
of Reference will be provided by the co-chairs
e) Oil
and Gas
Mr. Peter
Krenz (Mullen Trucking) and Mr. Patrick Delaney (PSAC) provided
a presentation on initiatives of the oil well drilling and oil
well servicing industries develop "best practices" for
cargo securement. It was agreed that the committee would be kept
informed of developments.
Action:
M. Delaney will organize a Task Team to Develop an oil & gas
drilling and service best practices
Note: A Terms
of Reference will be provided by the co-chairs
f) Others
i) Securement
requirements in closed vans
Mr. VanderZwaag
(OTA) raised a number of issues regarding securement requirements
in van trailers, noting that the Standard did not provide much
guidance on when blocking, bracing or void fillers are needed.
He reported that work was underway in Ontario to develop and propose
guidelines that would assist carriers and enforcement officers
in this area.
8. Other Business
No additional
items of business were proposed.
9. Next
Meeting
The co-chairs
thanked all in attendance and reminded them that NACS harmonization
is a work in progress, and that we've just begun the process to
improve the standard, and movement towards harmonization.
The next North
American Cargo Securement Harmonization Committee meeting is scheduled
for immediately following the CVSA Fall Workshop in Biloxi, Mississippi,
September 29th and 30th, 2005.
10. Adjournment
Meeting adjourned
at 5:05 p.m. MDT.
