| Cargo
Securement Standards Harmonization Committee Meeting
- September 27, 1997
Ramada
Renaissance Hotel
Denver,
Colorado
RECORD
OF DECISIONS
In Attendance:
CVSA - R.
Fiste - Co-Chair, CCMTA - L. Pelletier - Co-Chair, CCMTA - S.
McAlister - Secretary, Alberta Transportation and Utilities -
S. Callahan, Alcan/Aluminum Association - B. Moore, Allegheny
Industrial - M. Johnson, Allegheny Industrial - S. Gallant, American
Concrete Pipe Association - C. Malloy, American Concrete Pipe
Association - M. Workman, American Trucking Associations - L.
Strawhorn, Ancra Canada Ltd - N. Reader, Assn of American Railways
- H. Grosso, Assn of American Railways - J. Blackman, California
Highway Patrol - M. Padilla, Canacar - F. Arenan, Caristrap International
- L. Karass, CCMTA Secretariat (Secretary Drafting Group) - J.
Pearson, Colorado State Patrol - D. Taullie, Columbus McKinnon
Corp - R. Reynolds, Columbus McKinnon Corp - T. Lowery, Cretex
Co. Inc - J. Nystrom, Cretex Co. Inc - S. McCloskey, Federal Highway
Administration - N. Thomas, Federal Highway Administration - L.
Minor, Federal Highway Administration - M. Schmidt, Great West
Casualty - J. Barber, Idaho State Police - B. Branson, ITW Cargo
Safe-Shippers Paper Products - T. Martin, Kinedyne Corp. - J.
Takacs, MacKinnon Transport Ltd - E. MacKinnon, Massachusetts
State Police - P. Sullivan, Michigan Truck Safety Commission -
D. Willcutt, New Brunswick Solictor General - B. Doyle, Nicholson
Track Tight - G. Nicholson, Ohio State Highway Patrol - L. Woolum,
Ohio State Highway Patrol - J. Feddern, Ohio Trucking Association
- L. Davis, Ontario Ministry of Transportation (Chairman Drafting
Group) - R. Covello, Ontario Ministry of Transportation - J. Billing,
Owner Operator Independent Drivers Association - R. Craig, Prince
Edward Island - G. Beaton, Safety And Health I&E - T. Pogue,
Saskatchewan Hwys & Transportation - P. Hurst, Shippers Paper
Products - J. Howlett Jr, Specialized Carriers and Riggers Association
- B. Rieck, Texas Transportation Institute - J. Montufar, The
Crosby Group - C. Lucas, Transport Canada - J. Neufeld, Transports
Quebec - J. Couture, Transports Quebec - G. Desrosiers, University
of Manitoba - A. Clayton, Wabash National/TTMA - K. Carr, WASTEC
- J. Legler.
1. Introduction
and Welcome
Mr. Fiste
welcomed participants to Denver for the fifth meeting of the Committee.
As President of CVSA and host of the CVSA Annual Meeting, Mr.
Phil Vasquez also welcomed delegates to Colorado, and expressed
support for the important work being done by the group.
A general
round of introductions was made.
Mr. Fiste
provided a brief overview of the project, noting that this effort
had been launched as a partnership between government and industry
in pursuit of a new, uniform performance based standard. He noted
that the small drafting group working on behalf of the committee
had produced Draft 5 of the standard for discussion at this meeting.
He noted that general agreement had been reached previously on
the contents of Parts 1 and 2, and that the focus was now on Parts
3 and 4.
2. Adoption
of Agenda
The agenda
was adopted as circulated.
3. Adoption
of Record of Decisions - May 3, 1997 - Houston,
Texas
The Record
of Decisions from the Houston meeting were reviewed and approved
by motion (Schmidt/Strawhorn).
4. Presentations
- Research in Support of a North American Standard
i) Aluminum
Association
Mr. Moore
provided a brief presentation on the test program which had been
completed on aluminum coils. He reported that the test procedures
had been developed by Professor Perkins, and the results were
used in part to validate the computer modeling techniques described
in the final report. He indicated that the study had demonstrated
that, with appropriate blocking, bracing and rubber mats, coils
up to 12,500 lb. could be transported safely without tie-downs.
In discussion,
it was agreed that the drafting group would review the report,
and would direct any questions to Mr. Moore.
ii) Association
of American Railways
Mr. Grosso
was welcomed to the meeting, and thanked for the generous support
provided by his organization to date, and in particular for the
copies of background research reports and loading guidelines prepared
by AAR. Mr. Grosso extended an invitation to members of the committee
to visit the test facility in Pueblo. He indicated that his organization
was pleased to contribute to this effort, and would be prepared
to undertake specialized testing in support of the work if needed.
He noted that his facilities were capable of testing highway trailers,
including investigations into the effects of shocks and vibration.
iii) Release
and Availability of Research Reports
Mr. McAlister
reported on the availability of research reports stemming from
the project, noting that an order form was included on the Internet
site (www.ab.org/ccmta/ccma.html) for all reports. He indicated
that all of the reports would be available from CMMTA for nominal
charge, including the overall summary report.
5. Overview
of Research and Standards Harmonization Process
Mr. Pearson
a brief overview of the background to the project, including the
cooperative research project, the organizational structure being
used to develop a common international standard and the work completed
to date.
6. North
American Cargo Securement Standard - 5th Draft
a) Summary
of Comments Received and Overview of Revisions
Mr. Pearson
provided a presentation on the evolution of the standard through
the first five drafts, along with a summary of the types of comments
which had been provided to date. He reported that endorsement
of the contents of Parts 1 and 2 had been provided at the last
meeting in Houston, and that the primary focus for changes in
Draft 5 had been on Parts 3 and 4.
He reported
that, since the last meeting, a background document had been prepared
by Mr. Billing in support of the selection of performance criteria
(copies were distributed).
He noted that
the original concept of preparing a performance based standard,
in layman's language, with clear explanation of the requirements
was presenting a challenge to the drafting group. He noted that
while overall, stakeholders had expressed general support for
the work completed to date, the more specific comments offered
on the latest draft had fallen into two "camps". From
the perspectives of enforcement of, and compliance with, a standard,
it had been suggested that stronger language and more detail was
required on specifically what must be done to comply. Conversely,
as a performance based standard, others felt that too much detail
and advice was being provided.
He noted that,
in preparing Parts 3 and 4 of the latest draft, the drafting group
had attempted to focus on the compulsory requirements of a new
standard, and remove sections which simply provided advice, guidance
or context information. He suggested that the evolution of the
format for the standard had reached an important decision point
if the expectations of the stakeholders were to be met.
In this regard
he proposed that the standard be broken into two parts;
-
a
strict description of compulsory requirements for cargo securement
which must be met to comply with the North American standard
and which will be expected for travel in Canada, the United
States and Mexico
-
a
more informative guide to cargo securement which will be of
assistance to carriers and enforcement officials in selecting
appropriate securement systems. It is envisaged that this guide
would be comparable in form and style to the model developed
in Australia and would serve as a resource in support of the
training and educational package to be prepared on the standard.
In
discussion of this proposal, it was noted that other standard setting
organizations were going through similar exercises (eg. ISO, SAE),
with distinction being made between "normative" requirements
and "informative" guidelines. While support was expressed
for the proposed division, it was generally agreed that both documents
should be produced and released to a common schedule. It was noted
that care would have to be taken to ensure that the "guide"
included reference to the specific requirements of the standard,
as it would likely be more widely read than the specific regulatory
requirements. (ie. the guide must not conflict with the regulations)
In this discussion,
other issues were raised related to the implementation and maintenance
of a common North American standard including:
-
the
need to provide a means to maintain the standard as a "living"
document, with opportunity for changes and updates to be introduced
and universally accepted, as required or desirable
-
recognition
of the importance of consistency in fines and sanctions as an
important component of a common standard
-
the
need to recognize and, where appropriate, accept innovation
in technology and securement systems
-
the
virtues of adopting a common standard by reference in the regulations/legislation
of all participating jurisdictions to ensure uniformity in requirements
and to expedite the introduction of changes in the standard
It was agreed
that the drafting group should consider these issues and prepare
a report with recommendations for the next meeting of the committee
in February.
It was noted
that adoption by reference poses challenges for many jurisdictions,
and further work is required to explore the feasibility of this
approach. Mr. Thomas noted that FHWA would still be required to
proceed through the rulemaking process even if the standard is
ultimately to be adopted by reference.
In concluding
this discussion, it was agreed that the standard would be prepared
as two documents; one containing the prescriptive, compulsory
requirements for cargo securement, and a second, companion guide
to proper cargo securement techniques.
7. North
American Standard Part 3: Cargo Securement Components
a) Overview
of Revisions
Mr. Pearson
provided a brief overview of the revisions which had been made
to Part 3, noting in particular that the "advisory"
sections had been largely removed to focus on the "must do"
requirements.
He noted that
the foundation for Part 3 was a proposed requirement that the
capacity of all components of cargo securement systems must be
rated and marked in accordance with recognized manufacturers standards.
He suggested that, in the absence of rating and marking to recognized
standards, the burden for assigning default strength values for
securement equipment should not fall to governments. Consequently,
at some point in the future, unmarked equipment will not be recognized
as contributing to cargo securement (ie. default values for strength
will be zero) unless recognized manufacturers standards include
default values.
In discussion
a number of issues and concerns were raised including:
-
recognition
of the problem of labels and tags falling or wearing off equipment
in service
-
the
difficulty of rating the strength of securement systems built
up from a variety of components (eg. strap assemblies comprising
webbing, hooks, winches etc., load bars used in logistics rails).
It was recognized that test procedures will be required for
establishing the strength of the entire system as used, in addition
to the establishing the strength of each of the components.
-
the
need to provide a grandfather or "phase-out" period
to allow existing equipment to serve it's useful life
-
the
need to include clear and consistent definitions in both the
securement standard and the manufacturers standards
-
recognition
that some components can be easily rated and marked and other
components present considerable difficulty (depending on how
they are used or loaded). For example rating the strength of
nailed wood blocking is difficult, if not impossible.
-
it
would be advisable to divide Part 3 into two sections; one dealing
with enclosed vans and one dealing with platforms
Mr. Carr spoke
briefly to the difficulties presented by required the strength
of van trailer walls to be rated and marked, noting that this
would have to be discussed by the TTMA's Engineering Committee.
It was noted that TTMA currently has recommended engineering standards
for trailer bulkheads and walls, although it was not clear whether
these are commonly used or reflect the strength characteristics
of the current fleet.
It was noted
that completion of Part 3 of the standard depended on receiving
comments, strong support and contributions from the equipment
manufacturing sectors, particularly with respect to identifying
appropriate manufacturing standards which should be referenced.
b) References
to Other Standards & Organizations
i) Web
and Sling Tiedown Association (WSTDA)
Mr. Takacs
provided an update on the updated and new standards being prepared
by the association. He noted that the updated standard for Synthetic
Webbing had been completed and was in the final balloting process.
He indicated that a standard for winches had been completed, and
would be distributed for balloting shortly. He indicated that
comments from the committee would be welcomed, and to the extent
possible, would be addressed in the redrafting process.
On behalf
of the committee, the Co-Chairs commended Mr. Takacs for his excellent
work in this area, and thanked him for providing working copies
of the emerging standards to the drafting group for review.
ii) Truck
Trailer Manufacturers Association (TTMA)
Mr. Carr reviewed
the process used by TTMA's engineering committee to develop recommended
practices. He noted the requests to TTMA to provide advice on
the strength of anchor points and trailer walls, and committed
to ensure that this was reviewed by the engineering committee
at its meeting in October. It was noted that Mr. Minor and Mr.
Strawhorn would be attending this meeting and could assist in
the discussion of the information requirements of the securement
standard.
Concerns were
expressed with the prospect of completing the securement standard
without better information on the strength of trailer bulkheads,
walls and floors. It was agreed that a letter should be sent to
TTMA from the Co-Chairs outlining the importance of this informaton
for the standard, and requesting that a closer working relationship
with TTMA be established to develop the information needed. In
the absence of information from the trailer manufacturers, it
was suggested that the material developed by AAR could be used.
iii) Waste
Equipment Technology Association (WASTEC)
Mr. Legler
briefly outlined new developments in the standards for containers,
indicating that there was now a good correlation between the work
on the cargo securement standard and the standards development
process in his sector. He noted that the performance criteria
had been embraced in the standards for Roll-on Roll-off containers,
and that he expected final approval of the revised standard shortly.
He indicated that he was willing to work closely with the drafting
group in preparing the next draft of the standard.
iv) National
Association of Chain Manufacturers (NACM)
Mr. Lucas
provided a brief report on the status of the latest standards
of NACM. He also briefly discussed the changes in strength rating
which had occurred for specific chain types from earlier standards.
In concluding
the discussion on Part 3, it was agreed that the committee should
correspond with all relevant industry organizations to:
-
outline
the status of the work being done on the North American Standard
-
explain
the strength rating and marking requirements which have been
proposed in Part 3
-
review
the draft outline of specific commodities identified in Part
4 for prescriptive standards
-
seek
their comments on the work completed to date, and their assistance
and support in ensuring Parts 3 and 4 are complete
8. North
American Standard Part 4: Proposed Specific Securement Requirements
by Commodity Type
a) Presentations:
Mr. Pearson
provided an introduction to this section, noting that the format
and content of Part 4 had been revised significantly from the
previous draft. He explained that the drafting group had revisited
the approach to this section by focussing on commodities for which
there appeared to be justification for development of prescriptive
standards (ie. only "bears", no "bunnies").
He noted that
the drafting group was anxious to receive comments on both the
revised list of commodities which had been prepared, and on the
specific requirements which were proposed for each. It was suggested
that comments on specific sections of Part 4, or expression of
interest in contributing, be directed to the appropriate member
of the drafting group with responsibility for the section.
i) 4.1
- General Freight
A brief presentation
was provided on this section of the draft by Mr. Pearson and Mr.
Desrosiers. Mr. Sullivan also provided explanation of the objectives
of the requirements for general freight.
In discussion
some confusion was expressed with whether these requirements would
apply to both vans and flatdecks, recognizing that it is often
difficult to secure and/or tie-down articles within a van. It
was suggested that the section be broken into two sections; one
for vans, and one for flatdecks. There was also considerable discussion
on the need to ensure that no cargo shifting occurs within vans,
and the requirement to use void fillers or dunnage bags.
In general,
support was expressed for the approach being taken to this section.
ii) 4.2
- Logs
Mr. Billing
and Mr. Desrosiers provided an overview of this section. In discussion,
it was agreed that logs deserved to be addressed as a specific
commodity within Part 4. A number of editorial comments were offered
for use in preparation of the next draft. It was noted that the
forest industry should be invited to review the proposal and to
participate in the preparation of this section.
iii) 4.3
- Dressed Lumber
Mr. Desrosiers
provided an overview of this section, noting that the proposals
contained in this section could also apply to the commodities
of similar size and shape. In discussion of the issues, Mr. Desrosiers
noted that the research had shown that the strapping of each level
of bundles was important to exploit the restraint available from
friction between the deck and the first layer of bundles and between
each layer of bundles when stacked two or three high. He also
indicated that meeting the longitudinal acceleration criteria
could best be achieved by blocking against a bulkhead at the front
of the trailer. It was noted that many flatdeck trailers are not
equipped with bulkheads, and this requirement would pose serious
problems for the current fleet. It was also noted that the second
trailer in double trailer combinations are not fitted with bulkheads
for operational reasons.
It was generally
agreed that this section should be retained in the draft standard,
and could be applied to transport of other commodities such as
bundles of plywood, particle board and drywall.
iv) 4.4
- Metal Coils
Mr. Minor
reviewed this section, noting that he had based the draft on the
current requirements with amendments and additional provisions
to reflect the findings of the research program. It was agreed
that metal coils must be specifically addressed in the standard.
Some discussion
of the need for specific requirements for transport of other metal
products occurred, such as metal ingots and coils of wire. It
was suggested that a weight theshold be established to distinguish
between when commodities must be subject to special securement
requirements or when the provisions for general freight will apply.
A number of
editorial comments were offered on the text, along with the suggestion
that additional pictures be used to clarify the requirements.
v) 4.5
- Paper Rolls
Mr. Minor
reported that work on this section had not yet been completed,
but indicated that a first draft would be available by the end
of October.
vi) 4.6
- Concrete Pipes
Mr. Billing
provided an overview of the draft of this section.
In discussion,
representatives of the concrete pipe industry reported that joint
efforts between the US and Canadian organizations had produced
an agreement on common standards for transportation. He provided
copies of the proposed standard and indicated that final approval
of the proposal was imminent.
It was agreed
that this section should be retained in the draft, and that the
drafting group should work closely with the concrete pipe associations
in preparing the next version.
vii) 4.7
- Drums
Mr. Desrosiers
introduced this section, noting that it was not clear whether
there should be special requirements for the transport of drums
within the standard. He explained that the characteristics of
drums can vary widely, depending upon their contents and the number
being transported. He noted that drums filled with liquids or
chain can be very heavy, and can pose challenges to securement.
Similarly, while empty drums may not be heavy, their structural
rigidity also poses challenges to securement, particularly when
laid on their side.
In discussion
it was agreed that the drafting group should consult with appropriate
industry organizations (chemicals, petroleum products etc) on
this section to review any guidelines which exist for loading
and securement of drums.
viii) 4.8
- Pallets
Mr. Covello
reviewed this section, noting that it was based in large part
on the requirements found in the Australian guide. In discussion,
it was agreed that this section should be included in the draft,
with additional elaboration on the specific requirements for loading
in vans versus flatdecks (eg. need to tie-down every pallet, use
of dunnage etc).
ix) 4.9
- Containers
Mr. Minor
reviewed this section noting that it was based primarily on existing
federal requirements in the United States. The issue of using
different acceleration levels for containers was raised, and questioned.
It was agreed that Containers should be included as a section
in Part 4. It was also agreed that the drafting group should review
the ISO container standards in preparing the next draft.
x) 4.10
- Loose Bulk Loads
Mr. Covello
reviewed this section, noting that it was based on the current
requirements in Ontario. Mr. Legler offered to provide assistance
with this section for the next draft.
xi) 4.11
- Automobiles
Mr. Neufeld
reviewed this section. In discussion it was suggested that the
automobile transport industry should be invited to review and
comment on this proposal. Mr. Strawhorn indicated that he had
forwarded a copy of Draft 5 to the national car carrier organization
prior to the meeting.
xii) 4.12
- Heavy Construction Equipment:
Mr. Neufeld
reviewed this section. As with car carriers, it was proposed that
comments and participation of the heavy equipment manufacturers,
and industry association such as SCRA be invited. Mr. Strawhorn
offered to provide the names of additional contacts in this sector
to Mr. Neufeld.
xiii) 4.13
- Crushed Vehicles
Mr. Neufeld
reviewed this section. It was agreed that this commodity should
be included in Part 4. In discussion, it was not known whether
this sector was represented by an association.
xiv) 4.14
- Roll-on/Roll-off Containers
Mr. Desrosiers
reviewed this section, noting that there appeared to be a need
to ensure that both ends of the roll-on container are adequately
secured to the transporting vehicle. He noted that good systems
do exist in the field, but that some types of containers are not
secured at the rear. Mr. Legler expressed strong support for including
this section in the standard, and offered to work with the drafting
group to complete this section.
In concluding
the discussion of Part 4, it was agreed that industry participation
in the preparation of the next draft was critical. It was agreed
that all stakeholders should be invited to forward comments on
Draft 5 to the drafting group by October 31, and in particular,
to indicate their interest in contributing to the specific sections
in Part 4 to the appropriate member of the drafting group.
9. Updates
on Standards Initiatives
a) Canada
Mr. Neufeld
reported that the anchor point standard would be published in
Part 2 of the Canada Gazette shortly, for implementation one year
after publication. He confirmed that this requirement would only
apply to flatdeck trailers. He noted that a draft test procedure
had been developed for anchor points, and was available for review
by interested parties.
b) United
States
Mr. Minor
reported that the process of developing the cargo securement standard
had been issued as an Advance Notice of Proposed Rulemaking earlier
this year, and that the comments which had been received were
generally supportive. He indicated that the intent was to proceed
with development of the standard through this process with a target
for completion in the latter part of 1998.
c) Mexico
Mr. McAlister
reported that Mexico had indicated an interest in participating
in this work, and that a representative of SCT was expected to
be in attendance at the next meeting.
10. Training/Education
Materials
The Co-Chairs
sought direction from the committee on the timing of work to be
done in preparing training materials for carriers and enforcement
officials. In discussion it was agreed that work should begin
immediately in developing a workplan for training and education
on the research findings and the new standard.
It was agreed
that a sub-committee would be formed, under the Chairmanship of
Mr. Brian Doyle from the New Brunswick Solictor General's department,
to begin work in this area. Interest in participating was also
expressed by Rick Craig (OOIDA), Tom Pogue (Safety & Health
I&E), Jack Legler (WASTEC), Larry Strawhorn (ATA), Paul Sullivan,
Bud Branson, Jimmy Emonds (CVSA) and Evan MacKinnon (CTA). It
was agreed that membership on this committee would be open to
any interested parties. It was noted that interested parties should
contact Sean McAlister at the CCMTA Secretariat.
It was further
agreed that the committee would prepare a workplan and framework
for development of this material for presentation at the next
meeting of the full committee (February 1998).
11. Other
Business
a) Dunnage
Bags
Mr. Martin
provided a brief overview of the use and application of air dunnage
bags, noting that these were subject to design standards and in
common usage as components of cargo securement. In discussion
it was agreed that discussion of these devices would be included
in the guide, but could not be made a compulsory requirement of
the standard.
b) Nicholson
Track Tight
Mr. Nicholson
provided materials on the system which his company had developed
for securement of heavy construction equipment on highway trailers,
and provided a copy of a video tape to the secretary for review
by the drafting group.
12. Next
Meeting
It was reported
that the next meeting would be held in Toronto in mid-February
1998. In view of the importance of this meeting, it was noted
that it would likely be over two days.
13. Adjournment
The Co-Chairs
thanked the participants for a productive session and adjourned
the meeting.
_______________________________________________
Attachment 1
Part 4: Prescriptive Cargo Securement Standards
Drafting Group Responsibilities
Comments on Part 4 can be made through the web page or by contacting
the appropriate member of the drafting group.
Section |
Contact(s) |
| 4.1 General
Freight |
G. Desrosiers,
J. Pearson, P.Sullivan |
| 4.2 Logs |
J. Billing,
G. Desrosiers |
| 4.3 Dressed
Lumber |
G. Desrosiers |
| 4.4 Metal
Coils |
L. Minor |
| 4.5 Paper
Rolls |
L. Minor |
| 4.6 Concrete
Pipe |
J. Billing,
G. Desrosiers |
| 4.7 Drums |
G. Desrosiers |
| 4.8 Pallets |
R. Covello |
| 4.9 Containers |
L. Minor |
| 4.10
Loose Bulk Loads |
R. Covello |
| 4.11
Automobiles |
J. Neufeld |
| 4.12
Heavy Construction Equipment |
J. Neufeld |
| 4.13
Crushed Vehicles |
J. Neufeld |
| 4.14
Roll-on/Roll-Off Containers |
G. Desrosiers |
|
