Cargo Securement Standards Harmonization Committee Meeting - May 3, 1997

Wyndam Greenspoint Hotel
Houston, Texas

RECORD OF DECISIONS

A general discussion ensued on the performance criteria and the implications of adopting these criteria. It was noted load restraint systems must be strong enough to meet the performance criteria. Vehicle structures and attachments must be strong enough to supply the necessary restraining forces when cargo is subjected to these accelerations. Finally, the load securing equipment must be strong enough to supply the necessary restraining forces to cargo when subjected to these accelerations. A number of participants noted it was difficult for them to translate these numbers into "real world" applications.

In discussion, Mr. Feltault questioned whether the performance criteria were as "robust" as those which had been developed and implemented by AAR. In particular he questioned the vertical acceleration number indicating .2g may not be high enough to meet the principles articulated in the first sections of the standard. Information was sought by Mr. Feltault on the confidence intervals for the deceleration rates. It was noted the performance criteria for the standard were within 1/10th of a g. as proposed by the TTMA. It was noted the criteria were supported by technical literature and were consistent internationally (ie: OECD, Australia). Participants were encouraged to provide literature which would suggest these criteria were not appropriate for highway transport in North America.

In order to permit the standards harmonization initiative to proceed it was agreed the Committee would endorse the performance criteria with direction provided to the Drafting Group to assemble and reference the studies which supported these criteria. It was agreed the AAR would undertake to provide confidence and distribution intervals materials for review by the Drafting Group.

b) Summary of Comments Submitted on Third Draft

Mr. Pearson and Covello summarized the comments which had been received to date on the third draft of the standard. Briefly, they noted comments had been supportive but additional definition and clarification was sought as to whether the standard applied to flat decks and vans, shipper responsibility for closed and sealed vans, whether friction was "reliable", the need to ensure loads are unitized, and the benefits of using dunnage in combination with trailer walls. Questions had also been raised relative to the non-use of tiedowns and how an assessment could be made as to whether cargo is adequately restrained, and whether cargo shifting will affect vehicle stability.

It was agreed these issues had been discussed at the meeting (See Items 4,5, and 6) and further work would be undertaken by the Drafting Group to address the concerns.

c) Review Cargo Securement Draft Standard - Revisions

Mr. Pearson provided a presentation relative to Parts 2 ,3, and 4 of the draft standard. He indicated for style and format the Drafting Group had utilized the Australian guidelines as a model. He noted the Drafting Group intended to use and reference other applicable manufacturing or industry developed standards where appropriate. Comments were sought from the Committee on the issue of lightweight cargo for transport and the general style and approach that would be utilized by the Drafting Group for sections 3 and 4 of the standard.

A general discussion ensued on Part 2 of the standard and the issue of cargo shift for lightweight materials. The proposal to use 50lb (23kg.) as the criteria was debated. In discussion a number of participants indicated other rules relating to Occupational Health and Safety would apply to lightweight packages. After considerable discussion Mr. Cooper proposed and it was agreed the three bullets referring to loads moving horizontally, lightweight objects and loose bulk loads, and bulk liquids would be deleted from the standard. The principle was otherwise endorsed by the participants.

It was noted weight distribution was critical to effective cargo securement and it was not well defined in the current draft. It was agreed the need to provide a better definition for "effectively contained" would be referred to the Drafting Group for further work.

Mr. Pearson indicated Part 2 was intended to be used as a "primer" in cargo securement methods. In discussion, it was suggested much of Part 2 could be used as instruction to shippers on proper cargo securement methods (See discussion in agenda item 5. a). Committee members sought additional illustrations of common vehicles in use in North America for the standard in this section. It was suggested current illustrations may imply the standard only applies to flatbed trailers.

It was further noted additional work relative to trailer floors and walls would have to be undertaken if these were to be factored into the standard. In addition, it was suggested some consideration should be given to the internal components used inside trailers to foster securement. In particular it was suggested some discussion of beams and shore bars should be included. Mr. Feltault offered to provide copies to the Drafting Group of testing which had been done by AAR and others which addressed internal cargo securement components. In addition, Mr. Takacs and others (Mr. Martin) undertook to provide additional information to the Drafting Group on these items.

It was suggested in order to permit the drafting of the other sections to proceed it was critical that Parts 1 and 2 be considered complete (minor editing excepted) by the Standards Harmonization Committee. In discussion it was noted these initial sections were the foundation for the North American Standard and the remaining sections would provide the detailed specifications and requirements. It was suggested without endorsement of these sections the Drafting Group could not proceed to develop Parts 3 and 4 of the standard. Following further discussion by the participants it was agreed with the above mentioned caveats Sections 1 and 2 would be endorsed by the participants.

Mr. Pearson provided participants with an overview of Part 3 of the standard noting the style and format was similar to that which had been developed in Australia. He noted the Drafting Group was not proposing these sections at this juncture, but rather sought confirmation from the Harmonization Committee that the style and format was appropriate for the North American Standard. In discussion, the request was made for further illustrations and diagrams which more clearly represented North American vehicles and equipment. In particular, the addition of more van body illustrations was sought. It was agreed along with a section on rubber mats there should be a section which addresses shrink or stretch wrap. The Drafting Group was requested to add these sections to Part 3.

It was noted at the last Standards Harmonization Committee meeting it had been proposed that in the absence of manufacturing, rating, and marking standards for cargo securement elements the Drafting Group would select a default value and this might be zero. Since that time the Drafting Group had refined the proposal to suggest that within a two year period after implementation of the standard all components of the cargo securement system (walls, tiedowns etc) would have to be rated and marked. This issue was briefly discussed by the participants with concern expressed relative to prohibiting existing equipment and materials. It was suggested current equipment or components would not be banned, but rather the value of zero would be given to unrated and unmarked materials and equipment when determining compliance with the performance criteria. It was noted to the extent possible the Drafting Group intended to reference other standards in the cargo securement standard. This approach was endorsed by the Committee.

Participants undertook a brief review of Part 4 of the standard. Concern was expressed that the language would have to be tightened and values added if it was to be used as the standard for regulatory purposes. In addition it was suggested the Drafting Group should be using Working Load Limit as opposed to Maximum Breaking Strength for these sections of the standard.

Comments were sought on whether the section was complete relative to the commodities to be covered. It was suggested small machinery and configurations of flimsy material should be added to the list. Mr. Strawhorn suggested that if participants identified and requested that every single commodity be included, the standard would never be completed. Rather he suggested the approach that should be taken by the Committee would be to identify and focus on those commodities which were "grizzlies", and not spend a lot of time on the "rabbits". In other words the focus of Part 4 should be on those commodities where there was a known cargo securement problem which could be linked to accidents or incidents. It was suggested the list compiled by the Drafting Group to date was fairly complete, and participants in their comments to the Drafting Group would only suggest additional commodities if they could be justified on the basis of accidents. This approach was endorsed by the Committee.

d) Sub-Working Groups for Parts 3 and 4

It was noted the Drafting Group would be meeting through the summer to develop Parts 3 and 4 of the standard. It would be important for participants to submit comments on the standard in the briefest delay. It was noted different members of the Drafting Group had been assigned responsibility for each of the specific commodities outlined in Parts 3 and 4 of the standard. In order to facilitate rapid development of these sections participants need only advise the CCMTA Secretariat of their desire to work with members of the Drafting Group on those sections which were of particular interest to them. This process for developing the prescriptive requirements was endorsed by the participants. It was agreed each participant would notify the Secretariat if they were interested in working on a specific section so they could be put in contact with the Drafting Group members responsible for developing the section.

e) Schedule & Timing for Comments

It was noted the Drafting Group would continue to meet through the summer to address the direction provided by the Committee and to complete work on parts 3 and 4 of the draft standard. It was agreed participants would provide their comments on the standard to the INTERNET site at www.ab.org/ccmta/ccmta.html or directly to the CCMTA Secretariat by June 1, 1997 at the latest. It was agreed a further draft of the standard would be prepared for review by the Committee in July and further comments would be sought from the participants on subsequent drafts.

The proposal to place comments received on the draft standard on the web site for all participants to review was discussed. It was agreed the web site be modified to include a section where comments from stakeholders can be reviewed. It was acknowledged that unless a stakeholder specifically requested that their comments not be placed on the web site the comments would appear for review by all stakeholders.

7. References to Other Standards & Organizations

The Co-Chairs indicated to the extent possible the new North American Cargo Securement standard should not conflict with other standards, and where possible these other standards could be incorporated into the cargo securement standard. It was further noted groups which had particular expertise like the WSTDA and TTMA would be called upon to assist in the development of the North American Cargo Securement standard.

a) Web and Sling Tiedown Association (WSTDA)

Mr. Takacs provided an overview of the work underway by the Association to develop marking and rating standards for webbing, winches, and tiedowns. He indicated work was being undertaken to rate these products so they could be properly used for cargo securement. Copies of the standards had been circulated to participants at the last meeting. The latest version of the standard for webbing and winches was distributed.

A general discussion ensued on the WSTDA standards and the issue of minimum vs. ultimate breaking strength. The relation to the working load limit was also debated. The need to develop performance criteria for the replacement of these components was identified as an issue. It was agreed participants would provide comments to Mr. Takacs on the standards by June 15, 1997 at the latest, and a further report would be provided at the next meeting. Mr. Takacs undertook to forward the completed and revised standards to the Drafting Group after this date for review and possible reference in the North American standard.

b) Truck Trailer Manufacturers Association (TTMA)

Mr. Watts indicated the TTMA had received a presentation on the project and had forwarded an initial reply to a series of questions which had been posed by the Drafting Group. He requested the Committee consider the majority of trailer manufacturers were small operations and providing the information sought by the Drafting Group was a difficult task given this data was not currently required for regulatory compliance testing. He indicated comments on the third draft had been forwarded to CCMTA for review by the Drafting Group along with recommended practices for trailer and tank nomenclature.

It was agreed the Drafting Group would be directed to consider this material in the preparation of the next draft of the standard.

c) Waste Equipment Technology Association (WASTEC)

The Co-Chairs welcomed Mr. Legler to the Committee and requested a presentation on the work currently being undertaken by WASTEC. Mr. Legler indicated the members of his association applauded the development of a uniform North American standard and were looking forward to working with the Committee to develop the requirements. He noted WASTEC was looking for the ANSI Z245 standards being recognized as the basis for specialized tilt frame and roll-off containers. He indicated the most expeditious way for the Committee to include requirements for specialized equipment applications would be to reference the existing national voluntary standards which had been developed. He concluded his presentation by noting the Z245 standards in general provide performance, rather than design specific requirements and therefore do not represent an artificial barrier to trade via the freezing out of new designs or innovative applications.

In discussion Mr. Legler indicated there did not appear to be a technical conflict between the performance objectives outlined in the North American Cargo Securement Standard and the current content of the relevant Z245 standards. He noted there had been a number of problems relative to field enforcement which could be addressed by a requirement for a chain and verification of the compatibility label for containers.

It was agreed the Drafting Group would be tasked with reviewing the WASTEC submission and making recommendations relative to the inclusion of the ANSI Z245 standards in the North American Cargo Securement standard.

d) National Association of Chain Manufacturers (NACM)

Mr. Covello, indicated his Drafting Group had reviewed a series of revised requirements to rate and mark chain. He indicated there was some confusion among the Group as to the selection of specific values in the updated standard from the NACM.

The issue of whether existing chain met the new requirements was discussed. Messrs. Takacs and Lucas provided additional elaboration and clarification on the values contained in the revised chain standard. It was noted US FMCSR 393 made specific reference to the tables produced by NACM, and hence justification would be required to incorporate the revised tables in US regulations, and in the CVSA OOS criteria. It was agreed Messrs. Takacs and Lucas would provide the rationale for the changes to both FHWA (Thomas/Minor) and Mr. Covello of the Drafting Group for consideration in the development of the North American Cargo Securement standard.

8. Updates on Standards Initiatives

a) Canada

The CCMTA Secretariat provided a brief overview of the Canadian regulatory environment and the split jurisdiction between the federal and provincial governments for cargo securement regulations. On behalf of Mr. Neufeld of Transport Canada, the Secretariat provided information on the proposed federal regulation to require anchor points on new vehicles. He noted it would initially apply to flat deck trailers over 10,000kg. A Canada Gazette Part 2 would be published in the near future with a 1 year lead time for trailer manufacturers to comply.

b) United States

Messrs. Thomas and Minor provided information on the US regulatory process and indicated FHWA’s intention to review Part 393 of the regulations. The comments on the initial ANPRM had generally been favourable to working with Canada to develop a North American standard. Some concerns had been expressed relative to costs. It was noted a summary of comments would be published in an upcoming rulemaking notice. In addition, FHWA intended to publish the draft standard at a yet to be specified date once the standard was further developed and additional consultations had been completed.

Concern was expressed relative to the schedule which had been adopted for completion of the project. US officials made a distinction between a major and minor rulemaking and outlined the different processes which were involved to ensure passage. It was suggested meetings between senior Canadian and US officials could be pursued to expedite the US regulatory process.

c) Mexico

Mr. Fiste indicated Mexico had declined to participate in the research, but had indicated their intention to participate in the standards harmonization initiative. The Secretariat indicated a formal reply had just been received from Mexico requesting copies of the studies, and advising that Mexico was in the process of conducting a study on common Mexican load securement practices (Secretariat Note: Mexican officials confirmed later in the week they will participate on the Standards Harmonization Committee. Mr. Enrique Gerner, and the new head of standards for the Mexican Department of Transportation and Communications will be the official representatives on the Committee).

9. Training and Education Materials - Initial Discussions

The need to develop educational and training material for the new Cargo Securement standard was discussed. Participants were requested to note and provide any good training material they had reviewed to the CCMTA Secretariat. The Co-Chairs suggested after the standard had been developed the Committee should devote some time to determining what materials were required, who would develop them and by what means (partnerships) they could be distributed.

The development of joint training and education materials was endorsed by the Committee. Mr. Fiste indicated CVSA would redraft the training sections of the CVSA OOS to reflect the new North American standard. Ms. Pelletier indicated left over funds from the research project had been allocated as "seed funding" for the development of educational and training materials. Mr. Craig indicated OOIDA would be interested in donating funds on a cooperative basis with other organizations to develop driver and inspector training materials. Other organizations present also indicated they would be prepared to donate funds for this purpose. It was further noted there would be a need to develop materials for shippers and the development of training materials would allow for additional descriptive text and interpretations to be provided which should not be included in the standard. It was agreed the Committee would return to this issue once the standard was near completion.

10. Other Business

No other business was identified by the participants.

11. Next Meeting

It was agreed the next meeting would be held just prior to the CVSA Annual Conference on September 27th, 1997 in Denver, Colorado. The possibility of a two day meeting was discussed. It was agreed the Co-Chairs would be provided discretion to schedule a meeting prior to this date if required.

12. Adjournment

The Co-Chairs thanked the participants for a productive session and adjourned the meeting.