An order
form was circulated. In addition, project reports can be obtained
by placing an order through the Project web site at www.ab.org/ccmta/ccmta.html.
The Committee viewed the short briefing video which documented
in summary form the research results and the standards harmonization
process. It was noted the longer video provides the detailed
research results and recommendations for the development of
the North American Standard, and a series of practical suggestions
for effective cargo securement. It was suggested the longer
video was more appropriate for training purposes. An order form
was distributed at the meeting and copies of both videos can
be obtained by contacting the CCMTA Secretariat.
b) American
Association of Railroads Research
Mr. Johnson
provided an overview of the research undertaken by Mr. Grosso
and the AAR to determine the frictional restraint provided by
roll/rubber mat systems using rubber mats of the type currently
approved for use in rail intermodal shipments. Mr. Johnson indicated
the tests had been undertaken following the last meeting to
develop baseline data and to evaluate current practice against
the proposed standard. He noted without the use of mats .3 g
was attained, while with mats the results ranged from a low
of .69 g to a high of .98 g. He concluded his summary of the
results by indicating there was not a significant degradation
in performance of the mats and the results were repeatable.
A brief
discussion of the results ensued with a number of government
participants indicating supplementary restraint (blocking/bracing)
would be required to ensure this configuration consistently
exceeded the performance requirements. It was noted the majority
of the results fell below the .8 g criteria and this would suggest
additional restraint must be provided. Drafting Group members
indicated the load would have to meet the performance criteria
in all directions. It was noted some of the test results could
be interpreted to suggest the side and rearward requirements
of the criteria had been met if .8 g was attained in the forward
direction. It was suggested it was not the responsibility of
Drafting Group or the Committee to certify a particular load
securement system met the requirements, rather the obligation
and responsibility to test, rate and certify a system would
reside with the shipper or manufacturer.
The Co-Chairs
sought an indication from the mat manufacturers as to whether
they would be prepared to test, rate and mark their products
for the co-efficient of friction and to provide guidelines to
the Drafting Group when a mat should not be used further by
a shipper. Mr. Johnson indicated he was prepared to meet with
other manufacturers of this product to develop the testing protocols
and to discuss the marking and rating requirements. He indicated
marking and rating specifications could probably be developed
within six weeks and the other elements sought could be developed
within 3 months. It was agreed Mr. Johnson would meet with other
manufacturers of mats and attempt to provide material, and information
on the marking and rating system to the Drafting Group as soon
as possible for incorporation in the standard. It was agreed
Mr. Johnson would coordinate this initiative with Messrs. Covello
and Pearson.
5. Overview
of Research and Standards Harmonization Process
For the
new participants Mr. Pearson provided a general overview of
the research and cargo securement standard harmonization initiative.
The purpose of the load securement research project had been
to gather comprehensive data on cargo securement systems. The
purpose of the Standards Harmonization Committee was to review
the results and develop a new performance based standard which
could be uniformly implemented throughout North America. Information
on the web site and the consultation process was provided to
participants. It was noted the slippage which had occurred in
the schedule was due to the late publication of the research
results, the increased number of comments which had been received,
and the work undertaken by various stakeholders to develop rating
and marking requirements which could be referenced in the standard.
He indicated it was expected the rule and interpretive guide
would be in final form for the fall of 1998 to be implemented
by government agencies throughout North America. As the standard
development process drew to a close the issues of maintenance
and implementation of the rule became more critical.
A brief
discussion ensued on the revised schedule which was endorsed.
It was agreed implementation issues would be deferred until
later in the meeting (See item 9 of this Record of Decisions).
6. North
American Cargo Securement Standard - Draft 7
a) Summary
of Comments Received on Draft 6
Mr. Pearson
provided an overview of the evolution of the standard. He noted
there was increased pressure for the Committee to complete development
of the rule and to begin work on the steps which would be required
for uniform implementation. He briefly summarized the comments
which had been provided by the ATA, Kinedyne, New York, SNF
Inc., Stelco, AAR, Caristrap and others on Draft 6. He suggested
there was a convergence to consensus on the scope and application
(Part 1), the performance criteria (Part 2), and on cargo securement
components (Part 3) where manufacturers standards for rating
and marking would be referenced. He noted work was continuing
on the prescriptive requirements contained in Part 4 and the
comments remained supportive as the Drafting Group attempted
to work out the specific details for the "problem"
commodities with affected industry groups. The emphasis of Drafting
Group efforts since the last meeting had been to analyse the
comments and transform per the Committee direction the draft
standard into a proposed rule and to develop the interpretive
guide.
b) Overview
of Revisions to Draft 7
Mr. Pearson
briefly provided an overview of the revisions which had been
made since the February meeting. The model rule and the interpretive
guide were being offered for first time review by the Committee.
He noted sections on loose bulk loads, pallets and drums had
been merged into the general freight sections as requested.
He noted significant liaison had occurred with the paper roll,
forestry, concrete pipe, and metal coil industries since the
last meeting. He noted Parts 1, 2, and 3 had remained largely
unchanged but had been reduced to the essentials with the explanatory
text found in the guide and the referenced manufacturers’
standards contained as Appendix 1. Part 4 pertaining to specific
commodities had been revised extensively in the model rule as
a result of the comments and discussions with industry groups.
He noted as requested by the Committee a requirement for the
driver to periodically check the securement of the load had
been added to the rule. He concluded his presentation by noting
at least one more iteration of the model rule and the guide
would be required to address outstanding issues with affected
industry groups and to complete the detailed development of
the prescriptive requirements for the fall of 1998.
A general
and wide ranging discussion ensued on the model rule. A number
of participants questioned the basis and validity of the performance
criteria which had been selected. It was suggested it would
be difficult to find an application where a vehicle would sustain
a .5 g (11 mph) acceleration in the rearward direction. It was
suggested a distinction needed to be made between loaded and
partially loaded vehicles as it was difficult to achieve a .8
g deceleration with a fully loaded vehicle. Justification was
sought for the criteria. Mr. Billing summarized the research
which had been completed on heavy vehicle performance limits
and indicated this criteria had been selected based on the research
and a review of the criteria which had been selected by other
countries which had established performance based cargo securement
rules. It was suggested down shifting up a steep incline and
impacts in the rear (loading dock) would generate forces near
the .5 g rearward requirement. In addition, it was noted for
the side criteria a vehicle would be near the roll over threshold
above .6 g. Mr. Billing indicated for the general rule it was
difficult and complicated to distinguish between fully loaded
and partially loaded vehicles and develop separate criteria
which can be enforced at roadside. Therefore the performance
criteria had to strike a balance which would cover all vehicles
in all situations.
It was clarified
the performance criteria attempted to formally recognize friction,
blocking, and the other securement methods which in combination
would meet the performance criteria. Various members of the
enforcement community indicated additional work would have to
be undertaken to clarify how the driver and enforcement personnel
could verify compliance with the performance criteria without
introducing different criteria for loaded and partially loaded
vehicles. It was agreed if any of the participants had data
to suggest the performance criteria were not appropriate this
material would be supplied to the Drafting Group for review
by May 31, 1998 along with supporting rationale for alternate
criteria.
Discussion
turned to the provision in the proposed rule that called for
all components to be marked and rated to industry standards
and the principle that the strength of unmarked/unrated components
would be assumed to be zero. A number of participants indicated
industry standards for rating and marking were not available
for all components at the current time and it was unlikely they
would be in place within a two year time frame. Mr. Strawhorn
indicated these provisions would have to be changed or ATA would
consider launching a lawsuit if any effort was made to legislate
these requirements in the US. It was suggested it takes five
years to clear chain from carrier inventories and 15+ years
to retire trailers. Mr. MacKinnon echoed these comments and
further noted for some types of securement equipment (i.e.:
rope, webbing) it was difficult to keep the rating on the material.
It was suggested the WSTDA and NACM work was aimed at addressing
these problems. It was noted this would not address the component
manufacturers who were not members of these organizations.
With respect
to trailers it was suggested the TTMA had been requested to
review the possibility of developing a rating and marking system
which could categorize trailers perhaps by weight to indicate
whether a trailer was suitable for hauling different types of
commodities. It was noted this would still not address the thousands
of pieces of equipment which are still in active service. It
was agreed the proposed standard was intended to provide a depiction
of the ultimate goal and that further work and discussion of
a transition strategy to achieve this objective was clearly
required. It was generally agreed a more "liberal"
approach would have to be developed to grandfather unmarked/unrated
components and vehicles when the rule came into force. It was
suggested for cargo securement components the Drafting Group
give consideration to using the default values which currently
appear in the existing FMCSR requirements. It was agreed all
participants would further review this section and provide comments
and suggestions on other options to address the marking and
rating issues to the Drafting Group by May 31, 1998. It was
agreed the Drafting Group would include a revised proposal in
the next draft of the rule and interpretive guide.
7. Reference
to Other Standards and Organizations
The Co-Chairs
sought an update on the status of the work of the various industry
associations in support of the standard and with particular
reference to marking and rating.
i) Web
Sling & Tiedown Association (WSTDA)
Mr. Lucas
provided an overview of the work which had been undertaken by
the WSTDA to develop marking and rating standards for webbing,
winches, and tiedowns. He noted this work had been completed
and it was anticipated the standards would be ratified by the
full WSTDA membership by June 1, 1998. In addition, work was
underway on a standard for interior van specifications which
should be ratified in early 1999.
In discussion
it was noted the work on the requirements for interior van requirements
should be coordinated between WSTDA members and TTMA to ensure
the requirements are consistent. It was agreed representatives
from both associations (WSTDA & TTMA) would work in close
contact with the Drafting Group through the summer to finalize
the requirements.
ii) Truck
Trailer Manufacturers Association (TTMA)
Mr. Carr
updated participants on the progress being made by the TTMA
to update recommended practice RP47. He indicated a technical
sub-committee would be meeting on May 17th to revise the recommended
practice and that specifications for van trailers would be added
to the requirements. He briefly noted the Transport Canada Test
method 905 pertaining to anchoring devices was being reviewed
for possible incorporation in whole or part as an appendix to
RP47. He concluded his presentation by indicating TTMA hoped
to complete the revision process by September 1998.
In discussion
the need to complete the revision by September 1998 was emphasized.
In addition, Committee members requested that classifying trailers
by category (i.e.: Class 1, 2, 3) for their capacity to handle
different commodities be considered as part of the review of
the rating and marking system. Mr. Carr indicated he would convey
the request to the TTMA members. On the issue of schedule it
was suggested the final revised practice could be approved by
the TTMA Board in the fall of 1998. It was agreed Mr. Carr and
TTMA would forward as soon as possible the next draft of revised
practice 47 for review and incorporation by the Drafting Group
in the next version of the rule.
iii)
Waste Equipment Technology Association (WASTEC)
Mr. McAlister
distributed to the Committee correspondence from Mr. Legler
which provided an update on WASTEC activities since the last
meeting. It was noted for the roll-off and hook-lift type securement
equipment the principles contained in the North American Cargo
securement standard were being included in the draft revisions
to the appropriate ANSI standards (i.e.: Z245.1 and Z245.3).
It was anticipated revisions to both standards would be completed
and ratified by the membership in September 1998.
In discussion,
it was noted the schedule adopted by WASTEC for ratification
of the ANSI standards was in line with the schedule which had
been adopted for completion of the North American Cargo Securement
rule. It was agreed no further work was required as the major
issues had been resolved since the last meeting.
iv) National
Association of Chain Manufacturers (NACM)
Mr. George
provided an update on the four issues which had been referred
to the Association by the Committee. He indicated the NACM membership
had agreed a default value of zero should be used when chain
cannot be identified. In addition, the NACM had developed a
definition for chain which could be used in the proposed rule.
He explained the safety factors which were attached to different
grades of chain and indicated the membership was reluctant to
change the safety factors unless there are compelling documented
reasons. He suggested all reference to chain load capacities
in the rule should be to working load limits and not the safety
factor. He indicated members of the NACM will mark G30 chain.
He noted the NACM membership had reviewed the issue of mixing
grades of chain to secure the same load and the membership had
concluded that as long as the static and dynamic forces do not
exceed the working load limits of the chain, mixing of grades
is not an unsafe practice. He concluded by indicating the NACM
membership was considering adding out of service wear limits
for chain to the NACM specifications.
A general
discussion ensued on the responses which had been provided by
the NACM. A number of participants indicated they had a problem
with unmarked chain being provided a rating of zero since the
chain would have some capability. It was noted some chain manufacturers
were not members of the NACM and as such would not rate and
mark chain. It was suggested consideration be given by NACM
to colour coding chain. It was again suggested the Drafting
Group use the default values which currently appear in the US
FMCSR for the next iteration of the rule. In addition, problems
were noted with the relationship between ultimate strength and
the working load limit which were assigned by the NACM to certain
types of chain. The use of the NACM assigned 4:1 and 3:1 safety
factor criteria for some types of chain resulted in a penalty
for use of the more capable product. Some participants indicated
it was critical the NACM resolve the issue of safety factors
and suggested the Drafting Group seek a solution from the NACM.
Drafting Group members indicated this went beyond the mandate
of the group and the scope of the principle where it had been
agreed it was the responsibility of the industry groups to set
the standard for their products which could be referenced in
the rule. Mr. George was requested to raise the issue of ensuring
the marking and rating remained on chain with the NACM membership.
Some participants expressed concern with the response provided
for mixing chain on the same load suggesting it would be an
unsafe practice to have high capacity chain on one side of the
load and low capacity chain on the other side. The NACM membership
was asked to consider whether this practice should be prohibited
in the rule. General support was provided by the Committee members
for the NACM developing out of service wear limits provided
this could be completed by September. It was agreed all participants
would provide any additional comments to Mr. George by May 31,
1998. It was agreed Mr. George would provide additional input
on these issues for consideration by the Drafting Group by August
1 at the latest.
8. North
American Standard - Part 4: Proposed Specific Requirements by
Commodity Type
a) Presentation/Discussion
and Ratification of Sections
The Co-chairs
indicated the purpose of this portion of the meeting was to
review and provide detailed comments on the proposed rule. If
additional work is required this would need to be identified
to the Drafting Group. In addition, the Committee would be asked
to make an assessment as to whether the individual sections
were complete and could be ratified.
i) General
Freight (Drums and Pallets) 4.1
Messrs.
Desrosiers and Pearson provided an overview of the General Freight
sections noting changes from the previous draft. In brief they
noted the three options or principles which were being provided:
1) Cargo must be fully contained within a vehicle of adequate
strength, 2) Cargo must be immobilized within a vehicle and
contained by structures of adequate strength, and 3) Cargo must
be immobilized on or in a vehicle by appropriate blocking, bracing
and tiedowns or combinations of these to prevent shifting or
tipping. They also noted the table providing guidance on the
number of tiedowns required for blocked and unblocked articles
had been revised per the comments received at the last meeting.
Prior to
the discussion on the general freight section a number of Committee
members requested a further review of the first sections of
the rule. It was agreed the word "public" should be
added to section 1.1 pertaining to application. For section
1.2 General Provisions it was agreed the words "adversely
affected" needed to be better defined by the Drafting Group
in the next iteration of the rule. A number of participants
offered to supply wording by May 31, 1998. It was agreed the
last paragraph in section 1.3 should be reworked to provide
further elaboration and clarification pertaining to the weight
of cargo and working load limits. Additional clarification was
sought on Section 2.1. It was agreed for the purpose of testing
conformance with the standard it would be acceptable for shippers
and carriers to test to each criteria individually recognizing
the difficulty in developing test protocols to verify compliance
to all the criteria simultaneously. With this clarification
a number of participants indicated it was their intention to
undertake "real world" testing of the criteria. It
was suggested if the relationship between weight of the cargo
and working load limit was better explained in the previous
section the development of records of testing would be facilitated.
It was acknowledged the intent of section 2.1 was directed at
new cargo securement practices. The issue of how these practices
could be uniformly recognized by jurisdictions was a critical
problem which had to be addressed during the implementation
and maintenance phase of the rule.
Discussion
returned to the need to establish what is "reasonable"
movement per section 2.3. A number of participants indicated
there were inconsistencies in the rule which would need to be
addressed by the Drafting Group in the next iteration of the
rule. It was noted current rules in Canada and the United States
are based on there being no movement of cargo. The research
had indicated movement did occur and the difficulty would be
in defining "acceptable movement". Committee members
agreed to provide their suggestions on how this issue could
be treated in the rule in their comments to the Drafting Group.
For Section 3 it was suggested the word "capability"
be substituted for "capacity" in order to recognize
the role of air bags in cargo securement. In addition, it was
noted some binders do not have secondary or positive locking
devices. It was agreed this section would be reworked by the
Drafting Group to indicate specifically when the binder needed
to be wrapped with wire.
It was clarified
the general provisions of this section applied to all cargo
with the exception of the specific commodities which appeared
after this section. Those commodities would have to meet the
general requirements and also be secured per the specific rules
of each section. Considerable discussion ensued on whether the
tables which appear in section 4.1.5 should be included or removed
from the proposed rule. Some participants argued they should
be removed because they did not recognize the different capabilities
of various tiedowns and served to confuse the relationship between
the weight of the load and the working load limit. It was noted
current rules specify 1 tiedown for every 10 linear feet of
cargo and the rule should be explicit on stating this requirement.
Other participants argued for retention of the tables noting
the objective was to develop a performance based rule and the
tables attempted to formally recognize blocking and the weight
and size of the cargo. To not take into account the difference
between blocked and unblocked cargo would violate the objective
of a performance based rule and would result in inconsistent
treatment of either very light or very heavy articles. Moreover,
it was suggested in order to get some jurisdictions to give
up their more stringent tiedown requirements it would be imperative
the proposed rule addressed size and weight of the commodity
directly. Finally, it was suggested drivers and enforcement
officers required explicit direction on the minimum tiedowns
required for different cargo which is blocked or unblocked.
It was suggested tables of working load limits for various tiedowns
be substituted instead in either the rule or the guide. It was
suggested the general view of the Committee was that the Drafting
Group be requested to remove the tables unless there were further
reasons for their retention, or they could be reworked so as
not to confuse the relationship between weight of the cargo
and working load limit. It was agreed members of the Committee
would provide any further views on retention or deletion of
the tables, and suggestions on how to incorporate tiedown calculation
into the rule to the Drafting Group by May 31, 1998.
ii) Logs
4.2
Mr. Billing
provided an overview of Draft 7 noting the changes from the
previous draft. He indicated Draft 6 had generated significant
commentary from stakeholders in Canada and the United States
and explained how he had attempted to incorporate the comments
in the current draft. He indicated further work was still required
to finalize this section and requested that Mr. Duncan provide
a presentation on the industry concerns.
Mr. Duncan
thanked the Co-Chairs for the opportunity to address the Committee
and distributed his presentation which outlined the concerns
of the associations and provided a series of suggested revisions
to section 4.2 of Draft 7. In brief, he noted the proposed rule
was considerably improved over earlier versions but work was
still required to consider and recognize industry norms, and
include all major types of trailer and load configurations.
He indicated the industry was prepared to undertake a rewrite
of this section in conjunction with Mr. Billing and the Drafting
Group.
In discussion
it was clarified if a specific forestry product was not referenced
then it should be secured per the provisions of the general
freight sections. Mr. Duncan noted some of his members had not
understood the provisions contained in the text and the rewrite
would more clearly define the requirements. He briefly highlighted
the key elements of the industry rewrite of the rule and indicated
the Draft had been reviewed by the forestry associations of
NC, SC, MN, WA,GA, WI and endorsed by various enforcement personnel.
It was noted additional work would be required on the treatment
of bunks (i.e.: There is no current US federal requirement),
the use of pole trailers, and the application of working load
limits to different configurations of vehicles and loads. Comments
were sought from Committee members. A number of participants
indicated they would like to forward both drafts to their respective
forestry groups. It was agreed all participants would provide
their comments on section 4.2 and the first draft of the industry
rewrite of the rule by May 31, 1998. Comments are to be directed
to the Drafting Group through the Project web site, or to the
CCMTA Secretariat which would then forward them to Mr. Duncan
and the Drafting Group. The Co-Chairs inquired whether the work
could be completed for the next Committee meeting. It was agreed
the final draft of Section 4.2 would be prepared for August
1, 1998.
iii)
Dressed Lumber 4.3
Mr. Desrosiers
provided an overview of the dressed lumber section noting the
changes which had been made since Draft 6. He noted the application
section had been revised to indicate which commodities are covered
by the section and the three options outlined were intended
to recognize the role of friction in securing the cargo and
to specify the minimum number of tiedowns required depending
on whether the load was blocked or unblocked in the forward
direction.
A general
discussion on the provisions ensued. It was noted in many instances
staking the sides of loads was not practical. In addition, the
use of the headboard was also problematic given the axle weight
regulations in many jurisdictions. A number of participants
indicated the proposed rule did not specify precisely how many
tiedowns were required when there were multiple tiers and the
location of the tiedowns in relation to the tiers. Concern was
also expressed at the total number of tiedowns which would be
required for blocked and unblocked loads and the requirement
to belly wrap. It was noted without developing a table based
on weight the current rules could allow only one tiedown every
10 feet for a stack of three tiers and this would clearly not
be acceptable for safety and enforcement purposes. It was suggested
revisions to this section should focus heavily on the use of
tiedowns to provide adequate securement to meet the performance
criteria.
Mr. Desrosiers
summarized the work conducted by MTQ in relation to dressed
lumber. He noted the section was attempting to strike a balance
between safety and reasonable cost and to recognize the research
had established that adding additional tiedowns beyond a certain
amount did not provide any additional safety benefits. Mr. Pugh
indicated he and other members of his industry were prepared
to undertake additional testing and a rewrite of this section
to resolve the issues described above. It was noted this testing
would have to be undertaken at industry expense given there
were no additional funds available from the CCMTA research project.
It was agreed a small working group including Mr. Desrosiers
would be created to review the CCMTA results, current loading
patterns and securement methods, and best industry practices
in order to resolve these issues and revise this section of
the proposed rule. It was agreed testing would be undertaken
through the summer to test the performance of all the elements
of the cargo securement system working together. Concern was
expressed as to when this section would be completed. It was
agreed the working group would develop by May 31 the work plan
and the re-written section would be prepared for August 1, 1998.
It was agreed all participants would provide any additional
comments on the current section by May 31, 1998 so these could
be considered by the group tasked with revising this section.
iv) Metal
Coils 4.4
Mr. Minor
outlined the major changes which had been made in Draft 7. He
noted this section had been developed on the basis of the CCMTA
research and the study conducted by the University of Southern
Illinois. He indicated more diagrams and illustrations would
be added to the guide. He noted the draft contained provisions
for the eye horizontal method of securement and additional work
had been undertaken on the blocking and bracing requirements.
He concluded his presentation by noting per the Committee direction
the tiedown angles had been specified, and a prohibition on
using chain in an "X" pattern had been added.
In discussion,
members of the industry in attendance indicated the proposed
rule was close to completion. It was noted the issue of blocking
and bracing had been clarified and the need to have the coils
in contact with the walls when shipped in vans was close to
resolution. Mr. Minor indicated some additional editing changes
were required for the new provisions and that he would be in
contact with industry members from both Canada and the United
States to finalize the requirements. It was agreed any final
comments on the metal coil section would be provided by May
31, 1998.
v) Paper
Rolls 4.5
Mr. Minor
provided an overview of the second draft of the paper roll section,
noting discussions were ongoing with industry to address concerns
and additional work would have to be undertaken in order to
complete this section.
A general
and wide ranging discussion on the securement and transportation
of paper rolls ensued. Mr. Oldridge indicated a number of recent
accidents in BC had called into question the effectiveness of
current loading practices of the industry. He indicated additional
testing and analysis was being undertaken by the RCMP and the
results would be available by the end of May. He noted the RCMP
and BC enforcement personnel were now checking vans to ensure
the blocking and bracing provisions of the current rule were
being adhered to by industry. A number of other enforcement
personnel indicated they opened van trailers to check for blocking
and bracing as well.
Mr. Durocher
indicated his company had undertaken and video taped dynamic
tests with Québec on vehicle decelerations. The primary
conclusion was that with a 45,000 lb. load .6 g deceleration
would never be reached. Discussion returned to the AAR tests
and whether additional supplemental restraint was required beyond
rubber mats. It was acknowledged by the government and enforcement
personnel the current rules in jurisdictions required blocking
and bracing in addition to the other means of securement developed
by industry. It was further noted the rules called for tiedowns
placed over the load to prevent vertical movement caused by
bumps in the road. It was noted some current industry practice
is not in compliance with existing cargo securement rules in
the United States and Canada. It was noted the majority of the
diagrams supplied by industry to date would be considered secure
under the proposed rule because the rolls were braced against
the wall/bulkhead and thus were immobilized.
Mr. Church
sought confirmation the major issues to be resolved centred
on split/bilge loading and unitization of paper rolls. Members
of the Drafting Group confirmed these were the primary area
of concern, along with the need to fill spaces within the trailer,
and the requirement for tiedowns over the load. Mr. Church noted
that as a result of some additional discussion between members
of his Association and Drafting Group members some ideas were
being developed to address the split load and bilge load situation.
It was suggested the effect of unitizing the loads with strapping
and the use of rubber mats was not clearly understood. It was
suggested unitization of the load might negate the requirement
for tiedowns over the load. It was suggested test data would
need to be presented to confirm this to allow the current provision
to be dropped in the new rule.
It was agreed
members of the paper roll industry in conjunction with Mr. Minor
and the Drafting Group would develop a work plan to address
the issues raised at this meeting. It was agreed the group would
consolidate and review the research from various sources. In
addition, the group would review current loading patterns and
securement methods along with industry best practice in order
to address split and unitized loads. It was agreed the work
plan would include provisions for any testing which could be
undertaken through the summer. It was agreed an initial draft
of the work plan would be developed by industry and submitted
to Mr. Minor and the Drafting Group by May 31, 1998. It was
suggested a meeting of the Drafting Group and the industry working
group would be convened in late June to review progress. It
was agreed all participants would submit any other comments
or concerns by May 31, 1998 so they could be considered by the
working group. It was agreed the final proposed rule would be
prepared for August 1, 1998.
vi) Concrete
Pipes 4.6
Mr. Billing
provided an overview of the changes which had been made on Draft
7 of the proposed rule. He noted since the last meeting he had
worked with both the US and Canadian Concrete Pipe Associations
to revise the language for the proposed rule so it was acceptable
to both organizations. He noted some additional minor editing
work was still required relative to the definitions but otherwise
the section should be considered complete. He concluded his
presentation by indicating odd number pipe would be covered
by the General Freight sections of the proposed rule.
In discussion,
clarification was sought on the intent of the provisions applying
to cable and whether a prohibition was being established for
it’s use in certain applications. It was agreed this would
be more clearly specified in the final rule. It was noted the
rule and guide had been endorsed by the Concrete Pipe Associations
in both Canada and the United States. It was agreed this section
would be considered complete and ratified by the Committee.
The Co-Chairs thanked the members of the respective Concrete
Pipe Associations for their dedicated work in completing the
standard.
vii)
Intermodal Containers 4.7
Mr. Minor
updated participants on the changes which had been made in Draft
7 noting an effort had been made to address the problem of securing
the corners of a container on a curved deck.
In discussion,
it was noted section 4.7.3 had inadvertently been omitted but
would be added in the next iteration of the rule. Mr. Strawhorn
indicated in some jurisdictions containers were permitted to
over hang the structure. It was suggested this situation needed
to be addressed with tighter wording in the next version of
the rule. It was agreed a few illustrations would be added to
the guide. The Co-Chairs inquired whether this section could
be considered complete. It was agreed any outstanding final
comments would be provided by May 31, 1998. It was agreed the
Committee would consider this section to be complete and ratified
with the changes noted above unless any new issues were raised
during the commentary period.
viii)
Automobiles, Light Trucks and Vans 4.8
Mr. Neufeld
provided an overview of this section noting the changes which
had been requested at the last meeting had been incorporated
into Draft 7. In brief he noted the requirement to secure in
all 4 directions had been further reviewed. He noted edge protectors
were not required and the use of 2 direct tiedowns had been
included.
In discussion,
it was suggested provisions should be added to reflect the normal
industry practice of securing the last vehicle in a row with
4 tiedowns. Mr. Strawhorn indicated he had received comments
from the Towability Committee of the Society of Automotive Engineers
(SAE) which raised issues relative to the application of the
requirements. A copy of this correspondence would be provided
to the Drafting Group for review. The Co-Chairs sought an indication
of whether this sections could be considered complete. Members
of the industry indicated their support for the provisions contained
in the rule. It was agreed any additional comments would be
supplied to the Drafting Group by May 31, 1998. It was agreed
Mr. Neufeld would make the editing changes which had been requested.
It was agreed pending a decision relative to the comments from
the Towability Committee this section would be considered complete
and ratified by the Committee.
ix) Heavy
Construction Equipment 4.9
Mr. Neufeld
outlined the changes which had been made in Draft 7 noting he
had relied heavily on the loading guidelines which had been
developed by the US military and the Special Carrier and Rigging
Association (SCRA). In brief, he indicated provisions distinguishing
between wheeled and tracked vehicles, proper positioning of
the equipment, and overweight and oversized equipment had been
added to the rule. Guidance on blocking was provided in the
guide along with references to the appropriate loading patterns
recommended by industry.
A brief
discussion ensued where it was agreed the rule needed to include
provisions requiring hydraulic shovels or similar equipment
to be lowered and secured at the lowest point in contact with
the trailer. In addition, it was agreed illustrations should
be added to the guide. It was agreed any supplementary comments
on this section could be provided up to May 31, 1998. It was
generally agreed this section would be considered complete by
the Harmonization Committee.
x) Crushed
Vehicles 4.10
Mr. Neufeld
provided an overview of the crushed vehicles section noting
changes which had been made in this section from Draft 6. He
noted three options were being provided each which must conform
with the general provisions contained in the General Freight
section. He noted at the last meeting he had been requested
to further review option 1 and the requirement for containment
on all four sides of the vehicle.
Mr. Kasapoglu
provided a presentation of a vehicle designed specifically to
haul crushed automobiles. Copies of the presentation were distributed
as background documentation to all the participants. He provided
additional clarification on the design of the vehicle and information
on Option 1 in the standard. Following his detailed presentation
to the Committee he further suggested options two and three
were not good options for the securement of crushed vehicles.
Moreover, he suggested tarping or netting was not a solution
for securing loose parts.
Discussion
turned on whether for option 1 there would be a requirement
for walls on all four sides. Committee members inquired whether
SNF was prepared to add a fourth wall at the four foot level
to their vehicle to contain loose parts or a one foot hinged
or removable wall. Mr. Kasapoglu suggested neither was warranted.
From the discussion the Committee agreed in light of the number
of crushed vehicles which are hauled on flat bed trailers it
was beyond the scope of the Committee to mandate the use of
speciality vehicles for the movement of this commodity. As such
the rule should not favour one type of vehicle design over another
and that no endorsement would be provided from the Committee
on the SNF design. Committee members did however indicate they
could see no reason why the SNF designed vehicle would not be
allowed to operate in their jurisdiction. It was suggested and
agreed there were two objective for this section: 1) to prevent
whole vehicles from becoming unsecured or lost during transport,
and 2) developing a mechanism to ensure small parts do not become
dislodged or lost during transport. It was agreed in both instances
the general provisions of the standard apply. It was suggested
a requirement to tarp might be necessary, or a requirement for
the driver to check the load for loose parts as a function of
the trip/daily inspection. It was agreed Mr. Neufeld and the
Drafting Group would redraft section 4.10 with these two objectives
in mind. It was agreed any additional comments on this section
would be provided to the Drafting Group by May 31, 1998.
xi) Roll-on/Roll-off
Containers 4.11
Mr. Desrosiers
indicated the changes which had been made in Draft 7. In brief,
it was noted the editing changes which had been requested at
the last meeting had been incorporated into the rule.
The Committee
reviewed the correspondence provided by Mr. Legler noting the
technical objective was to have the end user employ and maintain
the integral securement system as the primary means of securement
for roll-off and hook lift containers. The employment of manual
securement should be seen as an alternate means of securement
in the event the integral system is either missing, inoperative,
or incompatible. The Committee felt this point had been covered
by the language contained in the rule. It was agreed the normative
references to the ANSI standards would be added to the rule.
It was agreed with these changes the Committee would endorse
this section and it could be considered complete.
xii)
Boulders 4.12
Mr. Pearson
noted at the last meeting a number of jurisdictional representatives
had requested the Drafting Group to develop a specific section
for large boulders. He presented the key elements and requirements
and indicated comments would be welcome from the Committee members.
It was agreed all Committee members would provide their comments
on this section by May 31, 1998.
b) Guide
to Cargo Securement - Part 2
i) Overview
Mr. Pearson
provided a brief presentation on the guide noting it was intended
that this section would accompany the rule and provide additional
clarification and practical advice on best cargo securement
practices. He noted much of the interpretation and guidance
which had appeared in the previous versions of the standard
(Drafts 1 through 6) had been included in the revised guide.
The objective of the guide was to clarify the intent of the
various sections of the rule and to assist in the drafting of
the regulatory provisions.
ii) Finalize
Guide or Identify Additional Work Required
Time constraints
did not permit a full discussion of this item to occur. Participants
did however confirm and endorse the objectives and use of the
guide. In brief, it was also agreed the finished guide should
be used by the training group as the basis for developing the
training materials. It was agreed the CVSA out-of-service criteria
provisions pertaining to cargo securement should be incorporated
into the guide. It was suggested much of the "best practice"
from other manuals and industry should be included in the interpretation
guide. It was agreed information on complying with the standard
and demonstrating how to calculate the appropriate number of
tiedowns for a given load would be included in the guide.
iii)
Schedule and Timing for Final Comments
Discussion
and agreement on additional work was undertaken during the previous
section. See items 8 i) to xii) of this Record of Decisions.
The Co-Chairs indicated to participants the importance of completing
all remaining work relative to the standard development process
by the fall. It was critical that all participants provide comprehensive
comments to the Drafting Group by the deadline specified. Mr.
Fiste indicated to US participants they were being provided
a special opportunity through the consultation process to assist
in the development of a rule prior to the formal rulemaking
process being initiated. It was suggested this opportunity should
not be lost and the best possible rule should be put forward
in the fall. In summary it was agreed all participants would
provide any additional comments on the rule and guide to the
Drafting Group by May 31, 1998. It was agreed the Drafting Group
and the working groups created at this meeting would produce
by August 1, 1998 the final proposed rule and guide.
9. Implementation
and Maintenance of a Uniform North American Standard
a) Overview
Mr. Pearson
provided an overview of the second draft of the Drafting Group
discussion paper addressing implementation and maintenance issues
relative to the North American rule. Once completed all jurisdictions
would have to determine whether there was a will to abandon
existing cargo securement requirements in favour of the single
rule. Ensuring the proposed rule is implemented consistently
by all jurisdictions implied it must be implemented in its entirety
by all jurisdictions. Any deviation will constitute a failure
to meet the primary objective of the initiative. Experience
had suggested the most effective approach to achieving a uniform
standard would be to assign responsibility for publication and
maintenance to a single agency. Conceptually this approach suggests
there is a need to establish a formal agreement between jurisdictions
which describes the obligations and process for the ongoing
maintenance of the standard. He concluded his presentation by
noting the Drafting Group was recommending the formation of
a working group to review the issues and develop recommendations
for the next meeting.
b) Discussion
and Comments on Proposed Process and Mechanism
A general
discussion ensued on the best method and means to achieve the
objective of a uniform North American Cargo Securement rule.
Mr. Minor suggested FHWA would prefer to include the full rule
in the FHWA regulations. A number of Canadian jurisdictional
representatives indicated they favoured adopting the rule by
reference indicating this would be the best means by which to
ensure uniformity in the requirements. It was noted some 30
US states had provisions where the US federal regulations are
automatically adopted in their requirements. Mr. Cooper indicated
the Canadian Trucking Alliance was seeking the rule be uniformly
adopted and implemented throughout North America. This view
was shared by most participants. It was suggested the adoption
by reference option should be pursued by the working group to
cover those US States which do not automatically adopt the US
FMCSR’s and Canadian jurisdictions. A brief review on how
interpretation bulletins are issued in both countries was undertaken.
It was noted it would be critical to maintain uniformity in
the requirements that a mechanism be established between Canada
and the United States for the issuance of uniform interpretation
bulletins and the approval of new cargo securement systems which
meet the performance criteria.
A brief
review of the other items contained in the report was undertaken
with the Committee endorsing the work plan. It was agreed a
small implementation group be tasked with reviewing these issues
and preparing an implementation plan for August 1998. It was
agreed any individuals wishing to participate on this group
would advise the Co-Chairs. It was agreed the initial composition
of the group should include members of the Drafting Group and
representatives from the ATA and CTA. It was agreed Committee
members would provide further comments and suggestions on the
mechanism and process to maintain and implement the rule by
May 31, 1998.
10. Training
/ Education Materials
Mr. Strawhorn
presented the report from the Working Group tasked with developing
a training and educational plan for shippers, drivers, carriers,
and enforcement officers on the proper methods and work practices
to load, secure and inspect cargo on North American highways
per the new rule. The Working Group was proposing the training
and education materials should be consistent, comprehensive
and appropriate for the target audiences and should be produced
in English, French, and Spanish. Mr. Strawhorn indicated at
the last meeting the Project Group had been requested to develop
the costing for the materials proposed. To this end Mr. Doyle
had provided costs which Mr. Strawhorn indicated had been reviewed
and were in line with the estimates which would be used by ATA
to develop similar material.
The need
to fully explain the performance based approach and requirements
prior to the standard being implemented in the respective countries
was emphasized. In discussion, it was suggested CCMTA should
serve to coordinate and administer the funding which would be
sought from Committee members and others to undertake this work.
It was noted it was being proposed that government and industry
split in partnership the $200 thousand US dollar cost to develop
the materials. Mr. Strawhorn indicated the Project Group was
optimistic these funds could be raised from the 22 organizations
who had contributed to the research project, and from those
agencies participating in the standards harmonization initiative.
It was noted contributions of between $5-10 thousand split over
30 partners would cover the necessary expenses. It was noted
funds had also been included for the administration of the project.
It was suggested upon completion of the rule the next step would
be to let an RFP for a firm to develop the materials under the
direction of a steering committee made up of the partners who
had contributed funds to the training component of the project.
Some participants
indicated a desire to approve the proposal, provide funding
and commence development of the materials outlined in the paper.
It was suggested the time lines would have to be adjusted to
reflect the new schedule for completion of the rule. It was
agreed it would be critical to the success of the rule that
the material be developed prior to enforcement of the new requirements.
It was suggested further work could not be initiated pending
the completion of the rule and guide. It was agreed the plan
including the various elements and costs would be approved by
the Committee and all participants would indicate to the CCMTA
Secretariat by August 1, 1998 the amount of funds they would
be prepared to contribute to the training partnership initiative.
11. Update
on Standards Initiatives - Next Steps for Implementation
a) Canada
Ms. Pelletier
provided a brief overview of the Canadian regulatory environment.
It was noted Draft 7 would be reviewed by the Standing Committee
on Compliance and Regulatory Affairs. When finalized the standard
would have to be ratified by the CCMTA Board before it could
be implemented in each Canadian jurisdiction. It was further
noted a report would have to be provided to the Council of Deputy
Ministers in September 1998.
It was noted
Transport Canada intended to publish in the near future a Canada
Gazette Part 2 regulation requiring anchor points on new flat
bed trailers with a 1 year lead time for trailer manufacturers
to comply. US participants sought confirmation on whether a
similar rule would be forthcoming in the US. Mr. Minor indicated
the regulatory responsibility for a new vehicle standard resided
with NHTSA who had declined to become involved in this area
due to other priorities. It was suggested the Co-Chairs should
approach NHTSA to urge them to develop a similar requirement.
It was suggested Committee members should write NHTSA indicating
their desire to see a similar requirement legislated in the
US. It was suggested the work of TTMA on recommended practice
47 might accomplish the same objectives as the Transport Canada
regulation.
b) United
States
Mr. Minor
provided information on the US regulatory process and indicated
FHWA intended to publish the entire proposed rule developed
by the Committee as a Notice of Proposed Rulemaking (NPRM) in
the fall of 1998. A 90 day commentary period would be provided
and it was likely the rule would go into effect late in 1999.
He further noted the project research reports would also be
made available on the US DOT web site located at www.dms.dot.gov
including information on how the hard copy reports could be
obtained from CCMTA.
From the
discussion it was acknowledged there would be a need to coordinate
the Canadian and US regulatory initiatives to ensure uniformity
and to reconcile any differences which may be created by the
different regulatory regimes. It was agreed this issue should
be considered by the Implementation Group (See item 9 of this
Record of Decisions) or at a minimum by a group of Canadian
and US officials.
c) Mexico
It was noted
CVSA had made overtures to Mexican officials to participate
in the standard harmonization initiative. A briefing would be
provided by Messrs. McAlister and Pearson to the CVSA Senior
Strategic Advisory Committee on Tuesday and an effort would
be made to secure Mexican comment on Draft 7 of the standard
(Secretariat Note: Following the briefing Mexican officials
indicated they would attempt to provide comments on Draft 7
of the standard).
12. Elements
to be Reported to Standing Committee on Compliance and Regulatory
Affairs
Ms. Pelletier
provided a brief overview of CCMTA noting the work of the Harmonization
Committee was reported to a permanent Standing Committee which
was responsible for motor carrier issues in Canada. She briefly
noted a report would be prepared for the Committee in June.
She briefly indicated the report would cover the current status
of the standard development process, training/education, an
would address some of the maintenance and implementation issues
raised by the Committee.
13. Other
Business
No other
business was identified by the participants.
14. Next
Meeting
