An order
form was circulated and information for securing copies of the
reports was provided. It was noted only two reports one relating
to the effect of cargo movement on tiedowns and the other relating
to performance limits of heavy trucks needed to be completed.
Reports could also be obtained by placing an order through the
Project web site at www.ab.org/ccmta/ccmta.html.
5. Overview
of Research and Standards Harmonization Process
For the
new participants Mr. Pearson provided a general overview of
the research and cargo securement standards harmonization initiative.
He noted the research had been a cooperative venture over the
past three years between public and private organizations in
Canada and the United States. The purpose of the load securement
research project was to gather comprehensive data on cargo securement
systems. He noted the standard is being developed with the collaboration
of governments and stakeholders from all three countries. It
was noted the Drafting Group drafted the standard based on the
direction provided by the Harmonization Committee. Information
on the web site and the consultation process was provided to
participants (copies of the presentation are available on the
Project web site). It was noted the slippage which had occurred
in the standard was due to the increased comments received from
new stakeholders.
6. North
American Cargo Securement Standard - Draft 6
a) Summary
of Comments Received on Draft 5
Messrs.
Pearson and Covello provided an overview of the evolution of
the standard noting the comments which had been provided from
past meetings. Essentially the guiding principles (Part 1) and
the performance criteria (Part 2) had been approved at previous
meetings, and work was continuing on the prescriptive requirements
contained in Parts 3 and 4, and on the implementation issues.
In general they noted comments remained supportive but additional
work had been requested on the mandatory as opposed to the guidance
sections of the standard. In addition a need to clarify the
requirements for vans and flat decks had been identified. Moreover,
Draft 5 had generated extensive stakeholder comment on specific
sections and commodities contained in Part 4. The emphasis of
Drafting Group efforts had been on refining and completing the
prescriptive requirements by commodity type.
b) Overview
of Revisions to Draft 6
Messrs.
Pearson and Covello briefly provided an overview to the revisions
which had been made since the September meeting. They noted
the contents of Part 4 had been restructured with the sections
on loose bulk loads, pallets and drums being merged with the
general freight sections. They noted the transition from a standard
to a regulation had not yet been completed and direction was
sought from the Committee (See items 8 b) and c) of this Record
of Decisions). They noted significant industry liaison had resulted
in major changes to the standard. In brief, they noted Parts
1 and 2 remained largely unchanged, Part 3 had been slightly
revised, reordered and expanded, and Part 4 had been completely
revised with drafts available for those sections which had been
missing from Draft 5. All sections of Parts 3 and 4 had been
revised as a result of the extensive comments received from
stakeholders. It was agreed further discussion would be deferred
until item 8
7. Reference
to Other Standards and Organizations
The Co-Chairs
indicated where appropriate the new standard would reference
manufacturing standards for cargo securement and requested the
various Association representatives update the participants
on the status of their work in support of the standard.
i) Web
Sling & Tiedown Association (WSTDA)
Mr. Takacs
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 indicated work had been undertaken
to rate and mark these products so they could be properly used.
In addition, work was underway on a standard for interior van
specifications which should be ratified in 1999. Copies of the
standards had been circulated to participants at previous meetings
and can be obtained by contacting him. He noted balloting on
the first four standards was proceeding and it was expected
the WSTDA membership would ratify the standards at a May meeting
in Victoria.
In discussion,
Mr. Takacs noted very little comment had been received on the
first four standards from anyone outside the WSTDA and he urged
participants to review and provide any comments immediately
as the standards would be finalized in May. It was agreed participants
would forward any comments on the standards to WSTDA by March
1, 1998. Comments should be sent to the WSTDA at 710 E. Ogden
Avenue, Suite 600, Napierville, Illinois (60563-8614). A brief
discussion also ensued on when the draft standard (#5) for interior
van specifications would be ready for possible incorporation
in the North American standard. It was agreed the WSTDA and
Truck Trailer Manufacturer Association should meet to discuss
the interior van specification standard and report at the next
Committee meeting. The Co-Chairs thanked Mr. Takacs for the
support provided by WSTDA in the research and standard development
phase of the project.
ii) Truck
Trailer Manufacturers Association (TTMA)
Mr. Carr
indicated the TTMA had met with the Drafting Group in Washington
on January 21, 1998 to review the standard and to address outstanding
issues relating to cargo securement relative to the manufacturing
of trailers. He noted the meeting had served to clarify issues
and provided trailer manufacturers with an opportunity to understand
the goals and objectives of the standard. He briefly noted the
TTMA had created a sub-committee to review freight vans and
had undertaken to revise recommended practice 47 and appendices
including the addition of a test method.
From the
discussion it was noted a preliminary draft of revised recommended
practice 47 would be reviewed by TTMA in May, and it was hoped
the final revised practice could be approved by the TTMA Board
in October. It was suggested the van wall strength should be
adequate if the load is spread over the surface of the wall.
It was noted in general it would be difficult to attach tiedowns
to the wall. It was further noted with respect to the .8g forward
acceleration criteria the industry representatives had not understood
this could be met through a combination of friction and the
strength of the front wall. It was noted .6g was available from
most bulkheads as this was a US federal requirement. Participants
were advised they could obtain copies of recommended practice
47 from Mr. Don Vierimaa of TTMA at 1020 Princess Street, Alexandria,
Virginia, 23314 (Tel: 703-549-3010). It was agreed Mr. Carr
and TTMA would forward as soon as possible the preliminary draft
of revised practice 47 for incorporation into the standard.
iv) Waste
Equipment Technology Association (WASTEC)
Mr. Legler
provided a presentation on the work currently being undertaken
by WASTEC. He noted WASTEC was looking for the ANSI Z245 standards
being recognized as the basis for specialized tilt frame and
roll-off containers. He noted the timing was perfect as WASTEC
was updating the ANSI standards at the same time the Harmonization
Committee was developing the cargo securement requirements.
He noted he had worked with Mr. Desrosiers to ensure the compatibility
of the requirements and would be presenting Draft 6 section
4.14 to his membership in the first week of March. He suggested
it was unlikely his membership would have problems with endorsing
the current version of the cargo securement standard.
In discussion
Mr. Legler indicated the market would work to eliminate sub-standard
equipment. He noted a small problem might still exist relative
to specifying in the standard the maximum movement limit of
7 cm (2 3/4"). It was suggested consideration also be given
to including options of steel cable and mechanical lifting devices.
Concern was expressed that an enforcement officer might confuse
the requirements in this section with the ISO standards. It
was agreed the Drafting Group would clarify the requirements.
The Co-Chairs thanked Mr. Legler and WASTEC for the work they
had done on the standard noting this was another excellent example
of government and private sector cooperation.
v) National
Association of Chain Manufacturers (NACM)
The Co-Chairs
welcomed Mr. George as the representative of the NACM to the
meeting and requested an update on the issues which had been
referred to the Association. Mr. George provided a series of
tentative responses to the questions which had been raised at
the last meeting noting the draft responses would have to be
ratified by the full NACM membership before they could be endorsed
as final. He suggested chain used for cargo securement should
be round wire welded chain of at least 1/4" wire diameter.
In concluding his presentation he suggested the default values
of proof coil chain should be used in the standard as it strikes
a balance between a practical and usable specification and the
needs of the users and the potential risk of misapplication
of the chain.
A general
discussion ensued on the safety factors between chain, hooks
and tiedowns. The importance of rating and marking was emphasized.
It was noted chain attached to a substandard hook could result
in problems and the lowest rating of either component would
have to be used in calculating whether the load was secure.
Clarification was sought from the NACM on whether a 4 to 1,
or 3 to 1 safety factor should be used for rating and marking
purposes. Mr. Davidzik indicated from an enforcement perspective
the mixing and matching of different grade of chain should be
restricted. It was agreed the Drafting Group and the NACM would
be requested to review this issue and incorporate appropriate
language where required in the general and prescriptive sections
of the standard. It was agreed Mr. George would take back a
request for the NACM to develop a rating and marking standard,
evaluate the safety factor issue, and provide a formal reply
on the default value to be used. Mr. George agreed to provide
a formal response to the Drafting Group as soon as possible
after the March 10, 1998 meeting of the NACM.
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
receive an overview of the results from the focus group sessions
held on the previous day and to provide additional direction
to the Drafting Group on issues which needed to be addressed
in the next draft. In addition, the Committee would be asked
to make an assessment as to whether the individual sections
were complete and could be ratified. It was agreed a short presentation
on the focus group sessions would be made by the Drafting Group
member responsible for the section followed by an identification
of future work.
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 and providing
a summary of the discussions held on the previous day. 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 in this draft drums and
pallets had been removed as separate sections and added to the
general freight requirements.
Following
discussion it was agreed there was a need to clarify the intent
of Table 1 and the guidance provided on the number of tiedowns
required. It was suggested the performance criteria must also
be used to establish the strength and number of tiedowns for
a variety of commodities and configurations. It was suggested
and agreed the Drafting Group review and substantiate the numbers
in Table 1. In lieu of a time requirement for the periodic checking
of securement systems it was agreed the Drafting Group would
be requested to revert to distance intervals and review the
possibility of using the log book and/or the daily trip inspection
report to verify when the check was conducted (for enforcement
purposes). It was agreed the Drafting Group would be requested
to further review the section pertaining to angles of the tiedown.
Common sense would be required from an enforcement perspective
to ensure the appropriate application of the angle requirement
(i.e.: tarps). It was further agreed the Drafting Group would
be requested to provide an additional explanation within 4.1.1.
in relation to the bulkhead requirement. The rationale for including
drums and pallets in this section was endorsed by the Committee.
Participants indicated general agreement for this section with
the caveats noted above. It was suggested this section could
be ratified at the next meeting. It was agreed any final comments
would be provided by March 6, 1998 with suggestions on which
part(s) of this section should be placed in the guide, and which
part(s) would be retained in the standard.
ii) Logs
4.2
Mr. Billing
provided an overview of the section in draft 6 noting the changes
from the previous draft. He indicated Draft 5 had generated
significant commentary from stakeholders and explained how he
had attempted to incorporate the comments in the current draft.
New issues raised included the need to develop a better understanding
of bunks and whether they should be load rated, defining "crowning"
for enforcement purposes, and whether there was a need to provide
additional requirements when ice and snow were present. Mr.
Billing indicated he would be pursuing these issues with industry
for the next draft.
The issue
of special requirements for short logs (less than 4 feet) loaded
transversely was discussed. It was agreed it would be impractical
to impose a restriction given the number of shippers and carriers
who haul this commodity throughout North America. It was agreed
Mr. Billing would further pursue these issues with industry
groups. It was agreed participants would review the questions
and provide any additional comments by March 6, 1998. It was
agreed the Committee would withhold endorsing this section pending
the revisions to be contained in Draft 7.
iii)
Dressed Lumber 4.3
Mr. Desrosiers
provided an overview of the dressed lumber section noting the
changes which had been made since Draft 5. From the focus group
sessions he reported that there had been general support for
the options which had been provided. It had been acknowledged
the best approach would be to improve the contribution of friction
between tiers (i.e.: rubber mats and special skids). The Drafting
Group was requested to consider making these requirements mandatory.
It was noted when material was tiered it was critical no shifting
of cargo occurs as it would impact on vehicle stability.
It was noted
this section was intended to apply to all commodities of similar
shape and size. It was agreed there was a need to indicate the
other commodities (e.g.: dry wall) that this section was intended
to cover and consult with the appropriate industry groups. It
was agreed the Drafting Group would be requested to review whether
adding "belly straps" would contribute to improved
cargo securement practice. It was suggested and agreed further
work would be undertaken to clarify the third paragraph relating
to restraint in the forward direction. In addition, it was suggested
some additional illustrations be added for tiered loads and
to specify the number and type of tiedowns required per the
last bullet. In light of the additional work to be undertaken
it was agreed approval for this section would be deferred until
the next meeting. It was agreed all participants would provide
any additional comments by March 6, 1998.
iv) Metal
Coils 4.4
Mr. Minor
outlined the major changes which had been made between draft
5 and 6 and reported on the outcome of the focus group session
held on the previous day. In brief, he noted that lighter coils
could be secured per the general requirements and that more
diagrams and illustrations would be added to indicate transportation
in vans. He noted the next draft would contain illustrations
demonstrating the eye horizontal method of securement and further
work would be undertaken on the blocking and bracing requirements.
From the
discussion it was agreed Mr. Minor and the Drafting Group would
be requested to provide a better explanation and illustrations
for the angles and how they are measured for the various configurations.
In addition the Drafting Group was requested to review the requirement
to place the coil in contact with the wall in a van trailer.
A number of participants suggested this would be difficult to
achieve. Moreover the Drafting Group was requested to review
the issue of using the "X" chain pattern for securing
coils. It was suggested and agreed for section 4.4.5 the banding
should be removed from the diagram. It was further agreed a
scenario illustrating the "eye forward" configuration
would be added. It was suggested and agreed for section 4.4.3
the header board requirement should be included. It was agreed
Mr. Minor would work with Mr. Carr and the TTMA to generate
this number. Mr. Strawhorn indicated the ATA had some additional
concerns relative to the placement of the coils, blocking, and
the use of tiedowns. These issues would be discussed at a meeting
of the Special Carrier and Rigging Association and the American
Association of Railroads to be held in Texas at the beginning
of March. It was agreed as soon as possible after the meeting
a copy of the concerns would be forwarded to CCMTA Secretariat
for distribution to the Drafting Group in order to facilitate
the preparation of Draft 7.
v) Paper
Rolls 4.5
Mr. Minor
provided an overview of the first draft of the paper roll section,
reported on the outcome of the focus group session, and provided
an outline of the supplementary testing which would be undertaken
to address a number of industry concerns. He noted an effort
would be made by the industry to undertake testing and share
data establishing the safety of current industry practice.
From the
discussion 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 would be considered secure because the
rolls were braced against the wall/bulkhead and thus were immobilized.
It was agreed Mr. Church and others would supply studies for
review by the Drafting Group (e.g.: Load straps by US carrier,
New Brunswick study). It was acknowledged there was a need to
undertake further testing to resolve some of the issues which
had been raised in the focus group session. Messrs. Grosso and
Jacques indicated their respective organizations might be able
to do tests if there was an agreement on what was required.
It was agreed
a working group consisting of Messrs. Billing, Church, Grosso,
Hershey, Jacques, and Minor would be formed to develop the scope,
tests and procedures for resolving outstanding issues. It was
agreed the group would try to establish whether there is a standard
protocol for friction testing. In addition, the group was to
determine the type of paper and roll size to be tested recognizing
not all configurations of paper roll could be tested. It was
agreed the issue of rolls loaded horizontally would be reviewed
for possible inclusion in the testing along with paper rolls
that have a high centre of gravity. It was agreed the tests
should include rubber mats & other securement options (e.g.:
straps). It was agreed an initial conference call should be
held to work out the logistics. It was agreed an effort would
be undertaken to conduct the testing in March.
It was agreed
a meeting of interested participants would be convened on March
31 in Ottawa with the Drafting Group to review the results of
the testing and to develop a further draft of the paper roll
section. It was agreed Mr. Church in conjunction with Mr. Hershey
would develop the agenda for the March 31 meeting and forward
it to the Secretariat for distribution (Secretariat note: Transport
Canada has provided a board room for the meeting. Particulars
to be forwarded by Mr. Pearson to interested parties). It was
clarified this meeting with the Drafting Group would be limited
to forest products (i.e.: logs, paper rolls, dressed lumber).
Stakeholders wishing to participate should contact the CCMTA
Secretariat for details and a notice will be placed on the Internet
site.
vi) Concrete
Pipes 4.6
Mr. Billing
provided an overview of the changes which had been made in Draft
6 and indicated work was continuing with both the American and
Canadian concrete pipe producers and shippers. He noted the
industry was reviewing some additional issues and consequently
the draft should not be considered final.
From the
discussion it was noted Mr. Billing was working with the industry
groups to resolve issues relating to the need for additional
diagrams, specifying tiedown capacities, and developing requirements
for tiered and mixed loads. These issues should be resolved
in the next few weeks and a final draft will be produced for
review and approval at the next meeting.
vii)
Containers 4.9
Mr. Minor
updated participants on the changes which had been made in Draft
6 noting in particular the existing legislated requirement had
been dropped in favour of the performance requirements of the
standard. He noted from the focus group session the issue of
containers resting on all four corners of a curved flat deck
had been raised. As a result an effort would be made to redraft
the language of the section to demonstrate how the corners could
be supported.
From the
discussion it was agreed a few illustrations would be added
to the section and grammatical and reference errors would be
corrected. The Co-Chairs inquired whether this section could
be considered complete. The general consensus was this section
would be considered final once the amendments and illustrations
had been incorporated in the text.
viii)
Loose Bulk Loads 4.10
Mr. Covello
indicated the Drafting Group was recommending the section on
loose bulk loads be removed from Part 4 as a separate section,
and that loose bulk loads must meet the general provisions of
the standard. It was noted the initial reason for including
the section had been to address the tarping requirement which
appears in a number of jurisdictional regulations. The Drafting
Group was suggesting the requirement for tarping should be left
to individual jurisdictions.
Concern
was expressed the non-inclusion of this specific section could
result in non-uniformity of requirements. In response it was
noted the general sections contained a prohibition against spillage.
Discussion turned to other loads such as carpet which might
require specific loading and securement guidelines. It was suggested
while carpet was a difficult commodity to secure, the freight
was not being lost at the side of the road. In addition it was
suggested the over width regulations and CVSA out-of-service
criteria would address issues relative to "bulging"
trailer sides. The Committee endorsed removing this section
from the prescriptive requirements.
ix) Automobiles
4.11
Mr. Pearson
provided an overview of this section on behalf of Mr. Neufeld
noting significant changes had not been made in this section
of Draft 6. He reported the focus group session had identified
the need to further review the issue of anchor point rating
and marking. In addition some consideration would be given to
including the dollies which are used to transport automobiles.
Mr. Ferrell
requested the Drafting Group review the number of tiedowns required
noting the industry practice in many instances was to use only
2 tiedowns. A request was made for the Drafting Group to revisit
the requirement for securement in all four directions. Moreover
the members of the auto-haulaway industry expressed concerns
relative to the angles which must be met (45 degrees) noting
in many instances the placement of the anchor points made this
difficult to achieve. Clarification was sought as to whether
all anchor points needed to be rated and marked, or whether
compliance could be achieved through a single permanent label
affixed to the vehicle which provided the anchor point rating.
A number of participants suggested NHTSA should become involved
in setting this requirement. It was noted NHTSA had expressed
no interest in developing an anchor point requirement. Participants
suggested a further effort be undertaken by the Drafting Group
to contact and involve NHTSA in the process. In general members
of the industry indicated their support for the provisions contained
in the standard. It was agreed additional comments would be
supplied to the Drafting Group by March 6, 1998. It was agreed
Mr. Neufeld would follow up with the participants on the issues
so that the appropriate language may be included in Draft 7
of the standard. It was agreed this section would be ratified
at the next meeting.
x) Heavy
Construction Equipment 4.12
Mr. Pearson
provided an overview of this section on behalf of Mr. Neufeld
indicating the changes which had been made from Draft 5 and
updated the participants on the results of the focus group session
held on the previous day.
Participants
indicated their concerns were similar to the automobile section
and suggested further work needed to be undertaken relative
to the anchor point rating, marking and placement requirements.
It was suggested and agreed the applicability section be reworked
to identify wheeled and tracked vehicles and additional clarification
be included in the next draft to indicate the provisions do
not apply to overweight/over width equipment which is considered
a non-divisible load. It was noted the movement of oversized
equipment would be covered by the special permitting requirements
in jurisdictions. It was suggested and agreed the Drafting Group
should give some consideration to developing a transition period
for existing equipment. Moreover the Drafting Group was requested
to redraft language in part 4.12.3 and to review the need for
blocking/bulkhead requirements for figure 2. In addition, it
was agreed additional illustrations would be added to this section.
It was agreed any additional comments would be provided by March
6, 1998 and an effort would be made to ratify this section at
the next meeting.
xi) Crushed
Vehicles 4.13
Mr. Desrosiers
provided an overview of the crushed vehicles section noting
changes which had been in the section from Draft 5. He noted
the Drafting Group had been requested to review the California
requirements and was seeking comments on whether the "status
quo" (i.e.: not requiring nets or walls) was appropriate
for this commodity. He noted the Drafting Group would further
consider the use of tarps to contain small parts.
Mr. Kasapoglu
provide a presentation of a vehicle designed specifically to
haul crushed automobiles. He provided additional clarification
on the design of the vehicle and information on Option 1 in
the standard. Some participants questioned whether side boards
or curtains could be placed on the open side of the vehicle.
While impressed by the design of the vehicle Committee members
were quick to indicate the standard should not favour one type
of vehicle design over another and that no endorsement could
be received from the Committee for this particular design. It
was noted a large number of multi-purpose flat deck trailers
were used for the transport of crushed vehicles and the standard
should not prohibit their use. It was agreed the Drafting Group
would be requested to revisit option 1(implies containment on
all four sides) and provide alternate wording. It was agreed
Mr. Neufeld would be requested to seek out the views of other
industry groups on this section. Messrs. Oldridge and Davidzik
indicated they would supply additional industry groups and comments
on this issue to Mr. Neufeld. It was agreed any additional comments
on this section would be provided to the Drafting Group by March
6, 1998.
xii)
Roll-on/Roll-off Containers 4.14
Mr. Desrosiers
provided participants with an overview of Draft 6 and reported
on the results of the focus group session held on the previous
day. In brief, it was noted some minor editing changes would
be made to the section and the Drafting Group had been requested
to further review the issue of "acceptable" movement
and in particular the 7 cm (2 3/4") requirement.
In discussion
it was noted the new ANSI standard might specify 5 cm. It was
suggested and agreed this would not be a problem and the "in-service"
norm of 7 cm could be retained. It was agreed the next draft
would reference the appropriate ANSI standards. It was agreed
the sentence applying to loose bulk loads with these type of
containers would need to be revised to be consistent with the
Committee decision on Part 4.10. It was agreed with these changes
the Committee would endorse this section and it could be considered
complete.
b) Agreement
on Any Additional Work Required and Deadline 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 issue
of whether boulders should warrant a special section in Part
4 of the standard or be considered as part of the general freight
section was discussed. It was noted the research had developed
principles for boulders which were not captured in the present
draft of the standard. A number of jurisdictional representatives
indicated they had experienced accidents and fatalities with
the transport of boulders. It was suggested one simple solution
would be to require boulders to be carried in dump trucks. It
was suggested there was still a vehicle stability issue which
needed to be addressed particularly with large boulders which
would not fit in a dump box. It was agreed the Drafting Group
would prepare a section on boulders for inclusion in Draft 7
for review at the next meeting. It was agreed Committee members
would provide suggestions on this section to the Drafting Group.
Discussion
turned to other issues not yet addressed by the Drafting Group.
It was noted work was still required relative to a process for
endorsing new and innovative means to secure cargo which would
meet the performance criteria contained in the standard. It
was noted the Drafting Group had yet to develop the common offences
under the standard (i.e.: failure to secure) and the guidelines
or recommended fines. It was agreed this work needed to be undertaken
but it was agreed further consideration of these issues would
be deferred in order to permit the Drafting Group to focus on
completion of the standard. Committee members were encouraged
however to submit their ideas on these issues and additional
work required in their comments to be provided by March 6. It
was agreed a "shopping list" would be maintained and
reviewed at the next meeting.
c) Guide
to Cargo Securement - Part 2
Messrs.
Covello and Pearson provided a presentation on this subject
noting the current standard contains a mix of regulatory and
interpretation material. It was noted some jurisdictions had
been requesting the next iteration of the standard be drafted
more as a regulation. In this context much of the advisory material
currently contained in the draft standard would be removed and
placed in an interpretation guide. Committee member direction
was sought on the shape and format of the rule and the guide.
From the
discussion it was agreed both a rule and guide needed to be
produced. It was noted without the guide there was a good chance
discrepancies would creep into the standard when jurisdictions
moved forward to implement the regulation. It was suggested
the finished guide should be used by the training group as the
basis for developing the training program. It was agreed the
CVSA out-of-service criteria provisions pertaining to cargo
securement be incorporated into the guide. It was suggested
much of the "best practice" from other manuals such
as the AAR, SCRA, and Australian guide should be included in
the interpretation guide. It was suggested much of Part 2 would
be included in the guide as opposed to the rule. 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. It was agreed a number
of examples and illustrations should be provided.
It was agreed
all Committee members would reflect on what should be included
in the rule and guide and provide suggestions to the Drafting
Group by March 6, 1998. It was agreed the Drafting Group would
produce for the next meeting the proposed rule, and a guide
which contains the rule and the interpretive text for inspectors,
drivers, carriers, and shippers.
9. Implementation
and Maintenance of a Uniform North American Standard
a) Overview
Mr. Pearson
provided an overview on the Drafting Group discussion paper
addressing implementation and maintenance issues relative to
the North American standard. He noted three issues were critical
in order for the full benefit of the initiative to be realized
by shippers, carriers and government agencies. The standard
must be viable and technically sound supported by the research
and state clearly what is required to comply. Once completed
implicated jurisdictions would have to determine whether there
was a will to abandon existing cargo securement requirements
in favour of the standard and then some mechanism must be implemented
to undertake revisions to address problems identified by jurisdictions.
Ensuring the proposed standard 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. Finally, 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.
b) Discussion
and Comments on Proposed Process and Mechanism
A general
and lively discussion ensued on the best method and means to
achieve the objective of a uniform North American Cargo Securement
rule. It was noted if all agencies abided by the document it
needed to be given a "home". Various options ranging
from CCMTA, CVSA, a standards setting body or third party were
debated. Mr. Legler suggested consideration be given to a joint
CSA/ANSI/CONSETRA (Mexico) Committee to maintain and upgrade
the standard. Mr. Minor suggested FHWA would prefer to include
the standard in the FHWA regulations rather than adopting by
reference. A number of Canadian jurisdictional representatives
indicated they were not opposed and actually favoured adopting
the standard by reference but noted the implications of this
option would need to be further discussed. It was noted from
a provincial perspective the body selected would have to be
recognized by all jurisdictions. It was further noted some US
states could also adopt by reference but a minimum 45 day period
for comment was required. Mr. Cooper indicated the Canadian
Trucking Alliance was seeking that the rule be uniformly approved
and adopted throughout North America. Mr. Couture proposed and
offered to draft a paper recommending the standard be adopted
by reference, and that CCMTA/CVSA be tasked with maintaining
and upgrading the rule for an initial five year period.
Ms. Pelletier
suggested this action was premature and the Standing Committee
on Compliance and Regulatory Affairs should be presented a redrafted
options paper recognizing the limitations relative to maintenance
of the standard. It was agreed further discussion of this issue
would be deferred until the next meeting. It was agreed however
that Committee members could provide comments and suggestions
on the approaches suggested in the paper and a redrafted paper
would be considered at the next meeting.
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.
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. Briefly, he noted training should be based on adult
education principles, be modular in format (to permit updating),
and should include a refresher and reminder component. The Working
Group was proposing common instructor and training packages
be developed in a variety of formats including manuals, video,
cd-rom and Internet. Moreover, shipping posters and driver handouts
were also being proposed. He indicated an aggressive work schedule
had been included and agreement was required on funding requirements
and sources. He concluded his presentation by noting the Working
Group was recommending a consultant be hired to develop these
materials and that a joint government/industry sub-committee
be formed to oversee development.
From the
discussion it was noted a performance based standard was considerably
different from existing regulations and therefore the materials
to be developed should encompass basic understanding of both
the "why" as well as the "how" of proper
cargo securement. The need to fully explain the approach and
requirements prior to the standard being implemented in the
respective countries was emphasized. The general focus and approach
of the plan was endorsed by the Committee. In discussion it
was suggested CCMTA should serve to coordinate and administer
the funding which would be sought from Harmonization Committee
members to undertake this work. CVSA was also suggested as a
potential location for the coordination of this work. Various
industry representatives indicated a desire to participate and
contribute funds for the development of material for their specific
commodities.
Some participants
indicated a desire to adopt the proposal, provide funding and
initiate development of the materials as outlined in the paper.
It was suggested it would be critical the material be developed
prior to enforcement of the new requirements. Ms. Pelletier
suggested it would be premature to ratify the proposal at this
stage pending completion of the standard. It was agreed the
Working Group would be tasked with developing the funding requirements
for each item contained in the plan. It was agreed further consideration
of the proposal would be deferred until the next meeting.
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 when completed the standard and guide would be
reviewed by the Standing Committee on Compliance and Regulatory
Affairs and then the CCMTA Board.
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. Some participants sought confirmation the requirements
would be consistent with US regulatory action. It was noted
it was hoped the TTMA revised recommended practice would address
the issues arising from NHTSA’s lack of interest in bringing
forward a similar regulatory requirement.
b) United
States
Mr. Minor
provided information on the US regulatory process and indicated
FHWA intended to publish as a Notice of Proposed Rulemaking
(NPRM) the standard (when finalized) for comment, as well as
all the research reports for review. He indicated the rulemaking
would indicate copies of the reports were available from CCMTA
and it was anticipated the rulemaking would be published later
this year following completion of the consultation process with
industry.
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 further discussion
of this issue would be deferred until the next meeting.
c) Mexico
Mr. Fiste
provided an update noting Mexico had declined to participate
in the research, but had been monitoring the standard harmonization
initiative. He indicated in discussion and correspondence from
Mexican officials they favoured the process and would review
the requirements when the standard was completed. He noted an
effort would be made to have Mexican officials in attendance
for the next meeting to allow any concerns or comments to be
brought forward prior to finalizing the standard.
12. Other
Business
No other
business was identified by the participants.
13. Next
Meeting
It was agreed
the next meeting would be held just prior to the CVSA Spring
meetings on May 2, 1998 in Irvine, California. Mr. Fiste indicated
he would like to receive an indication of planned attendance
in order to ensure the room was large enough to accommodate
the participants. It was agreed participants would contact CVSA
at (301)-564-1623 to confirm their intention on participating
and to secure conference registration information.
14. Adjournment
The Co-Chairs
thanked the participants for a productive session and adjourned
the meeting.
