Do these two rules contradict one another? By virtue of RULE 2, I say there is no need to go to the other side of the trailer to get full WLL. What say TTR?
RULE 1
https://www.fmcsa.dot.gov/regulations/title49/section/393.106
393.106 (d) (3)
(d) Aggregate working load limit for tiedowns. The aggregate working load limit of tiedowns used to secure an article or group of articles against movement must be at least one-half times the weight of the article or group of articles. The aggregate working load limit is the sum of:
(1) One-half the working load limit of each tiedown that goes from an anchor point on the vehicle to an anchor point on an article of cargo;
(2) One-half the working load limit of each tiedown that is attached to an anchor point on the vehicle, passes through, over, or around the article of cargo, and is then attached to an anchor point on the same side of the vehicle.
(3) The working load limit for each tiedown that goes from an anchor point on the vehicle, through, over, or around the article of cargo, and then attaches to another anchor point on the other side of the vehicle.
RULE 2:
https://www.fmcsa.dot.gov/regulations/cargo-securement/cargo-securement-rules
Minimum Working Load Limit for Cargo Securement Devices and Systems
The aggregate working load limit of any securement system used to secure an article or group of articles against movement must be at least one-half the weight of the article or group of articles. The aggregate working load limit is the sum of: One-half the working load limit of each tiedown that goes from an anchor point on the vehicle to an attachment point on an article of cargo; and The working load limit for each tiedown that goes from an anchor point on the vehicle, through, over or around the cargo and then attaches to another anchor point on the vehicle.
Aggregate WLL....one more time once and for all LOL
Discussion in 'Flatbed Trucking Forum' started by rank, Oct 11, 2015.
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They do seem to be worded to contradict each other but I think it just how they are worded. Ive always been told only way to get full WLL was to go deck to deck. Every time ive been inspected or talked with DOT the only counted chains that were tied deck to deck for full WLL. I always put on more then required and have just got in habit of trying to get atleast a couple that are deck to deck whether im pulling step or rgn
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Yeah but IMO "deck to deck" doesn't prevent sideways movement as well as pulling from one side of the trailer with at least 4 chains so I "cross chain or X-chain" wherever possible but I don't like using twice the chains to overcome that silly 1/2 WLL rule either.
My solution is I follow rule 2 and carry a photocopy of it in my log book. Haven't been questioned yet but I'd like to be able to quote and actual reg number if the situation ever arises.
Typical govt gobblygook. -
It all says pretty much the same thing but defines the aggregate in different ways to cover each different situation.
Example on finished dies and molds, I have to tie them down with three or four items (chains/straps combo), the die or mold have holes in them so they can be lifted into the machine, I put in the appropriate pin in those holds (1, 1.5 or 2 inch pins) and then put a chain over them, tie it down with a binder on each side of the deck. The chain is in front of and in back of the die or mold and ensures that it won't move but because of the size, I put at least one or two straps cross the die or mold with padding (they have sharp edges no matter what the machinists say they ground the edges down) to add to the securing of that piece. The aggregate is one half of the total of the chains/straps WLL. I also use one WLL number for all the chains - I have mixed grades on most of the trucks I drive so I go with the lowest grade and use that.
Now there was times where I will wrap the straps around a piece when I am driving a small flatbed, in the case of a 3000 lb mold where it is put right on the deck, I will go around it one way with one strap and anchoring it on the same side with another strap on the opposite side and then go over the top with a strap to hold it down as an added securement. I have been criticized a few times by big bad truckers who were filling up next to me about overusing straps but they don't seem to deal with slippery things that are machined to a smooth finish with oil on them that make them slide everywhere on almost every surface they are put in. Nothing like leaning against a 5000 lb cavity on a machine and having it move a few inches. -
We just went through a securement class from the FMCSA directly. What I got from that was that as long as both ends of the chain secures to the trailer at some point then you get the full WLL.
They did however try to tell us that the outrigger brackets on the Cozad trailer was the securement point and not the trailer frame.rank Thanks this. -
Define "deck-to-deck" please, just out of curiosity.
Is that what you call using one chain with a binder on one end? -
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Someone else will have to chime in. -
tsavory Thanks this.
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