don't use rub rail for securement, but what is the underside called?

If the anchor point is not failing from a chain or strap hooked to it, it’s strong enough. That’s how I interpret the regs.

 

393.104 hasn't been changed since 2006. It's right in the citation notes at the bottom of that particular section.



Of particular note is this comment from Kinedyne recommending that "rub rails" be renamed to "securement rails" and given a WLL.

Federal Register :: Request Access

This was the FMCSA response to that:

Federal Register :: Request Access

ECFR is updated almost daily but they do cite the most recent NPRM at the bottom of each specific section that applies to that section.

The rule of no markings needed for anchor points is indeed from 2002 as noted in the FMCSA response above. It hasn't changed since then. Nowhere in the current laws is there any wording that says any anchor point needs a marked or known WLL.

 

Most people would agree with you. I've never had an inspector ask me about the WWL for tie down points on our RGNs or flatbeds.. As fussy as they get out here I'm sure they would have if it was an issue.

 

Be that as it may, the manufacturers don't get the ticket, if they decide to. I did note, that the manufacturer may not be required to mark and rate, but again, as all things usually end up, it's CYA, as the one that gets the ticket, is the one with the least control over specs, but all the responsibility to justify their decision.

 

Get a ticket for what? What specific regulation is broken by using an unrated anchor point?

 

Here we go again. Here's a link to an industry article that points out that the trailer is part of the securement system. Again, if the part you attach to, is not rated (East, in this case regards rub rails), it is by default, insufficient in and of itself to qualify as a load rated anchor point for use, and is subject to a violation under the previous referenced cite. I didn't disagree that makers don't have to mark/rate them, I'm only pointing out that if they don't, the onus is on you when you decide to use them, that the decision to use an unrated securement point is on you and if it is unrated, it becomes the weakest link and down rate of your securement if YOU can't prove what it's rated for, let alone that it is sufficiently undamaged to qualify for that rating. Like unmarked chains or straps get lowered rating, and therefore lower securement values and thereby invalidating their Aggregate WLL value. The ticket/violation becomes yours because YOU can't produce the documentation that the anchor point is rated for what you think it's rated for. So I err on the side of caution, rather than bravado or braggadocio. Better to have the information than not. Fini.

Don’t Overlook Trailer Anchor Points

 

The trailer frame.

 

Melton trained me to use the rub rail. I can't see how one of the biggest flatbed companies out there would train drivers to use the rub rail if it were against the regs. On another note, when using the rub rail, you have to be careful not to cover the reflective tape with the strap. DOT WILL cite you for that if they have a bug up their arse that day.