Can I strap my spillkit on catwalk with bungie cords?

I believe you could get cited on FMCSR §393.104 (c) Vehicle structures and anchor points. You fender is not designed to be used as a tie down point. How if you have a tray install or brackets mounted to allow for items to be tied down you most likely would meet all requirements.

 

It's not tied down to the fender. It sits in the fender but is strapped to the long enclosed hose storage tube beside it.

 

All of the regs quoted apply to cargo securement. I would think that if something's not on the BOL, it's not considered cargo and therefore not subject to the requirements.

 

Anything carried in or on the truck is "cargo" and needs to be secured.

 

Show me the official definition, please I looked, but couldn't find one.

 

http://www.fmcsa.dot.gov/rules-regulations/truck/vehicle/cs-policy.htm

Looks to me as though anything in or on the truck must be secured in a manner which keeps it not only in or on the truck, but in the location in or on the truck where you put it. If it can move while in transit, it is not secured.

 

See, Article of cargo is defined, but cargo doesn't seem to be. To ME, 'cargo' would be limited to whatever is being transported in exchange for revenue, and would therefore be limited to what is listed on the BOL. I'm looking for an 'official' definition, since what matters to ME doesn't make much difference to the FMCSA

 

[ame]http://www.youtube.com/watch?v=-kQTqSPqpE4[/ame]

 

If you want to run around operating under your definition, you go right on ahead....hopefully you won't kill anyone in the process. If you have ANYTHING on your truck that isn't secured in a manner which prevents it from moving or possibly falling off the truck, you can receive a citation for an unsecured load. It doesn't matter if it is "dunnage" or any other piece of equipment. I've seen drivers cited for having a gallon jug of oil wedged between their fuel tank and frame rail under the cab of their truck...because it isn't "secured". If it is on the truck, it needs to be secure. That's the law. You can argue your "definition" until you're blue in the face, and it isn't going to change the fact that you are getting a ticket for your unsecured stuff.

 

I haul containers and use a bungee on some of the front locks to hold the lock locked. would the DOT not accept this? Its like a scissor lock so when its pulled outwards its locked, then a bar goes over the top of it. But when you bounce down the road the bar jumps up and down causing the lock to be unsecured over bumps.