So.... if an officer attempts to issue a violation, I would politely request to see the written regulation.
I worked in Safety for about 18 months. I don't recall if the issue was ever found in the regs. I do know that it was challenged an the Driver won in court in LA. I think I am going to start a new thread on crazy securment violations.
As for using 1 chain and two binders to create 2 tie downs, it's perfectly legal. The regulation states 4 a minimum of 4 tie downs, it doesn't say anything about 4 chains. If you arrange the chain and binders with slack in the middle you can cut the chain and both tie downs will remain secure, that's two tie downs. This was brought up at the San Antonio meeting in 2010. IMO CVSA made a mistake in it's response, they had an article in Guardian written, but they should have also added it as a FAQ in Op Policy 5.
As far as the 50 vs 100 WLL is concerned, does anyone have the docket number, RIN or FRDN? I can't find anything anywhere about it. I thought I had read the minutes for every cargo securement subcommittee meeting in the last decade, I would think something like that would be talked about, and debated at more than one meeting. Anyone know what meeting this changed was discussed at? If the regulation has changed, I'm genuinely curious as to why. It would seem to go against the testing that was done to come up with the regs, although I do see some ways that it could be made to fit. However, I haven't seen any other changes that would seem to be necessary. Has more testing been done? Has something been reinterpreted? I only see those chains providing about 60% WLL of securement, so what has changed?
Sounds like somebody needs a new green book! Or possibly come around a little more often. This gets hacked out a couple times every month.
My company says you can use stake pockets with four points of contact and to avoid spools if possible. Never hook right onto rub rail but I'm kinda new to this so???
Maybe I do need a new green book... What is the month/date of yours that shows the new regulation saying you get the full WLL? Let's talk about Appendix G to Subchapter B of Chapter 3, more commonly known as an annual DOT inspection. Did you know that a level 1 or level 5 inspection no longer counts as an annual inspection? It's ok if you haven't heard, the change took effect last Friday. The change in the regulation was published in volume 81 of the Federal Register page 47732, RIN 2126-AB81, docket number FMCSA-2015-0176. They say that since inspectors don't always check everything on the side of the road it shouldn't count as an annual. That was a regulation that changed last week. I can find everything I need to know, and I saw it last weekend, yet with this alleged WLL change I can't find anything but a link to a summary of the rules.
Don't use a green book anymore. Just go straight to their website. I never used a level 1 or 5 for my annual anyway. And was more specifically talking about having to have the strap inside the rub rail. I always do exc pt when wide but it isn't required.
I never hooked onto the rail Not even with a fuehauf. Those rails can snap. What to do then? Well, I had a ravens covered wagon, that means a drop tie every foot on edges rated for half inch chain (Yea yea yea...) pull it up, throw hook on, bind it. Done.