put strap outside of the deck is ok？

You're right, I did and see that the wording was removed...although I disagree with why they did it, (manufacturer's non-standard designs, lack of updated fleet equipment and varying enforcement) it's removed. Thanks.

 

Okay, kylefitzy, I see that I stand corrected about the rub rail verbiage removal. And you're right, there is some contradictory information from the FMCSA, about the reason for the removal being manfacturer lack of standardization in design being applicable to all flatbed type trailers (the one in your picture being an example); the lack of consistent enforcement and interpretation.

The point you note about lack of rating of anchor points still has a weak argument point. In the section I cited:

(c) Vehicle structures and anchor points. Vehicle structures, floors, walls, decks, tiedown anchor points, headerboards, bulkheads, stakes, posts, and associated mounting pockets used to contain or secure articles of cargo must be strong enough to meet the performance criteria of § 393.102, with no damaged or weakened components, such as, but not limited to, cracks or cuts that will adversely affect their performance for cargo securement purposes, including reducing the working load limit.

The language quite clearly states that the anchor points must be strong enough to secure the load in accordance with § 393.102, so there is an implicit requirement for the tiedown points to be rated. I'm sure, even the trailer you show in the picture, considering the metal thickness, welding and tensile strength is the reason a manufacturer puts those D-rings and holes for anchor points there for you to secure to. I don't have your trailer documentation, but I'm pretty sure it would outline what they recommend or specifically don't recommend, what you can use as an anchor point.

The best thing from the discourse is that since early on when I requested from the company the ratings of the anchor points documentation, I've seen many trailer manufacturers including on the trailers, labels describing and showing the ratings of the various anchor points, which is a good thing for drivers to be confident that they are knowingly securing their loads with confidence of the actual WLL that they have from anchor point on the trailer through the chains and straps connecting to an opposing anchor point. This was information that previously was probably only available in the documentation that O/O may have, but company drivers wouldn't..thereby leaving company drivers at a loss to know their actual WLL rating.

 

And this contributes to the conversation or edification, how?

 

While I agree that anchor points and similar items need to be strong enough to secure the cargo without deforming, that does not mean they need to be rated. Raiting Main’s there needs to be a publish number by the manufacturer, backed up by testing under control the circumstances. If something is not explicitly stated in the regulations, you can’t receive a citation for it.
This trailer I’m pulling only has D rings in a few locations in a well, and none of them were in the right location for this load. Those are the only rated anchor points on this trailer. Everyone’s free to do as they see fit, but I have no problem using unrated anchor points as long as they are Structurally sound, including rubrails on aluminum trailers. I’ve never had an issue.

 

I would put empty pallets on top before throwing straps over it.Spreads the downward force more evenly.

 

Most of the flatbed trailers I have seen in the PNW have the non sliding winches on the outside of the trailer and they go over the rubrail with the straps.

 

All the years I pulled flatbed I pulled a Western. They don’t have rub rails and I never had any issues in MT or any other state.

 

Meanwhile, products just like that palletized seed get shipped in dry vans by the millions. Not one of then strapped down. I've seen countless loads of aluminum ingot shipped in dry vans with nothing but a flimsy load bar behind them. Yet flatbeds are required to secure as if it's the end of the world.

 

I’m guessing it has something to do with those hard aluminum sides on most dry vans. But what do I know?