From FMSA Rules September 27, 2002
Proper Use of Tiedowns
The new regulations require each tiedown to be attached and secured in a manner that prevents it from becoming loose, unfastening, opening or releasing while the vehicle is in transit. All tiedowns and other components of a cargo securement system used to secure loads on a trailer equipped with rub rails must be located inboard of the rub rails whenever practicable. Also, edge protection must be used whenever a tiedown would be subject to abrasion or cutting at the point where it touches an article of cargo. The edge protection must resist abrasion, cutting and crushing.
Time for a lesson in "Real Trucking". (not the little box type truck you seem to be in)
Final Rule
Federal Register:
June 22, 2006 (Volume 71, Number 120)]
[Rules and Regulations]
[Page 35819-35834]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr22jn06-20]
[[Page 35819]]
DEPARTMENT OF TRANSPORTATION
Federal Motor Carrier Safety Administration
49 CFR Part 393
[Docket No. FMCSA-2006-21259]
RIN 2126-AA88
Parts and Accessories Necessary for Safe Operation: Protection Against Shifting and Falling Cargo
AGENCY: Federal Motor Carrier Safety Administration (FMCSA), DOT.
ACTION: Final rule.
Final Rule - Federal Motor Carrier Safety Administration
SUMMARY: FMCSA amends its September 27, 2002, final rule concerning protection against shifting and falling cargo for commercial motor vehicles (CMVs) operated in interstate commerce in response to petitions for rulemaking ...................
DOE agreed that the FMCSA proposal to rescind Sec. 393.104(f)(4) would not have an adverse impact on safety, but DOE noted that the inference that it is acceptable to attach tiedowns to rub rails appears to be in conflict with requirements for anchor point and the "North American Cargo Securement Standard Model Regulation."
Kinedyne also recommended retaining the existing Sec. 393.104(f)(4). However, Kinedyne recommended that if this section is eliminated, then the rub rail should be re-identified as a "securement rail" and needs to have an established WLL rating by the trailer manufacturer per Sec. 393.108
FMCSA appreciates the comments provided by EMC, and agrees that vehicle manufacturers can incorporate features that assist the vehicle operators in complying with the cargo securement regulations. The Agency believes that in many instances, the nature of the cargo dictates the ability of the cargo securement devices to meet the existing requirements of Sec. 393.104(f)(4). As discussed in the NPRM, however, State enforcement personnel and motor carriers expressed difficulties in achieving uniform and consistent enforcement of the regulation. Therefore, the Agency rescinds Sec. 393.104(f)(4) as proposed.
That is why today, there is no mention in FMSCA guidelines
Part 393.104 that states whether tie down straps should be inside the rub rails or outside the rub rails. The ruling made back in 2002 was rescinded and Part 393.104 was re-written June 22, 2006 and the "
with rub rails must be located inboard of the rub rails whenever practicable" wording/rule was removed.
Part 393.104: What standards must cargo securement devices and systems meet in order to satisfy the requirements of this subpart? - Federal Motor Carrier Safety Administration
Take your time, read the whole ruling, study up on it, and if you ever want to give "Real Trucking" a try, give me a call. I'll help you any way I can, OK.