Flat Bed Rules?

redytrk

Veteran Expediter
Charter Member
Wasn't there a rule that straps must be inside the rub rail?
 

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greg334

Veteran Expediter
I see that all the time.

Speaking of flatbeds, I noticed UPS freight has a few here in the south running.
 

Streakn1

Veteran Expediter
Wasn't there a rule that straps must be inside the rub rail?

As an open deck hauler myself, I find nothing in the U.S. cargo securement rules (49 CFR S392.9 & Part 393) that specifically forbids this practice of securing straps to a deck. The Canadian rule (NSC Standard 10) does state as follows:

"In Canada, securement devices MUST be routed inboard of the rub rails whenever "practical". Rub rails can be used as anchor points if the tiedown is fitted with a flat hook end and it is not possible to attach the hook to another more suitable anchor point".

As a practice in the US, we never attach our chains or straps directly to the rub rail, nor do we route our securement devices outboard of the rub rail. We do on very rare occassion route our 2" flat hooked straps outboard of the rub rail when attaching the hook directly to the rub rail and our 4" straps when carrying an over width load that causes us not to be able to route the strap inboard of the rail. Our rails meet specified requirements as a securement point, and although some states frown on this practice, to date we've not been ticketed or told to reroute them by DOT.

Personally, we believe that the straps are more vulnerable when routed outboard of the rail, especially in the event of an accident. Since we do not go into Canada their rule does not apply to us.
 
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greg334

Veteran Expediter
Streak,
You do know that the strap manufactures do recommend a strap change out every two years?
 

Refer Hauler

Expert Expediter
Found this @ JJ Keller

"Noting that tiedown failure caused by trailers rubbing against fixed objects is “extremely rare,” the FMCSA decided in 2005 that removing the rub-rail rule would not detract from highway safety and would make enforcement more consistent. Despite objections from Canadian officials, the FMCSA issued a final rule on June 22, 2006, rescinding the prohibition on routing tiedowns outside the rub rails. "
 

FREE TO FAIL

Seasoned Expediter
My understanding of the rule is that the rub rails are not considered load bearing unless the manufacturer of the trailer specifically states they are. so the fact that you have a rated strap tied to a non load bearing part of the trailer negates the the capacity value of the strap.
 

Streakn1

Veteran Expediter
Streak,
You do know that the strap manufactures do recommend a strap change out every two years?

Who would want to risk using a strap that long before replacing it? Certainly not us!

Straps are cheap $15-30 each. 20- 2" and 20- 4" straps replace once a year (or as need), much less expensive than replacing freight or worse.

We believe one must spend monry to make money, including replacing equipment before its performance ability becomes questionable.
 

Streakn1

Veteran Expediter
Found this @ JJ Keller

"Noting that tiedown failure caused by trailers rubbing against fixed objects is “extremely rare,” the FMCSA decided in 2005 that removing the rub-rail rule would not detract from highway safety and would make enforcement more consistent. Despite objections from Canadian officials, the FMCSA issued a final rule on June 22, 2006, rescinding the prohibition on routing tiedowns outside the rub rails. "

That is true. But when have we (commercial vehicles) seen consistent enforcement from state to state or even county to county when it comes to enforcing federal rules concerning the operation and safety regarding commercial vehicles?
 

nightcreacher

Veteran Expediter
Putting a tie down strap on the outside of the rub rail, doesn't give as secure a hold as putting it under,and although you may never rub the side of the trailer, and cut a strap,you never know when it cold happen.I don't know anyone that will not change their tie down straps at least every other year,unless they just aren't used that much,as in most of the flat bed teams at FDCC.
 

Brisco

Expert Expediter
That is true. But when have we (commercial vehicles) seen consistent enforcement from state to state or even county to county when it comes to enforcing federal rules concerning the operation and safety regarding commercial vehicles?

Very very very true statement.

Using tie-down straps on flatbeds is a whole other game over most of these guys that are using tie-down straps in a "Box" truck as probably 99% of these guys here on this board are. (CV's too)

Strapping outside the rubrail is case by case issue. All depends on what is you are strapping down, the weight of what you are strapping, and the size of what you are strapping. In the picture above, a load of rebar, strapping outside the rubrails is sufficient. That rebar also has other measures in play to keep that load secure. Notice the metal bands holding the rebar in place? Also, notice the 2X4's all throughout that load? Those metal bands are probably secured to those 2X4's in some fashion, and those 2X4's are probably secured to that flatbed also. So that is a safe load in DOT's eyes.

Now if you had a load of oil field piping, solid or hollow, that is difficult to secure to keep them from rolling around, then under the rubrail is highly suggested. Why? It all depends on where you have to place your straps if you went outside the rubrail. Those rubrails are flexible, especially midway between the 2 beams where they're attached to the trailer itself. Let's say you're strapping a load of pipe and the next strap point is right dab in the middle of the beams/frame attachments. You may get that strap tight as hell right there sitting in the lot with the trailer parked, but once you hit the road and that trailer flexes making a turn or bouces off a pothole, then that strap point may loosen up because that rubrail flexes too. Hauling oil field piping, all it takes is one strap to loosen up which will eventually loosen other straps.

Same scenario when trying to strap down vehicles putting straps outside the rubrails. Vehicles bounce and move all the time lossening straps and chains as you go down the road. That's why guys who've been on the road with flatbeds for a while get to know what can be strapped "outside" the rubrails and what cannot be.
 

redytrk

Veteran Expediter
Charter Member
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.
 

MYGIA

Expert Expediter
Owner/Operator
Who would want to risk using a strap that long before replacing it? Certainly not us!

Straps are cheap $15-30 each. 20- 2" and 20- 4" straps replace once a year (or as need), much less expensive than replacing freight or worse.

We believe one must spend monry to make money, including replacing equipment before its performance ability becomes questionable.

I run a dry box, not a flat bed, but was curious about your comments regarding the annual or semi-annual replacement of your straps. I “assume” this is because they are exposed to all types of weather – which reduces their useful and safe life expectancy. Do you know if this same policy is recommended for straps used only inside a dry box?
 

Brisco

Expert Expediter
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. :cool:
 
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