OOSC, Parte II, Punto 2. sujeción de carga, e. (3) - Posiciones de amarre

This issue request asked for guidance as to which section of the regulations utility poles would fall under, general securement regulations or commodity specific regulations. A picture was submitted along with the issue request showing a trailer with angled bunks at each end. The adjustable length trailer had three utility poles on it, secured with six securement devices. The poles were not touching the bunks at each end of the trailer so OOS violations had been recorded for failing to meet the requirements of the commodity specific regulations. The issue request was sent to Cargo Securement Committee for guidance. The trailer was determined to meet the definition of a pole trailer and utility poles meet the definition of a log. In the case of the picture presented, the driver had the option to use either general securement or commodity specific but could only be held to general cargo securement regulations. Commodity Specific regulations allow general securement rules to be used when no more than four processed logs are transported. If more than four processed logs are transported on a pole trailer, the commodity specific regulations would then be the only applicable means of securement. Discussion then took place on whether or not there were a sufficient number of securement devices on the load. It was determined that weight securement requirements would most likely be met with the securement devices shown. There were two securement devices in the first ten feet with four additional devices, so length requirements also appear to have been met. Committee members were reminded that the regulations do not require the specific location of securement devices when meeting length requirements, only that the required number based on length are on the load.