OOSC, Parte II, Artículo 2. sujeción de carga - Correas de poliéster WLL

Currently, there is no assigned WLL in the FMCSRs that addresses polyester straps or strapping similar to that of steel strapping. The attached file from one manufacturer showed an approximate breaking strength of this type of strapping.

The request was for a uniform guidance on a WLL table regarding this banding. FMCSA indicated that the regulators discussed the fact that in the case of the coils, the straps are not securing the load to the vehicle, the pallets are in van trailers on friction mats and covered under general provisions. The straps are not required to have a WLL unless they are attaching the load to the vehicle.

Based on the information from the regulators at this meeting, this would not be acceptable as the primary means of securing cargo. The forum indicated that the load was not secured appropriately in this case and that written guidance needed to be developed to ensure consistency.

It was determined that some guidance should be drafted for implementation into Operational Policy 15 as this question has come up at least twice and if they enforcement community continues to ask the question about the same type of securement mechanism, guidance is likely necessary to prevent the question from coming up again and again.

One of the attendees indicated that the supplier of these straps stated that these straps are not designed as tiedowns at all and are only designed to unitize loads. They are really intended to be slightly stronger than a tie-wrap. They are used mainly in the rail industry. The potential of this strapping being used more and more on the road will be happening as the industry is being aggressive with the road transportation industry.

It was brought up that the issue is really two-fold. There are loads that are in van trailers that are secured within the van trailer and the structure of the trailers is a means of securement. There are other loads, such as the transformers that are on flat deck trailers that have no other means of securement other than the strapping from the transformer to the skid. This is used at the shipper, the banding is used to secure the load to the pallet, but no one has seen the straps used to secure a load to a trailer at this point. The supplier is looking to replace metal strapping as a unitization product. The strapping does not meet the requirements of a tiedown as it is not adjustable, and it is not steel strapping.

There were pictures brought up of a truck chassis that is transported with the tires and wheels loaded on the frame using steel strapping. The regulation was referred to and it is indicated in both the NSC Standard 10 and in 393.112 that all tiedowns other than steel strapping, must be adjustable, therefore, if the steel strapping is used as a tiedown, it is acceptable, but no other banding material can be used. The steel strapping is in regulation as a tiedown, so it is an acceptable tiedown and can be used as such. It was determined that because the steel strapping can be used as a tiedown and a polyester strap cannot, that this may be causing confusion at the roadside. It was also suggested that steel strapping has been used for many years for the securement of cargo on rails and vessels, so it has to be applicable to roadway or all loads would have to be secured in a different manner after removing the rail. Steel strapping has its own section 13(1) and (2) in the NSC regarding the fact that it can be used as a means of securement and how to use it when securing loads to the trailer. The US regulation has a default chart for steel strapping.

It was suggested that a notation could be added to the guidance that is already in Operational Policy 15 in 2.b.(5) regarding shrink wrap and stretch film for the purposes of unitization.

The forum agreed that the following language should be presented to the Vehicle Committee for implementation into Operational Policy 15.

b.(5) Is stretch film and/or shrink-wrap or banding material an acceptable means of unitizing cargo?

ANSWER: Yes, as long as all of the individual articles in the unit of cargo remain secured inside the surface of the material.

Banding material (other than steel strapping) is not considered a securement device and is not sufficient as a primary means of securement.