Dispositivos de seguridad para remolques que no sean remolques completos

Cracked Hitch Systems discussion: The OOSC covers the cracking but is the CFR code correct because the violation referenced covers full trailers? This was discussed in the committee for cracking in the past on full trailers and it was put back onto the committee to come back with more data on ball hitches. Discussion about the CFR reference was that it is specific to full trailers and a trailer with a ball hitch is a considered a semi-trailer. General consensus that the 396.3(a)1 regulation should be added to the references in the cracks in 3.g. Potentially can affect other sections. Added into OOSC 3.c, 3.d, 3.e, g the violation of semi-trailer 396.3(a)1 into the references and added the word full in front of trailer. No vote was needed as this was concerning CFR references. This portion of the action item was closed.

Safety Chains discussion: This issue was discussed several years back. It was determined during this past discussion that states should be adding 392.2 violations if they have a state law relevant to semi-trailers, and this will ensure a tracking mechanism for safety data. FMCSA needs data before requiring safety chains on semi-trailers. Suggestion to have Crash Data Analysis committee gather crash data on semi-trailers with missing or damaged safety chains. Bryant Gay will take to crash data committee and ask. This portion of the action was closed and may be re-opened if Crash Data Analysis has relevant data on the topic.

Ball Hitch Rating discussion: The hitch from the action item is not rated for enough weight to tow the trailer. An Ad Hoc committee was formed in 2013 which researched the ratings of ball hitches and came up with the following: The enforcement officer simply cannot go off of the GVWR of the trailer compared to the rating of the coupling device because that is probably not what the trailer weighs. An empty or lightly loaded trailer would obviously be different than a trailer that was loaded to full capacity. The officer would be required to know the weight of the trailer and the amount of pull on that coupling system in order to determine if the combination was over its rating by the manufacturer. Enforcement officers do not have the knowledge or expertise in this area to be determining whether or not a particular system is an imminent hazard or not. The recommendation from the ad hoc committee was that it was not something that we wanted to address since it would open up many issues involved with the different components and that inspectors would lack to expertise to properly understand and enforce a regulation of this type. The weight rating of hitch components varies greatly from one to another. The coupling device spoke of in the issue request is only one of those components.

The ratings of hitches on towing units, balls, and coupling devices vary from one manufacturer to another and even based on size, whether the connection is a 1 7/8”, 2”, or 2 5/16”. For example, a 2” ball will have a rating of 4,000 lbs to 7500 lbs based on its construction and manufacturer. The system in the picture is showing a 2 5/16” ball and socket system. Most 2 5/16” balls are rated at 10,000 lbs, but can be less. This means the ball is still rated under the 12,500 lbs of the coupling device and well below the actual 14,000 lbs GVWR of the trailer which would mean that the ball is the weakest point, not the coupler.

During the vehicle committee meeting, industry representatives reaffirmed the ad hoc committee decision. Industry reps stated that the device in the picture is rare in that it actually states trailer weight. Coupling devices are usually just given a rating not an actual trailer weight. This rating would then be based on the amount of pull on the coupling system and not necessarily on the weight of the trailer. This would mean that even if the inspector knew the weight of the trailer, he/she would still not have the necessary information to determine if the coupling system was overloaded and a hazard because there is no way to know the actual amount of weight being pulled by the coupling system. Based on this information, the vehicle committee determined there would be no action taken. This portion of the action item was closed with no action taken.

Elongated Holes discussion: Are elongated holes to be considered loose mounting of a hitch system? Discussion that elongated hole doesn’t affect integrity of the hitch system. General consensus of the committee was that it would not be a defect because its not an imminent hazard. It was suggested to reach out to several manufacturers to find out if it is integral part of the system and becomes an imminent hazard if the holes for the attachment pin are elongated. Ron Jenkins will reach out to manufacturers and report back to committee to make an informed decision. This portion of the action item remained open.

Biloxi: Ron Jenkins talked with several trailer and hitch manufacturers and they agree that it is a problem but there is no guidance on when it would become an imminent hazard issue to become OOS. None of the manufacturers would produce anything in writing with a recommendation to place it OOS. With no recommendations from manufacturers, no action was taken and the item was closed.