Use of prohibited towing methods and non-approved coupling devices creates a situation which poses an imminent hazard to the motoring public.

393.71 of the FMCSR outlines the appropriate means by which a motor vehicle or trailers may be towed in a driveaway-towaway operation. Specifically, 383.71 (g) states "No motor vehicles or combination of motor vehicles shall be towed in driveaway-towaway operations by means other than a tow-bar, ball-and-socket type coupling device, saddle-mount connections which meet the requirements of this section, or in the case of a semi-trailer equipped with an upper coupler assembly, a fifth-wheel meeting the requirements of § 393.70."

Attached are photos from a stop conducted by Officers of the Georgia Department of Public Safety. This commercial wrecker was utilizing an underlift arm with two chains attached to the bottom side of a loaded semi-trailer containing 40,000 lbs of freight. The underlift arm was not directly supporting the semi-trailer in any capacity. The semi-trailer was essentially being towed by means of attached chains with the two 1/2 inch chains supporting the weight of the load and being responsible for proper tracking as the vehicle combination negotiated hills and curves. Chains are not an approved coupling device for towing a motor vehicle or semi-trailer as specifically outlined in 393.71 (g). This vehicle traveled approximately 4 miles through a High Crash Corridor on Interstate 85 and then proceeded approximately 5 miles down a 4 lane state route through a heavily populated metro area before being stopped by our Officers. A simple disconnect of this unauthorized means of towing at any time could have resulted in a tragic event, however there is nothing currently found in the OOSC that we could directly apply to this scenario. Further noted, this incident was not an emergency tow or a necessary tow to get a highway back open as the result of a crash.

Part 2 of the OOSC policy statement states that an "Imminent Hazard" means the existence of any condition of a vehicle or cargo that substantially increases the likelihood of serious injury if not discontinued immediately, I ask that CVSA consider drafting and adopting language into the OOSC that would address the specific issue of utilizing non-approved coupling devices or non-approved methods to tow motor vehicles and trailers.