Entry DateJanuary 13, 2023
Issue Number23-001-VEH
NameBrad Gibson
AgencyTexas Department of Public Safety
Address6200 Guadalupe St.
Bldg. P
Austin, Texas 78752
United States
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Phone(512) 486-6481
EmailEmail hidden; Javascript is required.
Issue NameOOSC, Part II, Item. 2, a. General Securement - Tarp Sided Trailers
Summary of Issue

Discussion was held at a recent Part B instructor recertification course regarding cargo securement on cargo enclosed in a tarp sided trailer. Disagreement ensued. Some stated that the cargo inside an enclosed tarp sided trailer would require cargo securement (tiedowns), just as a cargo must be secured on a flatbed trailer (393.106 and 393.110), and others quoted CVSA previously stating that the tarp sided trailer would meet 393.102(c)(1) and/or 393.102(c)(2) until the vehicle's stability or maneuverability had actually been adversely affected.

Justification or Need

Disagreement among the nation's Part B instructors needs to be resolved by CVSA.

Request for Action

Clarification on the cargo securement requirements, if any, for cargo enclosed in a tarp sided trailer.

Action Taken by Committee

The Cargo Securement Harmonization Public Forum discussed this at length, had brought a guidance to Vehicle Committee at the last meeting that was rejected by the board. Presentations were made to the Forum after that in the Ottawa meeting regarding tarp sided trailers. Ultimately, it was determined that a tarp sided trailer does not provide cargo securement and tiedowns or other means must be used to secure the cargo. It was suggested that if industry has some sort of trailer that uses a tarping system as part of its securement system that those engineering documents be submitted to Canada/US or both to have them reviewed and put on the CVSA website in the Equivalent Means of Securement webpage Equivalent Means of Securement so that inspectors/industry are aware that those systems are acceptable (examples that were shown in previous meetings were fiberglass /sod /wood shaving and poultry trailers. An amendment to Operational Policy 15 was developed and presented to the Vehicle Committee. The following wording was approved.

Cargo Securement
2.b.(15) Does a properly closed curtain-sided trailer satisfy the cargo securement requirements under general provisions or do the articles of cargo require tiedowns for length, weight or commodity-specific requirements?

A curtain-sided trailer does not provide securement and the cargo needs to be secured as per 393.100 through 393.136 or NSC Standard 10.

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