CARGO & SECUREMENT

Robert Reed
Reed Transportation Service Inc.
Columbus, Ohio 2008
HISTORY
No motor vehicle shall be driven unless the driver thereof shall have satisfied himself that
the tailboard or tailgate, tarpaulins, chains (except ground or contact chains) ropes, stakes,
poles, and the like, or any part of the load, are securely fastened to prevent dangling,
flapping, swinging, or falling from side, end, or top of load. (Rule 10, 1.M.C.C 12/23/1936)
49 CFR Part 393 Subpart I Protection Against Shifting and Falling Cargo came into existence
August 31, 1973. (38 FR 23522)
Subpart I encompassed 393.100 through 393.106.
Part 393 encompasses Parts & Accessories Necessary for Safe Operation.
392.9 Safe Loading was enacted September 23, 1971. (36 FR 18363)
HISTORY Cont.
All cargo does not have to be wedged immovably in the vehicle. The intent of the rule was
not to impose that severe of a requirement. (37 FR 12641) June 27, 1972)
383.85 specified that cargo must be restrained by the sides, sideboards, or stakes and the
rear end-gate, endboard, or stakes of the vehicle, by tie-down devices, or by similar means of
protecting against shifting cargo. Carriers may chose any one of the three specified methods
of preventing shifting or falling cargo in transit.
Hows a cattle hauler tie-down his loads?
(36 FR 18862) 9/22/1971
NEW REGULATIONS
The modern uniform cargo regulations based upon the North American Standard for
Protection Against Shifting and Falling Cargo Model Regulations came into effect as a FMCSA
final rule September 27, 2002. (67 FR 61226)
The compliance date was January 1, 2004.
The FWHA issued advance notice of the proposed rule on October 17, 1996. (61 FR 54142)
The proposed rules were issued by FMCSA on December 18, 2000. (65 FR 79050)
The FMCSA final rules were amended on June 22, 2006 (71 FR 35819)
NEW REGULATIONS Cont.
Several cargo securement accidents in New York between 1990-1993 prompted a July 1993
House of Representatives hearing that led to the North American Load Security Research
Project.
This was the basis for the North American Cargo Securement Standard Model Regulations.
These rules are applicable to all commercial vehicles. See CMV definition @390.5. (10,001LB.
+ GVWR)
The regulations are principally performance based.
The rules are primarily the same for the United States, Canada, and Mexico.
PERFORMANCE CRITERIA
Neither motor carriers nor enforcement officials will be able to determine vehicle
performance capabilities.
The agency is adopting a single set of performance standards that would ensure that all loads
are properly secured, regardless of the stopping capability or maneuverability of the vehicle.
The focus of the rules is crash avoidance-type cargo securement rules, rather than
crashworthiness cargo securement standards.
67 FR 61215 Final Rule, FMCSA Response 9/27/2002
PERFORMANCE CRIETERIA
Longitudinal, lateral, and vertical accelerations that cargo must withstand in non-crash
conditions applied separately are as follows;
0.8g deceleration in the forward direction.
0.5g deceleration in the rearward direction.
0.5g acceleration in the lateral direction.
The values are based on analysis of previous studies of commercial vehicle performance.
Representatives of Government & Industry had a consensus on these limits that are similar
to those of Great Britain, Europe, Australia and New Zealand
VELOCITY - SPEED
Acceleration is the rate at which the speed or velocity of an object increases.
Deceleration is the rate at which speed or velocity decreases.
These terms are commonly reported as a proportion due to gravity (g).
Velocity of an object dropped from a high elevation increases approximately 32.2
feet/second.
Cargo that is immobilized or secured in accordance with the general rules or the commodity-
specific rules are considered to meet the performance criteria.
VALUES
The analysis of studies of CMV performance indicated that the highest deceleration likely for
an empty or lightly loaded vehicle with an antilock brake system, all brakes properly
adjusted, and warmed to provide optimal braking performance, is in the range of 0.8 -0.85g.
However, a typical loaded vehicle would not be expected to achieve a deceleration greater
than 0.6 g on a dry road.
The typical lateral acceleration while driving a curve or ramp at the posted advisory speed is
in the range of 0.05g - 0.17g.
VALUES Cont.
Loaded vehicles with a high center of gravity roll over at a lateral acceleration above 0.35g.
Lightly loaded, or heavily loaded vehicles with a lower center of gravity, may withstand
lateral acceleration forces greater than 0.50g.
0.5g in the rearward direction reflects from the vehicle backing slowly into the loading dock.
These forces take into account, braking, acceleration, climbing of hills, braking in reverse,
traveling over bumps or cresting a hill.
FORCES
0.8g Forward Force = 80% of Cargo weight when driving straight ahead.
0.5g Rearward Force = 50% of Cargo weight when accelerating, shifting gears while climbing
a hill, or braking in reverse.
0.5g Sideways Force = 50% of Cargo weight when turning, changing lanes, or braking while
turning.
0.2g Upward Force = 20% of Cargo weight when traveling over bumps in the road or cresting
a hill for vehicles that the cargo is not fully contained inside.
NACSS Fundamentals of Cargo Securement (page 7)
TRUCK OPERATION
0.8g Deceleration in the forward direction and the 0.5g accelerations in the lateral and
rearward directions represent the most extreme operating conditions short of a crash. (70 FR
33435) 6/8/2005
Normal driving = the maximum acceleration that a driver might expect from hard braking or
a turning maneuver (71 FR 35823) 6/22/2006
FMCSA has not eliminated the requirement that cargo securement systems and devices not
fail under the maximum performance capabilities of the vehicle. (71 FR 35824)
6/22/2006
The cargo must remain secured on or in the transporting vehicle under all conditions that
could reasonably be expected to occur in normal driving including emergency situations,
except a crash.
(NACSS Handbook page 3)

BRAKING
About 85% of all brake applications for heavy vehicles occur during normal driving, and result
in decelerations under 0.19g. A deceleration above 0.3g is quite a hard stop. Only about
0.11% of all brake applications exceed 0.4g.
NHTSA data on 216 vehicles (200 ABS truck tractors) accumulated over nearly 600,000 hours
(two years) and 18 million miles of tractor operation. In 13 million brake applications brake
pressures of 15 psi. or less (light braking) accounted for approximately 84% of the total
braking time recorded. 10% of the brake applications were between 15 & 20 psi. and almost
all the remaining brake applications were below 45 psi, (moderate to hard braking). Only
0.02% of the total braking time was at 75 psi. or greater.
No deceleration levels above 0.47g were measured in the more than 13 million brake
applications.
CRITERIA APPROPRIATE
For many years a 0.6g deceleration was the best that could be attained. However, todays
truck tires and brakes are more capable than ever before. In discussions with tire, brake and
vehicle manufacturers there was an agreement that the g forces defined in the proposal are
now achievable. While these forces will rarely reach the 0.8g forward, 0.5g rearward and
0.5g lateral values, they can be achieved and so should be expected under certain non-crash
conditions. Therefore we accept the new values.
American Trucking Associations (ATA) comment
(Federal Docket 97-2289-70 & 67 FR 61214 )
FMCSA - TERMS
Direct Tiedown - is one that is intended to provide direct resistance to potential shifting of an
article being transported. A direct tiedown may be attached to an article and to an anchor
point on the CMV, or it may be attached to an anchor point, go around or through an article,
then be attached to another anchor point.
Indirect Tiedown - is one that is intended to increase the pressure of an article or stack of
articles on the CMV. An indirect tiedown is attached to the vehicle, runs directly over or
through an article, then is attached to another anchor point on the other side of the article,
and is tightened.
Federal Register Vol. 65 No. 243 page 79055 & FMCSA Driver Cargo Securement Handbook
FMCSA - DEFINITION
Immobilized not an absolute does not mean that shifting of cargo is not permitted under
any circumstances, which the Agency acknowledges is impracticable under real-world
operating circumstances.
This also conflicts with 393.100 (c) which states that cargo must be contained, immobilized
or secured to prevent shifting upon or within the vehicle to such an extent that the
vehicles stability or maneuverability is adversely affected .
Language added to 393.102 (c) (1) and (2).
(71 FR 35822) 6/22/2006

CARGO SECUREMENT DEVICES & SYSTEMS
393.104 (a) General. - All devices and systems used to secure cargo to or within a vehicle
must be capable of meeting the requirements of 393.102 Minimum Performance Criteria.
393.104 (f) (3) Each tiedown must be attached and secured in a manner that prevents it from
becoming loose, unfastening, opening or releasing while the vehicle is in transit.
393.112 Tiedown must be able to be tightened by the driver while in-transit
Tiedown A combination of securing devices which forms an assembly that attaches articles
of cargo to, or restrains articles of cargo on, a vehicle or trailer, and is attached to anchor
point(s).
Anchor point Part of the structure, fitting or attachment on a vehicle or article of cargo to
which a tiedown is attached.
SECUREMENT DEVICES & SYSTEMS
393.104 (C) Vehicle structures and anchor points. Vehicle structures, floors, walls, decks,
tiedown anchor points, headerboards, stakes, posts, and associated mounting pockets used
to contain or secure articles of cargo must be strong enough to meet the performance
criteria of 393.102, with no damaged or weakened components, such as, but not limited to,
cracks or cuts that will adversely affect their performance for cargo securement purposes,
including reducing the working load limit.
Working load limit (WLL). The maximum load that may be applied to a component of a
cargo securement system during normal service, usually assigned by the manufacturer of the
component.
393.102 (b) does not establish manufacturing standards
FMCSA - DEFINITIONS
Accident The term accident does not include an occurrence involving only the loading or
unloading of cargo. (49 CFR 390.5 Definitions)
Article of Cargo A unit of cargo, other than a liquid, gas, or aggregate that lacks physical
structure (e.g., grain, gravel, etc.) including articles grouped together so that they can be
handled as a single unit or unitized by wrapping, strapping, banding or edge protection
device(s).
Blocking A structure, device or another substantial article placed against or around an
article of cargo to prevent horizontal movement of the article of cargo.
FMCSA DEFINITIONS Cont.
Sided vehicle. A vehicle whose cargo compartment is enclosed on all four sides by walls of
sufficient strength to contain articles of cargo, where the walls may include latched openings
for loading and unloading, and includes vans, dump bodies, and a sided intermodal container
carried by a vehicle.
Bracing. A structure, device or other substantial article placed against an article of cargo to
prevent it from tipping, that may also prevent it from shifting.
Shoring bar. A device placed transversely between the walls of a vehicle and cargo to
prevent cargo from tipping or shifting
*See 49 CFR 393.5 Definitions
VAN TRAILER
393.102 (c) (2) Transported in a sided vehicle does not mean the vehicle has to be completely
filled from top to bottom, side to side, and from end to end.
FMCSA agrees that there are many loads that can be transported in a van type vehicle, using
correct loading patterns, without any additional forms of securement. The agency never
intended that the cargo securement rules require tiedowns on all articles of cargo
transported in van type trailers, regardless of the type of cargo and loading arrangement.
The new regulatory language in 393.106 will ensure a performance-based approach to
securing articles of cargo in van-type trailers. (67 FR 61215) 9/27/2002
VAN TRAILER Cont.
393.100 (c) Prevention against shifting of load. Cargo must be contained, immobilized or
secured in accordance with this subpart to prevent shifting upon or within the vehicle to such
an extent that the vehicles stability or maneuverability is adversely affected.
393.102 (c) (2) Equivalent means of securement. Transported in a sided vehicle that has walls
of adequate strength, such that each article of cargo within the vehicle is in contact with, or
sufficiently close to a wall or other articles, so that it cannot shift or tip to the extent that the
vehicles stability or maneuverability is adversely affected; or
393.102 (c) (3) Secured in accordance with the applicable requirements of 393.104 through
393.136.
393.106 (b) General. Cargo must be firmly immobilized or secured on or within a vehicle by
structures of adequate strength, dunnage or dunnage bags, shoring bars, tiedowns or a
combination of these.
67 FR 61226 71 FR 35831
VAN TRAILER Cont.
FMCSA has determined that parts of the final cargo securement rule were ambiguous as
written. The proposed change to 393.102 (d) would clarify that van trailers carrying cargo
need not use tiedowns so long as cargo is loaded in such a way as to prevent cargo from
shifting and falling during transport. The rule as originally written could be read to imply that
all trailers with walls for restraining cargo (such as van type trailers) would have to use
tiedowns. FMCSA did not intend to impose the use of tiedowns on cargo loaded on trailers
with sidewalls that are of adequate strength, and which are loaded in such a way as to
prevent cargo from shifting or spilling during transport.
(Regulatory Analysis and Regulatory Flexibility Analysis, May 2005, page 3, FMCSA-05-21259-
1)
These statements are also repeated @ 70 FR 33432, June 8, 2005

MAJOR CHANGES -2006
393.110 (a) when tiedowns are used, instead of in addition to the requirements. (only applies
if tiedowns are used)
393.110 (c) if an individual article is, instead of if an individual article is required. (only applies
when other means of immobilization is being used)
393.106 (a) incorrectly referenced 393.122 through 393.142 when it should have made
reference to 393.116 through 393.136.
393.106 (d) will resolve any remaining confusion regarding the process for determining the
aggregate working load limit for a cargo securement system.
393.108 role of friction mats in cargo securement system.
393.104 (f) (4) original (2002) rescinded (attaching tiedown to rub rails not a violation) (new
(f) (4) was (f) (5) edge protection)
393.118 concerning lumber and building products, tiers bundles and tiedown of middle
bundles (on flatbed or platform trailers)
IMPRACTICABLE
Term used but not defined in the FMCSA regulations. (e.g. 392.9)
Thesaurus = not viable, unfeasible, unworkable, impossible, impractical
Antonym = viable
Definitions 1. not possible: that cannot be carried out
effectively. (Encarda World English Dictionary 1998-2004)
2. incapable of being put into service (Harper Collins Websters
Dictionary 2003)
3. not practicable; incapable of being put into practice with
the available means (Dictionary.com Unabridged 9/13/08
4. impossible in practice to do or carry out (Compact Oxford
English Dictionary 2008 @ askoxford.com
SPECIFIED METHODS HISTORY
The three specified methods of securement in the 1971 regulations were as listed.
(1) Sides, sideboards, or stakes, and a rear endgate, endboard, or stakes
(2) Tiedown assemblies or dunnage
(3) Other means of protecting against shifting cargo which are similar to, and at least as
effective as, those specified in subparagraph (1) or (2) of this paragraph. 393.85 (1) (2) (3)
(36 FR 18862-18863) 9/23/1971
49 CFR 392.9 Safe Loading was improved 9/23/1971 (36FR 18863)
SPECIFIED METHODS REVISION
49 CFR Part 393.85 was reserved and became Subpart I Protection Against Shifting or
Falling Cargo @ 49 CFR Parts 393. 100 through 393.106 (38 FR 23522) 8/31/1973
(1) Option A The vehicle must have sides, sideboards, or stakes, and a rear endgate,
endboard, or stakes.
(2) Option B Tiedown Assemblies
(3) Option C (for vehicles transporting metal articles only) must confirm to either the rules
of subparagraph (1) (2) or (4) or the special rules for transportation of metal articles in
paragraph (c) of this section.
(4) Option D The vehicle must have other means of protecting against shifting or falling
cargo.
Steel hauling option was added to rules as method of securement. (38 FR 23522)
8/31/1973
MODERN STANDARDS
393.100 (a) Applicability. The rules in this subpart are applicable to trucks, truck tractors,
semitrailers, full trailers, and pole trailers.
393.100 (b) Prevention against loss of load. Each commercial motor vehicle must, when
transporting cargo on public roads, be loaded and equipped, and the cargo secured, in
accordance with this subpart to prevent the cargo from leaking, spilling, blowing or falling
from the motor vehicle.
393.100 (c) Prevention against shifting of load. Cargo must be contained, immobilized or
secured in accordance with this subpart to prevent shifting upon or within the vehicle to such
an extent that the vehicles stability or maneuverability is adversely affected.
67 FR 61226 9/27/2002
CARGO SECUREMENT DEVICES OR SYSTEMS
393.102 (a) Tiedown assemblies (including chains, wire rope, steel strapping, synthetic
webbing, and cordage) and other attachment of fastening used to secure cargo:
393.102 (c) Equivalent means of securement. The means of securing articles of cargo are
considered to meet the performance requirements of this section if the cargo is;
(1) Immobilized, such so that it cannot shift or tip to the extent that the vehicles stability or
maneuverability is adversely affected: or
(2) Transported in a sided vehicle that has walls of adequate strength, such that each article
of cargo within the vehicle is in contact with, or sufficiently close to a wall or other articles,
so that it cannot shift or tip to the extent that the vehicles stability or maneuverability is
adversely affected: or
(71 FR 35832) 6/22/2006
MODERN CARGO SECUREMENT SYSTEMS Cont.
393.102 (c) (3) Secured in accordance with the applicable requirements of 393.104 through
393.136.
393.106 (a) The commodity-specific rules 393.116 through 393.136 take precedence over the
general requirements of this section when additional requirements are given for a
commodity listed in those sections.
FMCSA Response - We agree with the principle that it is important to ensure that shippers,
carriers and drivers use the proper tools and techniques to secure cargo. (67 FR 61216) 9-
27-2002
Regardless of whether the FMCSRs are applicable to shippers, they have a role in ensuring
highway safety when they load containers for transport on the highway, and seal the
containers, for whatever reason. (67 FR 61217) 9/27/2002
APPLICABILITY
The FMCSAs and RSPAs (hazmat) rules are complementary and motor carriers transporting
hazardous materials must ensure compliance with both agencies rules, whenever applicable.
The agencys cargo securement rules have historically been applicable to the full range of
cargo-carrying commercial vehicles subject to the FMCSRs since the safety regulations were
first issued more than 60 years ago. The rules are performance-based to the greatest extent
practicable resulting in requirements that increase with the size of the articles of cargo, or
the complexity of the load securement system necessary to ensure that the articles are
properly secured.
(67 FR 61214) 9/27/2002
FMCSA RESPONCES
We continue to believe that it is necessary for drivers to inspect cargo securement systems
because the amount of tension in the tiedown assemblies may decrease significantly after
the driver begins operating the vehicle. Vibrations may cause the articles of cargo to shift
slightly such that the tiedowns need to be readjusted to ensure that the articles do not fall
from the vehicle, or shift to the extent that the vehicles stability is adversely affected.
(67 FR 61217) 9/27/2002
We have always understood that there are articles of cargo that require special means of
loading onto commercial motor vehicles and recognized that the general cargo securement
rules may not be appropriate when applied to the securement systems used for these
articles. In many cases, if the general rules are applied to these loads, the articles of cargo
may be damaged during transport to the extent that they could no longer be used for their
intended purposes.
(67 FR 61218) 9/27/2002

OTHER ISSUES
Bills of Lading 49 USC Subtitle X Chapter 801
Section 80113. Liability for nonreceipt, misdescription, and improper loading. This section
discusses shippers weight, load, and count issues, said to contain, contents or condition
of contents of packages unknown issues.
Section 80113 also discusses liability for improper loading and availability of weighing the
freight, counting the freight and freight concealed by packages. (Pub. L. 103-272, Sec. 1 (e),
July 5, 1994)
49 CFR 371 Brokers of Property Records to be maintained for 3 years. (62 FR 15421)
4/1/1997
RELATED TERMS
Industrial or exterior packaging/load containment - Containers, drums, pails, cases, trays,
boxes, racks, cages, bins, closures, bags, shrinkwrap/stretchwrap, adhesives, tape & tubes.
Unitizing of cargo pallets, slipsheets, steel or plastic banding.
Sustainability/efficiency in manufacturing is the way in which a product, materials,
packaging and palletization methods impact space utilization, storage, transportation and
distribution costs through the lifecycle supply chain. (www.packworld.com/whitepaper-
24624)
Logistics the part of the supply chain processes that plans, implements, and controls the
efficient, effective flow and storage of goods, services, and related information from the
point of origin to point of consumption in order to meet customer requirements. (The
Management of Business Logistics 7
th
Edition) (2003)
LOGISTICS
Logistics interfaces with operations/manufacturing, production, finance, accounting &
marketing.
Logistics scope of activities = Transportation in-bound and out-bound, storage (inventory &
warehousing), industrial (exterior) packaging, material handling, inventory control & order
fulfillment.
Safe Delivery - An orders safe delivery is the ultimate goal of any logistics system.
Third-Party Logistics (3PL) = an external supplier that performs all or part of a companys
logistics functions.
(The Management of Business Logistics 7
th
Edition (2003)
COMMENT
Obligations & practices in loading, unloading, and transportation of cargo may depend upon
the conditions, events, circumstances, environment, facilities, instructions, type of freight,
type of equipment, contracts, agreements, Bill of Lading, company policies, shipper, receiver
or broker policies or a combination of the above.
See ASTM D-5728, D-4675, D-4649 & SOP for standards involved.
Shipping Container The shipping container (including any necessary blocking, bracing,
cushioning, or waterproofing) shall comply with the regulations of the carrier used and shall
provide safe delivery to the destination at the lowest tariff cost. (ASTM D-3951)
Unitization = Shipments should be considered for unitization where appropriate or specified.
Unitization encompasses, but is not limited to, bundling, consolidation in a container, or
placement on a pallet.
Shipping container & unitization terms are quoted from Standard Practice For Commercial
Packaging American Society for Testing and Materials (ASTM) D-3951
REFERENCES
DOT FMCSA Parts and Accessories Necessary for Safe Operation: Protection Against
Shifting and Falling Cargo. Final Rule 6/22/2006. Docket No. FMCSA-2006-
21259
DOT FMCSA Development of a North American Standard for Protection Against Shifting
and Falling Cargo. Final Rule 9-27-2002. Docket No. FMCSA-97-2289
DOT FMCSA Parts and Accessories Necessary for Safe Operation: Protection Against
Shifting and Falling Cargo. Notice of Proposed Rulemaking. Request for Comments 6/8/2005.
Docket No. FMCSA-2005-21259
DOT FMCSA Regulatory Analysis and Regulatory Flexibility Analysis May, 2005 FMCSA
05-21259-1
DOT FMCSA Development of a North American Standard for Protection Against Shifting
and Falling Cargo Proposed Rulemaking FMCSA Docket 97-2289 12/18/2000
FMCSA Enforcement Memorandum MC-PSV 12/31/2003
Title 49-Transportation - Docket No. MC-12: Notice No. 73-21
(38 FR Pages 23520-23524) 8/31/1973
Title 49-Transportation - Docket No. MC-12: Notice No. 72-7
(37 FR Pages 12640-12642) 6/27/1972
Title 49 Transportation Docket No. MC-12: Notice No. 71-28
(39 FR Pages 18862-18865) 9/23/1971
REFERENCES Cont.
www.fmcsa.dot.gov
www.regulations.gov
http://uscode.house.gov
www.gpoaccess.gov
www.askoxford.com
http://dictionary.reference.com
www.packagingdigest.com
www.packworld.com
www.astm.org
CVSA North American Standard Out of Service Criteria Handbook 4/1/2007
Ohio Commercial Driver License Handbook CDL Testing Model 11/07
Grocery Manufacturers of America/Kraft Video The principles of Damage Free Loading
2002
ATSM Standards - D-3951, D-4649, D-4675 & D-5728
Federal Register Microfilm Review/Study @ State of Ohio Library Columbus, Ohio
North American Cargo Securement Standard Driver Handbook 11/2003
MORE INFORMATION
This reference material is established upon extensive research, training, use and practical
experience of the Author. The regulations, laws, and standards of the industry along with a
multitude of facts, research, publications, comments, history, background, curriculum, and
news articles were used as resources. Due to ever-changing of regulations and standards this
information carries no guarantees to correctness or completeness. The intended use for this
reference material is for educational, training, and awareness purposes of the receiver or
user. Comments are welcomed.
Robert Reed
Reed Transportation Service Inc.
Columbus, Ohio 614-853-0340
www.trucrite.7p.com 2008 9-19-08