Clarification of the Cargo Securement Regulations

ABB Inc. is a major shipper of electrical transformers. Each transformer is enclosed in a steel box which measures approximately 3-1/2 x 3-1/2 x 3-1/2. The unit weighs approximately 800 pounds. Each transformer unit is secured to a wood pallet with (2) 3/8" diameter x 2" long lag screws. The transformers are loaded on a flatbed trailer, two wide, down the length of the trailer. Shipper rules prohibit any securement device contact with the steel box due to the possibility of marring the paint and subsequent rust. The carrier is securing these loads by routing two web straps over each set of two wood pallets (2" x 2" or 2" x 4" frame boards) with no securement devices over the actual transformer. Some units are secured with the same lag screws into a 4" x 4" wood runner which is then secured to the floor by the use of web straps.

Clarification of the cargo securement regulations related to this load configuration.

Determine if an 800 pound transformer secured by the use of (2) 3/8" diameter x 2" long lag screws into a wood base is in compliance with FMCSR parts 392.9 and 393.100-110. For small transformers, use 2x4s or 4x4s to secure the units to the trailers: Pictures were supplied to committee For large transformers use chains and or straps to secure as follows: Pictures were supplied to committee The tiedowns were not over the transformers but on a bracket that the transformers are attached to