Inconsistent Interpretation and Application on the Securement of Scrap Metal Loads

Regulations concerning safe securement of scrap metal loads, including crushed cars, is inconsistent and too open to interpretation by shippers, carriers, and enforcement personnel. The result is inconsistent securement standards, inconsistent enforcement standards, and increased potential for unsafe loads.

As a retired Commercial Vehicle Safety Specialist with the Idaho State Police, and as a currently employed Safety Compliance Manager for a relatively large commercial carrier which uses flatbed trailers almost exclusively, I feel this is a very important issue which needs immediate attention. Scrap metal loads are inherently dangerous loads. The regulations themselves need to be very clear without having to rely so much on various personal and/or official interpretations.

Compliance and enforcement would be much easier and effective if the regulations for securing scrap metal, including crushed cars, was uniform with no distinction as to type scrap metal. Securement by chains or cables should be required on all scrap metal loads, as well as the load being covered by netting, no matter the source or compressed shape of the scrap metal. Synthetic straps should be prohibited on all scrap metal loads, not just on crushed cars as currently stated in the regulations. Flattened cars should require four tiedowns, as currently stated in the regulations. Bales or cubed scrap metal should be secured with the number of tiedowns as currently required.