OOSC, Part II, Item 7. Securement of Cargo, Tiedown Defect Table - Loose Synthetic Webbing

The CVSA North American Standard Out-of-Service Crtieria (OOSC), item 7. Tiedown Defect Table ? Synthetic Webbing ? 1st Bullet Point: \"Loose synthetic webbing.?3rd Bullet Point: \"The tiedown contains any fitting, tensioning device, or hardware which is broken, obviously sprung, bent, twisted, or contains visible cracks or significant nicks or gouges.\" 49 CFR 393.104(b): \"All Tiedowns, cargo securement systems, parts and components used to secure cargo must be in proper working order when used to perform that function 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.\" Different types of platform trailer freight, stacked high and loaded in the middle of the trailer, will have the synthetic straps tighten and secured as required. However, the distance between where the straps are touching at the top of the freight, with the straps pulled down and out to secure them to the anchor point on the frame, can cause the straps to flap, thus possibly causing the straps to tear and possibly causing damage to the cargo. To lessen this situation a half-turn is made on the straps. This method creates an air foil and equalizes air flow on all exposed surfaces of the strap, thus eliminating flapping and vibration at highway speeds.

OOS violations are being documented under the OOSC with the wording \"twisted strap\". These violations are on straps that are in good condition, are within Federal Standards, not loose, secured correctly, and there are no defects on the hardware. \"Hardware\" being the ratchet or buckle and the hook at the end of the synthetic webbing strap that is used to secure the hook to the anchor point on the trailer. Hardware is also the tensioning device on the trailer and includes the steel hook at the end of the synthetic webbing and any other hardware the strap is attached to for securing to an anchor point.

Please review the documentation wording in the OOSC on ?loose synthetic webbing?, and ?hardware which is twisted? for clarification that the synthetic webbing strap is not the hardware portion and the half-turn strap method used on these types is not due to loose webbing. A picture has been submitted via email to [email protected] for review with this request for action.