OOSC, Part II, Item 2. Cargo Securement, i. Metal Coils

The issue is the transportation and securement of metal coils and specifically, the current definition (or lack thereof) of \"GROUP\" in FMCSR 393.120.

This issue is deemed to be urgent! Our vehicles are being placed out-of-service by enforcement personnel because enforcement officers are deeming that any two coils or more which are in contact with each other and which have a combined weight equal to or greater than 5,000 pounds are considered a group and are therefore required to be placed in coil bunks (or other similar means of containment) and supported off of the trailer deck, as is required for single coils which have a weight equal to or greater than 5,000 pounds. Affecting this same definition is what constitutes or causes a group to occur. Officers have also deemed that cargo securement straps that wrap two coils together to improve securement as being a device which groups the coils together. This is affecting our performance and that of our customers. Service failures, increased loading and unloading times, inconsistent enforcement, are increasing.

I request that an immediate review of this issue be conducted with the participation of both government and industry participants to review current industry practices and determine what the actual definition of grouping should be. Should a cargo securement device in contact with or wrapping two coils cause the coils to now be considered a group, or does it require the addition of a separate metal band, strap or other device in contact with two or more coils to cause a group to be formed (such as slitter coils strapped together)? Are two or more coils simply in physical contact with each other a group? These questions need to be answered, but not before looking at what is presently employed, the industry's present performance and the impact that adding additional hardwood and coil bunks on every load will have on net load capacity and both carrier and shipper/receiver productivity (the economic impact).