OOSC, Part II, Item 7. Securement of Cargo, p. Roll-on/Roll-off or Hook Lift Containers

Roll on/off box with an integral securement system securing the front and rear sides was stopped for an inspection. One of our officers noted a violation of 393.104B-Defective Tie-Down assembly for some broken wires in the wire rope of the winch that pulls the box up and down onto the roll on/off chassis. Data Q came down from company and wanted clarification as to whether this was considered a tie-down or not because of the integral securement devices that secure the box to the chassis.

Seems to be some confusion or misunderstanding between whether this adds a secondary type of securement should the integral system fail. Clarification would be helpful to get this resolved so the company can have an answer.

Clarification as to whether this winching device should even be considered in the inspection of a roll on/off type container that is equipped with a working and functioning intergral securment system that secures the box to the chassis. These are the quesations I would like clarification on: Is an integral locking device an equipment situated at both ends of a container and designed to prevent movement in any direction? Should an integral locking device that does not fasten the back end of the container be considered an integral locking device? When situation # 2 happens, should a tie down described in section 393.134 (b) (3) be used? When an integral locking device in good working order is used, should the wire lifting device be included in the inspection? When the wire lifting device is used as the primary securement system, do we use the Tie down defect table for wire rope in the OO’S to determine if that wire is suitable or not for that use?