OOSC, Part II, Item 2. Cargo Securement, h. Dressed Lumber or Similar Building Products

Carriers are having difficulty complying with the requirements for securing bundles of lumber that are three or more tiers high. 393.118 requires tiedowns to be placed over the middle tier of these loads. When the bundles placed beside each other have different heights, the strap becomes ineffective at securing the lower bundle and actually exerts upward pressure on the bundle above it. These straps can actually make the load less secure than leaving them off or not tightening them. However, officers are issuing violations for loads that don't have the straps or that leave the straps loose.

One carrier experienced 2 inspections where violations were recorded that put the carrier over the threshold for Cargo Securement on the CSA monthly reports. This reflects badly on the carrier in the eyes of their customer and jeopardizes their business.

Issue the following guidance for the purposes of determining when straps are required over the middle tier of bundles to comply with 393.118(d)(3)(iv)(b)(1) & (2). Tiedowns are required over bundles in the middle tier when: • Laterally adjacent bundles in a middle tier have a similar top height that allows a strap to be placed laterally across the bundles, and that strap can be tightened without causing any upward force to act on any bundle placed above the strap. Tiedowns are not required over bundles in the middle tier when: • Laterally adjacent bundles in a middle tier have different top heights and tightening any strap placed over the middle bundles would cause upward force to act on a bundle placed above the strap. • The top of the highest bundle is less than 72 inches from the top of the vehicle deck surface.