OOSC, Part II, Item 2. Cargo Securement, i. - Stacks of Slitter Coils with Eyes Vertical on Pallets

Cargo Securement Issue: Officers at the Michigan/Ontario border point stopped a van trailer loaded with stacks of slitter coils with eyes vertical on pallets. (see attached pictures). The van trailer was equipped with anchor points and the stacked slitter coils were secured with chains forming an "X" pattern overtop. The coils within each stack were not banded together. Each stack weighed less than 2268 kg or 5000 lbs. Question: What is a group of coils? Division 3, Part 2 of NSC Standard 10 is applicable to metal coils that are "individually or grouped together have a total weight of 2,268 kg (5,000 lbs)". What does grouped together mean? Does this mean grouped together and secured by a securement system that is common to the group of coils or the total gross quantity of the load, or is it when the coils are touching each other inside the trailer? It would appear that section 49 does not contemplate slitter coils transported in stacks as pictured as it requires each slitter coil to be individually secured. Question: Could this load be secured to the general provisions under Part 1 of NSC Standard 10 or must it meet the requirements of the metal coil specific commodity?

Request Clarification or interpretation on what is considered a group of coils.

I am seeking an interpretation of "grouped together" and how should similar loads of "stacked slitter coils" be secured inside van trailers. Would it make a difference to the securement method if the stack of slitter coils was greater or less than 5000 lbs?