Securement of Equipment with Hydraulic Shovels or Accessory Attachments that the Manufacturer Deems Adequate

Clarification is needed regarding securement of equipment with hydraulic shovels or accessory attachments that the manufacturer deems adequate as a tie down. We recently had an isolated incident in which an officer deemed these tie downs as inadequate and issued a citation based on the fact that although the strength and number of tie downs was well over legal requirements, there was not a total of four attached to the inner frame. In this particular instance, there were no frame anchor points as they were obviously redundant to the manufacturer.

Fixed hydraulic shovels are in fact stronger than most frame mounts and track attachments and should be allowed as a valid anchor point that functions as both to restrain the machine from movement and hold the shovel or blade down. The citation was overturned but without clarification and therefore, I would appreciate help in the matter. Attached are pictures of the manufacturers tie down points in question.

Issue No. 10-034-VEH addresses this partially but I would like a better understanding of whether a manufacturer recommended tie down to a hydraulic attachment is adequate or must we attempt to find a less adequate tie down spot in addition to the manufacturers suggestion.