Operational Policy 15 - Regulatory Guidance 2.b (1) - Bungee Cord/Tarp Straps

Utah inspectors have interpreted the guidance in CVSA Operational Policy Fifteen as it relates to the use of bungee cords when used for securement to be a violation. The issues came up specifically as it relates to the bungee cord when used as primary securement and supplemental securement for chutes on ready mix trucks. We have also been advised by Utah inspectors the use of bungee cords to secure light weight items such as shovels, brooms, squirt bottles, and other light weight items carried on trucks is also a violation. Other states in the Rocky Mountain area have taken the position that mixer truck chutes, and other light weight items should be considered equipment and or dunnage and as such using bungee cords to secure them is not a violation. Due to the inconsistent interpretation of the guidance we request this be an action item for the vehicle committee at the CVSA September meeting in Boise ID.

The narrow interpretation Utah inspectors have taken will place almost every ready mix truck and numerous other trucks in violation and most of those violations will be considered an OOS violation, due to the fact it involves load securement. The chute securement on ready mix trucks is designed by the manufacturer and are delivered to the customer with the chute securement in place. To retro fit all mixer trucks with adjustable, load rated straps which may not even work would be extremely costly to the industry. While I certainly understand prevention, the fact is there is not a problem with chutes falling from mixer trucks using the current securement, which means the current securement devices in place must be working as designed.

Clarification of the guidance for the use of bungee cords to secure chutes on ready mix trucks and for equipment considered light weight and their use to secure dunnage.