393.118 (d) 3. of the FMCSR's Requiring Belly Straps on Loads over 2 Tiers High

On 5-28-16 we had a load of building products that loaded at a Home Depot distribution center in Bloomfield, CT on our trailer at the time of a New York roadside inspection. We were written a violation under section 393.118(d)(3) which requires belly straps on loads over 2 tiers high. The configuration of the load would not allow for belly straps based on the uneven bundles of different types of building products loaded on the trailer. When there are uneven bundles it is impossible to work belly straps under the bundles to effectively belly strap and comply with the regulation. We received the violation on the roadside inspection report that impacts our CSA score.

Due to how loads are configured and the constraints that Home Improvement chains face in shipping product orders to their stores, these loads cannot be evenly configured to allow effective belly strapping making compliance of 393.118(d)(3) virtually impossible. We need a review of these types of loads where the configuration of the loads such that belly strapping is not possible to be exempt from this section of the regulations and allow for the strapping over the top of the product that cannot be belly strapped.

As previously mentioned, we would like to request or petition a change in section 393.118(d)(3) of the Federal Motor Carrier Safety Regulations that there be relief to this regulation when product loaded at a Home Depot type Distribution Center. The reasoning behind this is that they load a grocery list of products on a trailer to 1 or more of their stores to meet their stores needs and not all of the product can be loaded in like size bundles based on weight and size which would allow the product to be belly strapped. In too many situations there are uneven bundles loaded side by side that prohibit feeding a belly strap between the bundles. In addition, even if you could weave a belly strap between these types of uneven bundles, the belly straps would not be effective. Because of the constraints of the load, we would like to see relief to this section of the regulation that would allow for a driver to strap over the top of product when belly strapping is not practical based on the configuration of the load. We have requested that Home Depot and Lowes, 2 home improvement chains that we haul for, also submit a request for the these reasons as well as the economic reasons for consolidation of products that go from a DC to a particular store to prevent extra transportation and the costs associated with additional loads and the subsequent push back of these costs to the consumer.