OOSC, Part II, Item 2. Cargo Securement, o. Flattened or Crushed Vehicles

Recently one of our officer in Quebec (Canada) performed a safety check on a carrier who was carrying some crushed cars that have been compressed not only to reduce their height but also their width and length. As shown on the pictures, the crushed cars were loaded on a flat-bed in five separate piles (row of 2) and secured with 15 chains, 3 for each piles (row of 2) . The chains used were 5/16in, grade 70 with a WLL of 4700lbs . The chains were tight using a synthetic webbing connected to the chains as permitted per section 91(2) of NSC 10. The synthetic web tiedown had a working load limit (WLL) of only 4695 lbs. So both the chain and the synthetic webbing had WLLs less than the minimum required of 5000 lbs as per section 92(2). There was also a « cargo net » installed on the top of the load to make sure that no loose parts fall off from the flat-bed. Question : Since the cars are crushed in 3 dimensions (height, length and width), should this kind of cargo be considered as general cargo and secured following Part I – General provisions of the NSC 10 or under division 7 (sections 91, 92 and 93) vehicles as a cargo ? To answer this question, it should be necessary to look at the CVSA forum minutes held at Montreal, Qc Canada (February 17, 2012): 22. Ad Hoc Task Force – Crushed Car Definition : Based on the approval of the definition by the Regulators Group, and some further discussion, the Forum approved the wording proposed by the adhoc task force to define a crushed car relative to FMCSR 393.132 & NSC 10, Division 7, Section 90-92. It was further noted that this definition is intended to distinguish a ‘crushed’ car from a vehicle that is ‘rolled’, ‘baled’ or ‘logged’, one that is at its original height and one that is damaged in a collision. The approved definition is: “Crushed Car is defined as: Vehicle that has been subjected to mechanical compression that reduces the vehicle’s height as part of a recycling process without significantly reducing the vehicle’s length or width.” If this kind of cargo should be considered as general cargo, these requirements do not need to be met : - Minimum WLL of 5000 lbs for tiedowns (no minimum for general cargo as long as the aggregate WLL is met) - No use of synthetic webbing, as long as there are corner protections when necessary (not legal under division 7 except if the webbing is no more than 15 cm above the deck of the vehicle) - Minimum of 4 tiedowns for each piles on a flat-bed (depending of the length of crashed cars, it is possible to install 2 or 3 tiedowns for general cargo) - No need to comply with subsection 93(2): the equipment used to contain loose parts shall be structural walls, floors, sides or sideboards or suitable covering material, alone or in combination (for general cargo, this requirement should be met with section 9 of NSC 10 “Cargo shall be firmly immobilized or secured on or within a vehicle by structures of adequate strength, blocking, bracing, dunnage or dunnage bags, shoring bars, tiedowns or a combination of these.”)

We think that this is a security issue because more carriers are using this way to carry "crushed cars" and we think that it would be appreciated to get an answer to this question as soon as possible. We are working on this file with the Ministry of transport.

We would like an answer to this question: Question : Since the cars are crushed in 3 dimensions (height, length and width), should this kind of cargo be considered as general cargo and secured following Part I – General provisions of the NSC 10 or under Division 7 (sections 91, 92 and 93) vehicles as a cargo ?