Operational Policy 15 - Guidance Regarding Tarp Straps and Bungee Cords

It's my understanding that the intent of Ops Policy 15 was not to prohibit bungee straps as the primary method of securement on tarps covering loads. If bungee straps are not prohibited as a primary means of securement for tarps covering loads, when does bungee strap violations become a CFR violation or OOS violation if the bungee straps are tied, unfastened, cut, rotten or broken and how many straps need to be defective?

Ops Policy 15 stats that bungee straps can't be used as a primary method of securement when securing articles of cargo and vehicle equipment. We need to revise Ops Policy 15 to exclude tarps that are covering loads to clarify the policy for roadside inspectors. Also, we need to identify what, if any, bungee strap violations that will create a CFR violation and/or OOS violation. I emailed pictures to Kerri of a single trailer load of lumber and the tarp was only secured with bungee straps with the majority of the straps tied, unfastened, cut, rotten and broken. When can we identify defective bungee straps as a violation, especially, when bungee straps are the only means of securement for a tarp covering a load?

Revise Ops Policy 15 to exclude bungee straps securing tarps that are covering loads clarifying the policy for roadside inspectors. Define when defective bungee straps securing a tarp covering a load becomes a violation.