Operational Policy 15 - Guidance for Securing Round Hay Bales

There is a wide variety of opinion on how round hay/feed bales should be secured to the trailer. Some carriers strap every stack down. Some strap 1st and last stack. Some have retractable racks on the side of the trailer that support the bales and angle them in toward center. Since there are no commodity specific rules on round bales, many well meaning carriers try to interpret 393.100-106 and are unsure of how to secure bales, or only take one piece of the regulation as an entire securement system. FMCSA has published a memo on the securement of square bales, but did not include round bales.

Round bales are the most common form of hay bales. While some of the transportation is done at a local level, there is a large amount of hay being transported in interstate commerce. Round bales can be loaded in a number of different ways and stacks, and being round, create unique challenges for industry and enforcement. Due to the unique shape and loading options, the current regulations can be unclear to industry and enforcement. Unsecured bales are undoubtedly a safety issue if they come off of the trailer and onto the roadway. Depending on several factors, a bale can weigh 700-1500 lbs. and roll down a roadway at traffic nearly at highway speed, not to mention sitting stationary in the lane of travel.

Clear commodity specific instruction for securing round hay bales should be available to both enforcement and industry. I would petition CVSA to include securement of round hay bales in Operational Policy 15, or petition FMCSA to create commodity specific cargo securement regulations for transportation of round bales, or an interpretation question under 393.100 that addresses securement of round bales.