OOSC, Part II, Item 2. Cargo Securement - Lugger Boxes

Enforcement has been placing carriers in many regions out of service for load securement. Some luggers have hydraulically activated tipping/dumping pins on their frames. Some commercial vehicle enforcement units accept using the tipping/dumping pins. For those who do not have approval to use the pins or do not have pins on their vehicles the ANSI Z245-1 committee assigned a subgroup to come up with a container securement solution. The subgroup was comprised of at least three lugger manufacturers, container manufactures, and many other individuals representing Safety & compliance, and Operations from Lugger owners/users. A draft document was presented at the last meeting of ANSI Z245-1 Mobile equipment committee on February 18th, 2019. The Z245.1 sub-committee finalized the document for a final vote of acceptance and acceptance of the Federal Motor Carrier Safety Administration and the Commercial Vehicle Safety Alliance.

There is inconsistent enforcement and understanding of what constitutes proper securement for a lugger truck.

The National Waste and Recycling Association and Institute of Scrap Recycling Industries, Inc ask the Commercial Vehicle Safety Alliance and FMCSA to review the attached securement method as a mitigation solution for proper securement.