OOSC, Part II, Item 2, Cargo Securement, p. Roll-on/Roll-off or Hook Lift Containers

Properly securing the rear of a roll-off container on a vehicle not equipped with an integral securement system.

Clarification different securement methods described in 393.134(b)(3)(i), 393.134(b)(3)(ii), and 393.134(b)(3)(iii). (Rear Securement of Roll-on/Roll-off Containers for vehicles not equipped with an integral securement system). The regulation, as printed, can be confusing and interpreted several different ways by carrier owners, drivers, and inspectors.

I have attached a photograph which depicts the method of securement most-commonly used in Alabama. (3) Secured to the rear of the vehicle with at least one of the following mechanisms: (i) One tiedown attached to both the vehicle chassis and the container chassis; (ii) Two tiedowns installed lengthwise, each securing one side of the container to one of the vehicle's side rails; or (iii) Two hooks, or an equivalent mechanism, securing both sides of the container to the vehicle chassis at least as effectively as the tiedowns in the two previous items. Is the method of securement, depicted in the photo, adequate per 393.134(b)(3)(i)? Does 393.134(b)(3)(i) require the strap to be wrapped around the chassis of the roll-off container? Does 393.134(b)(3)(i) require each side of the vehicle to be secured using this method or is one side sufficient?