OOSC, Part II, Item 2. Cargo Securement, Tiedown Defect Table - Cordage (Fiber Rope)

We have had questions from inspectors, as well as debate/discussion with drivers/companies regarding the ability to secure cargo with cordage/rope. The major issue relates to knots, including a slip knot type attachments and whether using this type of attachment would meet the requirements under 393.112, and be considered "adjustable". The second issue relates to a tie-down being defective if it contains knots. For example, knots are specifically noted in chains and synthetic webbing, but appear to be allowed for rope due to the following defect description in the OOS Criteria: "Ineffective knots formed for the purpose of connecting or repairing binders." This also ties in to the previous issue of whether a slip knot would qualify as adjustable. This could be interpreted that in order to use rope as an authorized tie-down, a binder or similar device must be used to meet the adjustable criteria?

Clarification is needed to ensure uniform enforcement by inspectors.

I request that this item be discussed to determine the appropriate uses and guidelines for use of cordage/rope for securement of cargo on/within a CMV. I have attached a few photos for reference of the issue(s). Thank You!