OOSC, Part II, Item 2. Cargo Securement, e. Tiedowns for Length - No Front End Structure

In 393.110(b)(3) many of the roadside inspectors are reading that there needs be 2 securement devices within the first 10 feet of the load. They continually insert the word WITHIN. If you look at the law as it is written, no where in it does it state where the tie downs need to be placed. It is only referring to how many tie downs are needed for the length of the article of cargo.

If you refer to the OOS criteria it explains (under the notes on page 31 and continued on 32) where the best placement of the cargo securement devices could be placed and it gives 3 separate scenarios. However it fails to give guidance to loads that are unable to to be contained within the confines of a flatbed trailer. Such as if the load extends beyond the front or the rear of the trailer. Common sense would indicate that you secure the length of the load within the length of the trailer, evenly spacing out the securement devices to get overall securement of the article of cargo.

I would like guidance given in 393.110 to indicate that the "penalty" strap is to be within the first 10 feet of the front of the trailer, or evenly spaced out to give the most resistance to a load shifting or moving during hard braking. Also include the language in the OOS criteria under notes in 393.110 for the spacing of securement devices, but add a special note for the penalty strap.