OOSC, Part II, Item 2. Cargo Securement, Friction Mats - WLL

Currently 393.108(g) states friction mats which are not marked or rated by the manufacturer shall be considered to provide resistance to horizontal movement equal to 50 percent of the weight placed on the mat. There is no further guidance for their use as far as when they can and cannot be used in determining the working load limit (WLL) under 393.106. There needs to be guidance added to Operational Policy 15 or regulatory guidance added to the FMCSRs to allow for uniformity in determining the WLL when friction mats are used as well as when and what types of cargo can friction mats be used on.

A recent inspection of an oversize load with a shipping weight of 120,000 lbs. was secured with a total of 4 chains – 2 on the front and 2 at the rear per cargo specific requirements in 393.130(c) that had a total working load limit of 40,000 lbs. aggregate WLL. The driver claimed he was using friction mats that were located under the front axle of the machine to meet the requirements of 393.106. (See the attached pictures). With no clear guidance on the use of friction mats, we had no choice but to count the friction mats towards the WLL of the machine being transported. However, there is no way of knowing the amount of weight being placed on the mat to determine what the mat is worth and it is unclear if the friction mat can be used at all in this situation.

Operational Policy 15 or regulatory guidance needs to be created to address the use of friction mats and when they can or cannot be used when determining the WLL under 393.106 and if they can be used to meet cargo specific requirements. Some suggestions would be: A friction mat cannot be used to replace a tiedown required by the cargo specific sections in 393.116 to 393.136. A friction mat cannot be the sole means of load securement in any application. Friction mats can only be used on items that weigh less than 10,000 lbs. Over 10,000 lbs., they can only be used as a supplement means of securement (blocking and bracing) but will not count towards the WLL.