OOSC, Part II, Item 2. Cargo Securement - Working Load Limit/Breaking Strength - 393.102

393.102 (a)(1) and (2) (a)(1) is discussing Breaking strength. This information is not readily available. Clarification needs to be made to better understand the requirements of this section. Even the "Practical Cargo Securement" guidebook, states that cargo must be secured to the rear (preventing forward movement) .8g of deceleration. It muddies the water even more in (a)(2) (a)(2) talks about WLL and does not clearly define that to comply with this number you must follow the guidelines of 393.106(d) which states that 1/2 of the weight of the cargo must be covered by the WLL of the securement devices. It goes on to say that .43g deceleration and .5g acceleration need to be covered... that is not quite consistent with (a)(1). If the driver has access to the breaking strength numbers or uses the WLL=1/3 of the breaking strength (which is an industry standard but not the rule and typically not labeled on the securement device) then when you work out the math it normally comes out to close to the same requirements. BUT, it is not exact, so why have it in there? it just makes the regulation difficult to understand and be in compliance. Maybe someone can explain it better, but I have worked the numbers several times (see attached) and they just don't make sense. It leaves carriers to make their own assumptions/rules on the requirements.

To better clarify the cargo securement regulations and make a distinction/unification of the two conflicting regulations.

Amend 393.102, to unify (a)(1) and (a)(2), reflecting equalized results from using either method, OR remove (a)(1) because the breaking strength is not readily available information to the end user... the driver. Also reflect greater protection against forward movement of the cargo, .435g protection against deceleration and .5g protection against acceleration is backward, it should, at a minimum, be the other way around.