Operational Policy 15, Item 2.b(1) - Tarp Straps and Bungee Cords

CVSA Operational Policy 15, Item #2.b.(1), revised at the 2018 CVSA Workshop in Kansas City as a result of issue request #17-032-VEH, is causing confusion among enforcement and industry regarding the use of bungee cords for small items such as brooms and rakes.

The first line of item #2.b.(1) for the United States guidance reads, "Bungee cords and tarp straps are not suitable for use as securement devices and are equally unsuited to having an assigned WLL." The second line seems contradictory to that because it states, "There is no intention to prohibit the use of these devices as primary or supplemental restraint for articles..." These contradicting statements have caused erroneous violations being issued on roadside inspection reports, burdens carriers with DataQ challenges, and burdens states with investigating DataQs. It is understandable why industry and enforcement both are confused since the lines seem contradictory.

Determine whether the first line is needed and if not, remove it. If the intent is NOT to prohibit the use of bungee cords for small items, such as brooms, rakes, shovels, etc., that are not part of the cargo, then remove the first line from the United States guidance. This was the ultimate discussion at the KC workshop in 2018, and the decision based on the meeting minutes.