OOSC, Part II, Item 2. Cargo Securement, l. Intermodal Containers - Fracking Sandboxes

Fracking sandboxes made by different Manufacturers are designed to be transported on an intermodal type chassis system or a flatbed trailer utilizing corner locks/integral locking device at each corner of the sandbox. Inspectors are finding one or more corner locks/integral locking devices not “locked” into place; thus, the sandbox is just sitting in place on the chassis. The sandbox does not meet the definition of an intermodal container and cannot be held to Commodity Specific requirements for Intermodal Containers in 393.126. They do, however, fit into the same category as “modified intermodal containers used for office space or other storage modules equipped with corner locks (i.e., PODs)” in terms of securement, as those outlined in Operational Policy 15, b. (11). Operational Policy 15 states these types of containers “may be secured using general prevision or they may be secured by corner locks as per equivalent means of securement,” which is outlined in 393.102(c).

Clarification needs to be made at what point a violation or an out of service condition exists when one or more unlocked corner lock(s)/integral locking device(s) is discovered, and no other tie-down securement is used. These types of containers are designed to be secured at four corners, and these devices are considered an “equivalent means of securement” (393.102(c)). 393.100(b) provides cargo must be secured in accordance with this subpart to prevent the cargo from leaking, spilling, blowing, or falling from the motor vehicle.

(1) Add fracking sandboxes to Operational Policy 15.b.(11). (2) Clarify at what point a violation and an out of service condition exists for any container of this type, other than an intermodal container, utilizing the corner locking devices/integral locking devices when those locking devices are found to be unlocked.