OOSC, Part II, Item 2. l. Intermodal Containers/Inspection Bulletin

Currently in CVSA Inspection Bulletin 2017-02, the Inspection Guidance portion indicates that only chain or wire rope is allowed in place of an integral locking device. Inspection Guidance 1.49 CFR §393.126 allows a corner of an intermodal container to be secured by means of chain or wire rope instead of an integral locking device." This is addressed in CFR 393.126(c) regarding intermodal containers secured to OTHER THAN CONTAINER CHASSIS VEHICLES. CFR 393.126(b) addresses containers transported on container chassis vehicles and states that all lower corners of the container must be secured with SECUREMENT DEVICES, or integral locking devices. The Inspection Bulletin also references the Canadian NSC Standard 10 as permitting chain or wire rope as securement, but only as a temporary replacement of a defective integral locking device. Standard 10 states that integral locking devices must be used. An interpretation addressed whether chain could be used as a integral locking device. "National Safety Code Standard 10 Cargo Securement Guidance and Interpretations Division 6: Intermodal Containers 2. Integral Locking Device Can a chain be used as an “integral locking device”? (Section 84(2)) Comments: While a chain is not considered to be an integral locking device, it can be used as a temporary tiedown to replace a defective or broken integral locking device on a container chassis to allow the trip to be completed and the integral locking device to be repaired." This interpretation addresses the use of chain and does not concern the use of any other securement devices such as wire rope or synthetic webbing. Since wire rope, synthetic webbing or other securement devices are not ruled out, then the use of synthetic webbing should be allowed as a temporary replacement for a defective integral locking device, either in the US or Canada.

On the occasion that an intermodal container cannot be secured to a container chassis due to damage to the container or chassis locking device, the use of synthetic webbing straps as a temporary replacement would be as safe as chain or wire rope provided the required WLL was met.

In CVSA Inspection Bulletin 2017-2 under the Inspection Guidance portion, the existing wording should be replaced with: "For intermodal containers transported on container chassis vehicles, 49 CFR 393.126(b) allows each lower corner of an intermodal container to be secured by means of a securement device including chain, wire rope, synthetic webbing or an integral locking device. Through an interpretation, Canadian NSC Standard 10 permits the use of chain to secure the corner of an intermodal container, but only as a replacement of a defective integral locking device." If Canada wishes to allow other securement devices, that may be added prior to the change being made, or in a future amendment.