OOSC, Part II, Item 2. Cargo Securement - Hay Racks

Email from Saskatchewan based company: We are looking for some clarification on one item. According to a “comment” in Division 4, Section 6, of the NSC 10 Cargo Securement Guidance and Interpretations update May 2016, Hay Racks are deemed to be a “Pole Trailer” and thus require a tie down for every stake. Our Hayracks historically had 4 stakes, which would require 4 ties downs, assuming they met the 1/6 WLL. These 4 bunk trucks would run with 5 tie downs and adequately met the 1/6th WLL. Because we now haul shortwood and TL with these trailers, we have installed 2 extra bunks. When hauling shortwood, the trucks wrap 6 tiedowns. When hauling TL, we have learned that the trucks sometimes run with 5 tiedowns. The 5 tie downs meet the WLL quite easily, and when you take the 2 extra stakes into account(stakes have been factored into the 1/6 for Log trucks), they have more than covered the WLL for the load. Unfortunately, by adding the extra 2 stakes, we now require 6 tie downs on the TL Hayrack because it is deemed to be a “Pole Trailer”. Remove the stakes(have less load security), and we only need 4 to 5 tie downs depending on WLL of ropes. You can see the flaw in the logic here that is a result of a decision to class a Hayrack as a Pole Trailer. Hayracks are not pole trailers, pole trailers are not permittable in SK to my knowledge.

Standard 10 clearly requires a tiedown at each bunk. Interpretation required: -Pole trailers vs Hay racks. Does this need to be reviewed? -Should the tiedown requirement be based off of length vs amount of bunks? -Other ideas/comments

Canadian regulators require an interpretation and seek discussion and comments from the Cargo Securement Forum in order to better answer this concern.