Operational Policy 15, Item 3. Coupling Devices b.3. - Wheel Lifts

Referencing 393.71(h)(5). “Method of clamping. Adequate means shall be provided for securely fastening the tow-bar to the towed and towing vehicles.” There appears to be no standard applied to what is “Adequate” for means of securement for vehicles on a wheel lift. (Eg. One tire strap/tiedown or two?) I understand this issue has been brought up in the past with other Issue submissions, specifically 13-001-VEH, 12-003-VEH,& 20-017-VEH. Ops policy 15, Answers the question of if vehicles are required to be secured to a wheel lift. However, it fails to indicate the how or the method of securement. The questionable methods of securement, for which I have encountered are as follows. I have attached photos of the examples. All these examples were not included in the exception for 390.23(a)(3) "Tow trucks responding to emergencies" exception. They are for hire operations, simply transporting vehicles from one location to another. 1. The most common is the use of only one tire strap or tiedown, when the wheel lift was manufactured and intended to be used with two. The use of only one strap or tiedown is considered inadequate based on industry standards and practices. This can be referenced in the 1990 NHTSA Study for the Vulcan Strapless System, where dropped vehicles were associated with the single or only hold down strap failing, in conjunction with other usage errors. I also contacted representatives from the Missouri Tow Truck Association and The American Towing and recovery Institute, located in Missouri. Both representatives stated they train and recommend the use of two adjustable tiedowns for light vehicles on wheel lifts. 2. Regarding large or heavy wreckers, I encountered a bobtailed semi-truck behind pulled by a heavy wrecker where a single 2in synthetic web strap was being used to hold the front axle in the axle forks. Again, both representatives train and recommend the use of two chains or tiedowns to secure the vehicle in the axle forks. The Institute representative even recommended securement against horizontal movement, by implementing a particular tiedown procedure securing the vehicle to the under lift. 3. The last example involves vehicles that have no wheels to be cradled by the wheel lift, or the wheel cradle arms are broken or missing. The vehicle is then attached by use of fixed chains, which are in tension only due to the weight of the vehicle hanging from the wheel lift or the upward pressure from the wheel lifts hydraulic system. The vehicle is not secured from vertical or forward movement when traversing rough surfaces where it may bounce upward and become loose from the chain.

As with nearly all of the cargo securement requirements, we have specific instruction on how certain cargo is to be secured. This is one area where the specificity appears to be lacking. In the Action Taken by Committee summary, of Issue 13-001-VEH, the following is mentioned “All tow devices require straps or some other means to keep the vehicle on the lift. Regulators indicated that the training standards from the Rigging and Towing Association indicate that all wheel lifts should use tire straps of some kind.” The pluralization of straps may lead some inspectors to conclude the use of at least two straps is what is required. But if that were the case it should be indicated in the answer provided in Ops Policy 15, Section 3 Coupling Devices, question b.(3).

Requesting clarification on what is considered “Adequate means” when securing vehicles to wheel lifts. Additionally, requesting the committee consider adding the decided clarification to Ops Policy 15, Section 3 Coupling Devices, question b.(3), with similar wording such as, “with a minimum of two adjustable tiedowns”