OOSC, Part II, Item 2. Cargo Securement a. General Securement

Requesting clarification of load securement questions related to vehicles, equipment, and machinery that weigh 10,000lbs or less. More specifically I am asking for clarification on vehicles such as a skid steer (9,000lbs) or similar construction equipment that is being transported in a dump trailer or trailers with side walls and not just on a flat bed trailer. It is my understanding this example does not fall under 393.128 securement for automobiles, light trucks, and vans because a skid steer does not meet the definition of any of those vehicles. Similarly, it does not fall under 393.130 because it does not weigh 10000lbs or more. So the vehicle should be secured in accordance with the provisions of §§ 393.100 through 393.114. Under 393.102 C2 "Equivalent means of securement Transported in a sided vehicle that has walls of adequate strength, such that each article of cargo within the vehicle is in contact with, or sufficiently close to a wall or other articles, so that it cannot shift or tip to the extent that the vehicle's stability or maneuverability is adversely affected; or" What qualifies as walls of adequate strength? Sided vehicle. A vehicle whose cargo compartment is enclosed on all four sides by walls of sufficient strength to contain articles of cargo, where the walls may include latched openings for loading and unloading, and includes vans, dump bodies, and a sided intermodal container carried by a vehicle. What qualifies as walls of sufficient strength? 393.102 Performance criteria for devices to prevent vertical movement of loads that are not contained within the structure of the vehicle. Securement systems must provide a downward force equivalent to at least 20 percent of the weight of the article of cargo if the article is not fully contained within the structure of the vehicle. If the article is fully contained within the structure of the vehicle, it may be secured in accordance with § 393.106(b). What is considered to be "contained within the structure of the vehicle. Does contained means a sided vehicle or something like a van trailer that is fully enclosed box?

Clarification of 393.102 C2 "walls of adequate strength". Set a standard for height of walls compared to the vehicle being transported. Also, clarify 393.102B "contained within the structure of the vehicle."

Requesting a commodity specific securement requirement for construction vehicles, equipment, and machinery that weigh 10,000lbs or less. or Clarification of 393.102 C2 "walls of adequate strength". Set a standard for height of walls compared to the vehicle being transported. Also, clarify 393.102B "contained within the structure of the vehicle."