Question 1: Does §393.102(b) prohibit the use of securement devices for which manufacturing standards have not been incorporated by reference?
Guidance: §393.102(b) requires that chain, wire rope, synthetic webbing, cordage, and steel strapping meet minimum manufacturing standards. It does not, however, prohibit the use of other types of securement devices or establish manufacturing standards for those devices. Therefore, if the securement device(s) has an aggregate working load limit of at least ½ the weight of the article, and the load is secured to prevent it from shifting or falling from the vehicle, §§393.100 and 393.102(b) would be satisfied. If the cargo is not firmly braced against a front-end structure that conforms to the requirements of §393.106, the securement system would have to provide protection against longitudinal movement [§393.104(a)]. If the load may shift sideways in transit then §393.104(b) would also be applicable.
Question 2: Does §393.102(b) require that securement devices be marked or labeled with their working load limit or any other information?
Guidance: No. Although §393.102(b) requires chain, wire rope, synthetic webbing, cordage, and steel strapping tiedowns to meet applicable manufacturing standards, it explicitly excludes marking identification provisions of those manufacturing standards. Since §393.102(b) does not establish manufacturing standards or marking requirements for other types of securement devices, such devices are not required to be marked with their working load limi
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