§393.102 Securement Systems
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 1/2 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
limit.