Cargo and equipment (such as tires, tools, tarps, etc.) carried on a commercial motor vehicle (CMV) must be loaded and secured in a way that prevents them from shifting on or within the vehicle, or from leaking, spilling, blowing, or falling from the vehicle. In addition, laws and regulations govern the security of vehicles at loading docks as well as the service of loading and unloading cargo (known as lumping).

• Various definitions are crucial to the understanding of cargo securement.

Aggregate working load limit: The summation of the working load limits or restraining capacity of all devices used to secure an article of cargo on a vehicle.

Agricultural commodity trailer: A trailer designed to transport bulk agricultural commodities in off-road harvesting sites and to a processing plant or storage location, as evidenced by skeletal construction that accommodates harvest containers, a maximum length of 28 feet, and an arrangement of air control lines and reservoirs that minimizes damage in field operations.

Anchor point: Part of the structure, fitting, or attachment on a vehicle or article of cargo to which a tiedown is attached.

Article of cargo: A unit of cargo, other than a liquid, gas, or aggregate that lacks physical structure (e.g., grain, gravel, etc.) including articles grouped together so that they can be handled as a single unit or unitized by wrapping, strapping, banding, or edge protection device(s).

Bill of Lading: An agreement between a shipper and a carrier governing their relationship with respect to the transportation of goods. It is the contract of carriage. As a contract, it names the parties involved and locations, defines the specific rate or charge for the transportation, and provides information regarding the limits of the carrier�s liability for damaged or lost goods. A contract carrier that has a specific agreement with a shipper is not required to use a bill of lading under 373.101.

Commercial motor vehicle: A self-propelled or towed vehicle used on a highway to transport property when the vehicle:

• Has a gross vehicle weight rating (GVWR) or gross combination weight rating (GCWR), or gross vehicle weight (GVW) or gross combination weight (GCW) of 10,001 pounds or more, whichever is greater; or
• Is transporting hazardous materials of a type or quantity that requires placarding.

Common carrier: A carrier that hauls cargo or passengers for any customer without a contract or master agreement. When acting as a common carrier, the goal is to obtain higher-paying loads from load boards on a load-by-load basis. All charges and conditions are subject to a bill of lading and rate sheet as agreed upon for specific loads.

Contract carrier: A carrier that has a contractual relationship with shippers, brokers, or freight forwarders to haul freight with the intent of creating more predictable load volumes on targeted freight lanes. The contract operates as a master agreement and covers rates, claims handling, accessorials, including loading or unloading charges, fuel surcharges, redelivery fees, and any other charge that is in addition to the linehaul mileage rate. Individual rate sheets may also be issued for each load subject to the master agreement on legal requirements.

Dockboard: A portable or fixed device that spans a gap or compensates for a difference in elevation between a loading platform and a transport vehicle. Dockboards include, but are not limited to, bridge plates, dock plates, and dock levelers.

Dunnage: All loose materials used to support and protect cargo.

Dunnage bag: An inflatable bag intended to fill empty spaces between articles of cargo or articles of cargo and the wall of the vehicle.

Edge protector: A device placed on the exposed edge of an article to distribute tiedown forces over a larger area of cargo than the tiedown itself, to protect the tiedown and/or cargo from damage, and to allow the tiedown to slide freely when being tensioned.

Heavy hauler trailer: A trailer which has one or more of the following characteristics, but which is not a container chassis trailer:

1. Its brake lines are designed to adapt to separation or extension of the vehicle frame; or
2. Its body consists only of a platform whose primary cargo-carrying surface is not more than 1,016 mm (40 inches) above the ground in an unloaded condition, except that it may include sides that are designed to be easily removable and a permanent front-end structure as described in 393.114.

Loading platforms: Loading docks, interior floors, driveways, or other walking or working surfaces.

Lumper: A day laborer employed to handle cargo.

Pulpwood trailer: A trailer or semitrailer that is designed exclusively for harvesting logs or pulpwood and constructed with a skeletal frame with no means for attachment of a solid bed, body, or container.

Tiedown: A combination of securing devices which form an assembly that attaches articles of cargo to, or restrains articles of cargo on, a vehicle or trailer, and is attached to anchor point(s).

Transport vehicles: A cargo-carrying vehicle that workers may enter or walk onto to load or unload cargo and materials. Transport vehicles include, but are not limited to, trucks, trailers, semitrailers and rail cars.

Wheel chocks/sand shoes: Wedges of sturdy material placed against a transport vehicle�s wheels to prevent movement, especially while people are working around or in the vehicle.

Working load limit (WLL): The maximum load that may be applied to a component of a cargo securement system during normal service, usually assigned by the manufacturer of the component.

• Various laws and regulations govern CMV loading and securement.

The laws and regulations governing commercial motor vehicle (CMV) loading and securement include:

• Federal cargo securement regulations in 49 CFR Part 393, Subpart I, Protection against shifting and falling cargo;
• Federal regulations in 392.9 for ensuring proper cargo and equipment placement and securement before driving as well as on the road;
• Federal regulations in 393.41(b) and 29 CFR 1910.26 for the use of wheel chocks; and
• Federal leasing regulations in 49 CFR 376.12, for contracts related to loading and unloading.

Note that state and local laws and regulations may also address the issue of cargo loading and securement. The Occupational Safety and Health Administration (OSHA) also has jurisdiction over the loading/unloading process.

• Cargo loading and securement regulations apply to motor carriers and their drivers who operate CMVs.
• Motor carriers and drivers that are only involved in intrastate commerce are subject to that state�s cargo loading and securement laws and regulations.

Cargo loading and securement regulations apply to motor carriers and their drivers who operate commercial motor vehicles (CMVs). In general, the rules do not distinguish between types of CMVs, so all kinds of CMVs are subject to the requirements, including all trucks, flatbeds, and box/van trailers.

A commercial motor vehicle is any self-propelled or towed vehicle used on a highway to transport property or passengers in interstate commerce when the vehicle:

• Has a gross vehicle weight rating (GVWR) or gross combination weight rating (GCWR), or gross vehicle weight (GVW) or gross combination weight (GCW), of 10,001 pounds or more, whichever is greater; or
• Is designed or used to transport nine or more passengers (including the driver) for compensation or 16 or more passengers (including the driver) not for compensation; or
• Is transporting hazardous materials of a type or quantity that requires placarding.

A highway is any road, street, or way (whether on public or private property) that is �open to public travel,� meaning that the road or way is available (except during scheduled periods, extreme weather, or emergency conditions) and passable by four-wheel standard passenger cars and is open to the general public for use without restrictive gates, prohibitive signs, or regulations other than restrictions based on size, weight, or class of registration.

Intrastate operations

A key part of the CMV definition is interstate commerce, meaning commerce that crosses state or national borders. Motor carriers and drivers that are only involved in intrastate (in-state) commerce are subject to that state�s cargo loading and securement laws and regulations. Under those laws or regulations, the CMV definition may differ from the one described above. In general, however, cargo securement regulations are uniform across North America, with some regional differences.

• Precautions must be taken during the cargo loading process.
• Wheel chocks are required for certain CMVs when parked at loading docks.

Precautions must be taken during the cargo loading process to ensure the vehicle does not move, cargo is properly placed on the vehicle, cargo is not damaged or overloaded, and lumping services are handled properly.

Wheel chocks

Wheel chocks, �wedges� placed against the wheels of a motor vehicle to prevent movement, are useful as a safety device and are required for certain commercial motor vehicles (CMVs) when parked at loading docks. In part, this applies to all general industry employers that use dockboards while loading and unloading transport vehicles. (29 CFR 1910.26) (29 USC 653) (49 CFR 393.41(b))

• Though the use of wheel chocks is recommended, FMCSA does not require wheel chocks in most cases because a CMV�s parking brakes are supposed to be able to hold the vehicle in place.
• OSHA requires that there be a means in place, such as wheel chocks or sand shoes, to prevent transport vehicles from moving while dockboards are used.

Wheel chocks are typically placed against the wheels of commercial trailers at loading docks. At times, they are required by either the Federal Motor Carrier Safety Administration (FMCSA) or the Occupational Safety and Health Administration (OSHA). Chocks are also recommended when drivers or other personnel are working around or on a commercial motor vehicle (CMV), such as to perform an inspection or perform maintenance, when vehicle movement could cause injuries or death.

FMCSA requirements

The FMCSA�s parking-brake standard requires that every CMV be equipped with a parking-brake system that can hold the vehicle or combination in place under any condition of loading. For this reason, wheel chocks are not required on most CMVs, with the exception of agricultural-commodity, heavy-hauler, and pulpwood trailers. These types of vehicles must be equipped with enough wheel chocks to prevent movement, but the regulations do not specify how or when to use them or how many to use.

OSHA requirements

OSHA has stated that relying only on the FMCSA�s brake regulations may not prevent transport vehicles from moving while dockboards are being used. OSHA contends that it has authority to enforce chocking requirements over:

• Transport vehicles that do not meet the CMV definition (such as those not operating on a �highway�); and
• CMVs not operated in interstate commerce.

OSHA requires that there be a means in place, such as wheel chocks or sand shoes, to prevent transport vehicles from moving while dockboards are used. Movement of a transport vehicle while it is being loaded or unloaded can lead to crushing or fall injuries.

Finally, note that motor carriers and shippers or receivers can mandate the use of wheel chocks even when not specifically required by regulation.

• Before loading cargo into or onto any trailer, the driver should make sure the trailer will not damage the cargo.
• Drivers need to count their cargo as it is being loaded.
• After verifying the count and condition during loading, the driver must make sure the load paperwork matches the cargo.

Before loading cargo into or onto any trailer, the driver should make sure the trailer will not damage the cargo. Simple steps such as sweeping, pulling nails, and making sure the deck and roof or tarps are watertight can prevent claims. Companies should have a policy in place (and enforced) that requires the drivers to do these things before loading.

Another key area for the prevention of all three types of cargo claims is the drivers� actions during loading. Many drivers use the time during loading as a sleeper break, to put themselves in a position to be able to drive more miles. The downfall with this is that when the driver signs the bill of lading, there is no way the driver can truthfully attest to what is in the truck. If the truck arrives at the receiver 30 cases short, for example, the driver cannot honestly say if the cases were on the truck in the first place. Companies should drive home the point to the drivers that they need to count their cargo as it is being loaded.

Also during loading, drivers should inspect their cargo. As a general rule, the driver is going to sign documentation that the cargo was in good condition at the time of loading. If it arrives at the receiver with damage, the receiver will not be concerned about who caused the damage. They will reject the freight and let the shipper and carrier fight it out.

After verifying the count and condition during loading, the driver must make sure the load paperwork matches the cargo. If the paperwork does not match, the driver will need to first bring it to the shipper�s attention. If the shipper will not make corrections, the carrier should have a procedure that instructs the driver to contact the company immediately.

• It is illegal to force or attempt to force a driver to load or unload, or to force the driver to employ someone else to load or unload.
• The written lease agreement or contract must contain a clear statement of who is responsible for loading and unloading.

The service of loading and unloading cargo by laborers is known in the motor carrier industry as lumping. Lumping was addressed in the Motor Carrier Act of 1980 and the Interstate Commerce Commission Termination Act of 1995.

Under those laws, it is illegal to force or attempt to force a driver to load or unload, or to force the driver to employ someone else to load or unload. A driver may hire someone to load or unload but cannot be forced to do so. If the driver is required by the shipper or receiver to hire someone to load or unload, the shipper or receiver must compensate the driver.

The intention of the provision is to give the driver the option of loading or unloading themselves or choosing to pay for assistance. Nothing in the law prohibits a driver from loading or unloading the vehicle himself or herself.

Written agreements

Exactly who is responsible for loading and unloading, and payment for that task, should be negotiated and agreed upon by the shipper and carrier in advance and should be in writing. This requirement can be met in several ways:

• The information may be incorporated into the �tariff� or �rate sheet� published by the carrier, and available to the shipper upon request.
• The responsibility for loading/unloading may be noted on the bill of lading issued by the carrier.
• A carrier operating under contract as a contract carrier may include the loading/unloading information within the contract with the shipper.

Leases and contracts

The law is clear regarding leased vehicles, and contracts entered into by owner-operators. The written lease agreement or contract must contain a clear statement of who is responsible for loading and unloading: the shipper, receiver, or the driver of the vehicle. 49 CFR 376.12(e)

Penalties

The Federal Motor Carrier Safety Administration (FMCSA) has severe penalties for violation of these loading/unloading requirements, found in Part 386 Appendix B.

Applicable laws

Under the Interstate Commerce Commission Termination Act of 1995, section 14102(b) outlines who is responsible for loading and/or unloading a vehicle:

(b) Responsible Party for Loading and Unloading: The Secretary shall require, by regulation, that any arrangement, between a motor carrier of property providing transportation subject to jurisdiction under Subchapter I of Chapter 135 and any other person, under which such other person is to provide any portion of such transportation by a motor vehicle not owned by the carrier shall specify, in writing, who is responsible for loading and unloading the property onto and from the motor vehicle.

Section 14103 further outlines details on loading and unloading motor vehicles:

(a) Shipper Responsible for Assisting: Whenever a shipper or receiver of property requires that any person who owns or operates a motor vehicle transporting property in interstate commerce (whether or not such transportation is subject to jurisdiction under Subchapter I of Chapter 135) be assisted in loading or unloading such vehicle, the shipper or receiver shall be responsible for providing such assistance or shall compensate the owner or operator for all costs associated with securing and compensating the person or persons providing such assistance.

(b) Coercion Prohibited: It shall be unlawful to coerce or attempt to coerce any person providing transportation of property by motor vehicle for compensation in interstate commerce (whether or not such transportation is subject to jurisdiction under subchapter I of chapter 135) to load or unload any part of such property onto or from such vehicle or to employ or pay one or more persons to load or unload any part of such property onto or from such vehicle; except that this subsection shall not be construed as making unlawful any activity which is not unlawful under the National Labor relations Act or the Act of March 23, 1932 (47 Stat. 70; 29 USC 101 et seq.) commonly known as the Norris-LaGuardia Act.

• All cargo must be firmly immobilized or secured on or within the vehicle.

Federal regulations specify how cargo and equipment on a commercial motor vehicle (CMV) must be loaded and secured to prevent that cargo or equipment from:

• Leaking, spilling, blowing, or falling from the vehicle; or
• Shifting so much that it adversely affects the vehicle�s stability or maneuverability.

Basic principles

All cargo must be firmly immobilized or secured on or within the vehicle using:

• Structures like floors, walls, and beams (as long as they are strong enough);
• Tiedowns like straps, chains, or ropes;
• Dunnage or dunnage bags;
• Shoring bars; or
• A combination of these.

Cargo that is likely to roll must be restrained by chocks, wedges, a cradle, or other equivalent means to prevent rolling. Those items used to prevent rolling must not be able to become loose in transit.

To prevent shifting, articles of cargo that are placed beside each other and secured by tiedowns across the top must either be:

• Placed in direct contact with each other; or
• Otherwise prevented from shifting towards each other while in transit, such as by placing dunnage in between.

• Tiedowns are an important part of a safe trucking operation because they prevent the shifting or loss of cargo.
• Knowing the working load limit of the securement system is key to securing cargo.
• Regulations do not require tiedowns to be marked or labeled.

The cargo securement requirements of the Federal Motor Carrier Safety Regulations specify how � and how many � cargo tiedowns are to be used. Tiedowns include chains, ropes, webbing, steel straps, binders, buckles, and other devices that can be used to secure cargo. Subpart I of 49 CFR Part 393 Tiedowns are an important part of a safe trucking operation because they prevent the shifting or loss of cargo.

Working load limits (WLLs)

A key concept when working with tiedowns is their �working load limit� (WLL) which indicates how strong they are and thus how much cargo they can secure. The WLL is the maximum load that may be applied to a tiedown or other component of a cargo securement system during normal service. The WLL is usually assigned by the manufacturer of the component and is generally equal to one-third (or in some cases one-fourth) of the ultimate breaking strength of that device.

The WLL of a tiedown, associated connector, or attachment mechanism is the lowest WLL of any of its components (including tensioner), or the WLL of the anchor points to which it is attached, whichever is less. For example, if a chain has a WLL of 6,600 pounds but the binder used on that chain has a WLL of 5,000 pounds, the WLL for that tiedown device is 5,000 pounds. This is based on the idea that the securement system is only as strong as its weakest component.

Determining the WLL of a tiedown

The regulations do not require tiedowns to be marked or labeled. However, manufacturers of tiedowns and associated equipment are encouraged to provide motor carriers and enforcement officials with a means to easily determine the working load limits of their products.

The WLLs may be determined by using either:

• The tiedown manufacturer�s markings on the device, or
• The tables in 393.108.

The WLLs listed in the regulation must be used when the tiedown material is not marked with a WLL by the manufacturer. If the value in the regulation is different from the manufacturer�s marking, employees should use the marked value. Note that an unmarked chain is assumed to be Grade 30.

Aggregate WLL

Another key factor when using tiedowns is their combined or �aggregate� WLL. The aggregate WLL of any securement system must be at least one-half times the weight of the article(s) being secured. For example, the tiedowns used to secure cargo weighing 30,000 pounds must have an aggregate WLL of 15,000 pounds. The aggregate WLL is determined by adding together:

1. One-half (50 percent) of the WLL of each tiedown that goes from an anchor point on the vehicle to an anchor point on an article of cargo;
2. One-half (50 percent) of the WLL of each tiedown that is attached to an anchor point on the vehicle, passes through, over, or around the article of cargo, and is then attached to an anchor point on the same side of the vehicle; and
3. The full (100 percent) WLL for each tiedown that is attached to an anchor point on the vehicle, passes through, over, or around the article of cargo, and then attaches to another anchor point on the other side of the vehicle.

Note that additional tiedowns may be needed based on the shape, length, and placement of the cargo.

• Tiedowns and related components must meet certain safety standards.
• The minimum number of tiedowns needed for an article of cargo depends on the cargo�s weight, length, and placement.
• Front-end structures are not required on a CMV.

Tiedown standards

Tiedowns and related components must meet the following standards:

• Tiedowns and associated connectors and mechanisms (except steel strapping) must allow for in-transit adjustment.
• Tiedowns must be attached and secured in a way that prevents them from becoming loose, unfastening, opening, or releasing while in transit.
• Tiedowns cannot be used if they have any knots.
• If a tiedown is repaired, it must be repaired in accordance with accepted manufacturing standards.
• Edge protectors must be used whenever a tiedown is subject to abrasion or cutting at the point where it touches an article of cargo.
• The minimum performance criteria for tiedowns, based on forces of acceleration and deceleration, are found in 49 CFR 393.102.

Minimum number of tiedowns

The minimum number of tiedowns needed for an article of cargo depends on the cargo�s weight, length, and placement.

When an article is not blocked or positioned to prevent forward movement by a headerboard, bulkhead, other secured cargo, or other appropriate blocking devices, it must be secured by at least:

• One tiedown for articles five feet (1.52 meters) or less in length, and 1,100 pounds (500 kg) or less in weight;
• Two tiedowns if the article is:
  • Five feet or less in length and more than 1,100 pounds in weight, or
  • Longer than 5 feet, but less than or equal to 10 feet (3.04 meters) in length, irrespective of the weight;
• Two tiedowns if the article is longer than ten feet and one additional tiedown for every ten feet of article length, or fraction thereof, beyond the first ten feet of length.

If an article of cargo is blocked, braced, or immobilized to prevent forward movement, it must be secured by at least one tiedown for every 10 feet of article length, or fraction thereof. For example, a 26-foot item of cargo placed against a bulkhead must be secured with at least 3 tiedowns (and the aggregate working load limit (WLL) of those tiedowns must be at least one-half of the cargo weight).

Front end structures

Front-end structures are not required on a CMV. However, if a front-end structure (like a bulkhead or headerboard) is used to prevent forward movement of cargo, then that structure must meet the standards in 393.114. The structure must:

• Extend either four feet above the floor of the vehicle or to a height at which it blocks forward movement of any item or article of cargo being carried on the vehicle, whichever is lower.
• Be at least as wide as the vehicle or wide enough to block forward movement of any article of cargo being carried on the vehicle, whichever is narrower.
• Be designed, constructed, and maintained so that it is capable of resisting penetration by any article of cargo that contacts it when the vehicle decelerates at a rate of 20 feet per second, per second.
• Have no openings large enough to allow any article of cargo in contact with the structure to pass through it.
• Be capable of withstanding the following horizontal forward static load:
  • If the structure is less than six feet tall, a load equal to one-half of the weight of the articles of cargo being transported on the vehicle uniformly distributed over the entire portion of the front-end structure that is within 4 feet above the vehicle�s floor (or at or below a height above the vehicle�s floor at which it blocks forward movement of the cargo, if lower); or
  • If the structure is at least six feet tall, a load equal to 40 percent of the weight of the cargo when the cargo is uniformly distributed over the entire front-end structure.

Substitute devices can be used if the devices are at least as strong as, and provide protection against shifting articles of cargo at least equal to, a front-end structure which complies with the requirements listed above.

• Federal regulations include specific securement rules for various commodities.

Commodity-specific rules

Federal regulations include specific securement rules for the following commodities. These rules must be followed in addition to the rules for general freight.

• Logs: 49 CFR 393.116
• Dressed lumber and similar building products: 393.118
• Metal coils: 393.120
• Paper rolls: 393.122
• Concrete pipe: 393.124
• Intermodal containers: 393.126
• Automobiles, light trucks, and vans: 393.128
• Heavy vehicles, equipment, and machinery: 393.130
• Flattened or crushed vehicles: 393.132
• Roll-on/roll-off or hook lift containers: 393.134
• Large boulders: 393.136

After the start of a trip, truck drivers must make sure that their cargo remains secured. They must do this within 50 miles of the start of the trip (within the first 25 miles is recommended), and then again:

• Whenever they make a change of duty status;
• After driving for three hours; or
• After driving for 150 miles, whichever occurs first.

This en-route inspection is not required for a sealed load that is not to be opened, or if checking the cargo is impracticable.

• Cargo and equipment must be secured regardless of vehicle type.
• Bungee cords and tarp straps are not suitable for use as tiedowns.
• Tarps are not specifically required under federal rules.

Q: Do I have to secure cargo in my dry van?

A: Yes, all cargo and equipment must be secured against movement, regardless of vehicle type. However, according to 49 CFR 393.102(c), cargo is considered to be secured if it is transported in a sided vehicle that has �walls of adequate strength� and each article of cargo within the vehicle is in contact with, or close enough 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.

Q: Do I have to secure my spare tire, spare chains, landing gear crank, and other vehicle equipment?

A: Yes. The tailgate, tailboard, dunnage, doors, tarps, spare tire, straps, chains, binders, wood blocks, and other equipment used in the vehicle�s operation must be secured.

Q: Does my vehicle have to have a headerboard/bull board/headache rack?

A: No, but if the cargo is in contact with a front-end structure, then that structure must comply with certain specifications. Refer to 393.114.

Q: Can a bungee cord or tarp strap be used as a primary means of securing cargo?

A: Bungee cords and tarp straps are not suitable for use as tiedowns, but they can be used as supplementary restraints for lightweight cargo and equipment.

Q: Are lever-type binders acceptable?

A: Yes. The rules do not specify the types of binders that may be used.

Q: Does coiled wire have to be secured according to the rules for metal coils?

A: In the United States, all coiled, rolled, or wrapped metal objects must be secured according to the rules for metal coils. In Canada, the rules for metal coils apply only to coils of rolled sheet metal.

Q: Are tarps required?

A: They are not specifically required under the federal rules, but they may be necessary to contain certain types of loads, and some states, provinces, and/or the company may require their use.

Q: Can cargo straps go around the outside of the rub rails?

A: Yes, in the United States, but not in Canada. At least as a best practice, all straps should be routed in-board of the rub rails whenever possible.