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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #12-0136 ([Transportation Enforcement Division Public Utilities Commission of Ohio] [Mr. Carlisle Smith])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Transportation Enforcement Division Public Utilities Commission of Ohio

Individual Name: Mr. Carlisle Smith

Location State: OH Country: US

View the Interpretation Document

Response text:

August 1, 2012


Mr. Carlisle Smith
Supervisor, Hazardous Materials Section
Transportation Enforcement Division
Public Utilities Commission of Ohio
180 East Broad Street
Columbus, Ohio 43215

Reference No.: 12-0136

Dear Mr. Smith:

This is in response to your June 21, 2012 email requesting guidance relating to the highway transportation load securement requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You present a particular loading scenario for intermediate bulk containers (IBCs) within a van type trailer and provide supporting photographs. You ask whether the IBCs, loaded as described and depicted are in compliance with the load securement requirements of the HMR.

The answer is no.

As depicted, the longitudinal (front to back) securement of the load may be appropriate, however, the lateral (side-to side) securement is insufficient. Section 177.834(a) of the HMR provides, "Any package containing any hazardous material, not permanently attached to a motor vehicle, must be secured against shifting, including relative motion between packages, within the vehicle on which it is being transported, under conditions normally incident to transportation." As loaded, voids between the IBCs and between the IBCs and the sides of the trailer could allow the IBCs to shift, and there is no securement mechanism in place to prevent the IBCs from shifting. Specific methods for securing packages in a motor vehicle are not provided in the HMR. However, varied methods, such as tiedowns, using dunnage or other cargo, shoring bars, jack bars, or toe-boards would be acceptable to secure the IBCs from side to side movement within the trailer.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.



Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division


Regulation Sections

Section Subject
177.834 General requirements