Interpretation Response #13-0044 ([N & M Transfer Co., Inc.] [Mr. Cary Krickeberg])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: N & M Transfer Co., Inc.
Individual Name: Mr. Cary Krickeberg
Location State: WI Country: US
View the Interpretation Document
Response text:
May 3, 2013
Mr. Cary Krickeberg
Safety Manager
N & M Transfer Co., Inc.
630 Muttart Rd.
Neenah, WI 54956
Ref. No. 13-0044
Dear Mr. Krickeberg:
This responds to your February 8, 2013 e-mail to the Hazardous Material Information Center (HMIC) requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the proper securement of Department of Transportation (DOT) Specification 106A500 multi-unit tank car tanks in closed van-type trailers. You present a scenario where the tanks are partially secured within a skidded frame that appears to provide forward, aft, and lateral restraint. In addition, you provide a supporting photograph showing vertical restraint being provided by the use of tiedown straps. You ask for the meaning of the undefined terms “chocked” and “clamped” as they are used in § 177.834(m)(1) and whether the tanks depicted in your photograph are in compliance with the securement requirements prescribed in the HMR.
The terms “chocked” and “clamped” were codified in the HMR in 1970 (HM-14; 35 FR 1109) and remain undefined. However, any method utilized to prevent the skidded tanks from shifting in transportation is acceptable. For your information, the general requirements addressing protection of shifting cargo are found in the Federal Motor Carrier Safety Administration Regulations (49 CFR Parts 300-399), specifically under §§ 393.100 to 393.106. These requirements allow varied methods of securement, such as blocking with other freight, banding, or use of tie-downs or load-locks.
As depicted, the tanks appear adequately secured to the skid. Further, § 177.834(a) of the HMR provides that 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. Specific methods for securing packages in a motor vehicle are not provided in the HMR. However, varied methods, including the method you describe, along with tiedowns, using dunnage or other cargo, shoring bars, jack bars, or toe-boards would be acceptable to secure the skidded tanks from movement within the trailer.
I trust this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
177.834(m)(1)
Regulation Sections
| Section | Subject |
|---|---|
| 177.834 | General requirements |