Interpretation Response #20-0091
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
January 11, 2021
Van Diest Supply Company
1434 220th St
Webster City, IA 50595
Reference No. 20-0091
Dear Mr. Hilpipre:
This letter is in response to your November 24, 2020, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to highway transportation load securement requirements. In your letter, you describe a scenario and provide photographs illustrating the method of securement of your intermediate bulk containers (IBCs) within a trailer. Furthermore, you state that you believe the forward pressure of the IBCs on each IBC in front of it—created by strapping the IBCs at the rear of the trailer—keeps all the IBCs from shifting side to side. Specifically, you request confirmation that this manner of load securement meets the performance standard of § 177.834(a) of the HMR.
Based on the photographs and information provided in your letter, we cannot definitively determine whether the load is secured against shifting. Section 177.834(a) states 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." As illustrated by the photographs, there appear to be voids between the IBCs, and between the IBCs and the sides of the trailer, which could allow the IBCs to shift in the absence of a method of securement. The longitudinal securement of the load by strapping the IBCs at the rear of the trailer may be appropriate if it achieves the performance standard of "securing against shifting" under normal transportation conditions.
Note that 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 could be acceptable to secure the IBCs from shifting within the trailer. I hope this information is helpful. Please contact us if we can be of further assistance.
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
|§ 177.834||General requirements|