In-Service Training for the Roadside Inspector

1
In-Service Training for the Roadside Inspector
2013 North American OOSC Inspector Training
2
Objectives

• Review the changes to the April 1, 2013
  Out-of-Service Criteria.

3
2013 OOSC Changes

• Effective April 1, 2013
• Part I Changes
• Part II Changes
• Part IV Changes
• Changes denoted by
• For this Presentation Changes highlighted in
  Red

4
2013 OOSC Changes - Part I

• 2. OPERATORS/CHAUFFEURS LICENSE OR PERMIT
  (NON-CDL)
• a. Vehicle 26,000 lbs. or less GVWR not
  designed to transport 16 or more passengers or
  placarded loads of hazardous materials.
• (1) Is not licensed for the type of vehicle
  being operated. (391.11(b)(5)) Declare
  driver out-of-service.

5
2013 OOSC Changes - Part I

• 2. OPERATORS/CHAUFFEURS LICENSE OR PERMIT
  (NON-CDL)
• a. Vehicle 26,000 lbs. or less GVWR not
  designed to transport 16 or more passengers or
  placarded loads of hazardous materials.
• (2) Operating a non-CDL required commercial
  motor vehicle with driving privileges revoked,
  suspended, cancelled, or otherwise disqualified.
  (391.15(a)) Declare driver out-of- service.
  (Out-of-service action to be initiated only upon
  home jurisdiction license verification.)

6
2013 OOSC Changes - Part I

• 2. OPERATORS/CHAUFFEURS LICENSE OR PERMIT
  (NON-CDL)
• Justification This change codifies the
  OPERATORS/CHAUFFERS LICENSE OR PERMIT (NON-CDL)
  Vehicle 26,000 lbs. or less GVWR not designed to
  transport 16 or more passengers or placarded
  loads of hazardous materials section and
  incorporates the condition of a disqualified
  driver. The DRIVER DISQUALIFICATION section of
  the OOSC has since been removed due to this
  change.

7
2013 OOSC Changes - Part I

• 3. CDL
• a. License
• (1) Does not possess a valid CDL issued by
  his/her state or jurisdiction of domicile.
  (383.23(a)(2)) Declare driver out- of-service.
  (Out-of-Service action to be initiated only upon
  home jurisdiction license verification.)

8
2013 OOSC Changes - Part I

• 3. CDL
• a. License
• (2) Operating a CDL required commercial
  motor vehicle with driving privileges revoked,
  suspended, cancelled, or otherwise disqualified.
  (383.51(a)) Declare driver out-of- service.
  (Out-of-service action to be initiated only upon
  home jurisdiction license verification.)

9
2013 OOSC Changes - Part I

• 3. CDL
• Justification This change codifies the CDL
  License section and incorporates the condition of
  a disqualified driver. The DRIVER
  DISQUALIFICATION section of the OOSC has since
  been removed due to this change.

10
2013 OOSC Changes - Part I

• 3. CDL
• b. Commercial Learners Permit (CLP)
• (1) Is not accompanied by the holder of a valid
  CDL. (383.25(a)(1)) Declare driver
  out-of-service.
• (2) Does not hold a valid automobile drivers
  license or have a valid operators status allowed
  by licensing jurisdiction. (383.25(a)(2)) Declare
  driver out-of-service.
• (3) Operating a commercial motor vehicle
  transporting hazardous materials as defined in
  383.5. (383.25(a)(6)) Declare driver
  out-of-service.

11
2013 OOSC Changes - Part I

• 3. CDL
• Justification This change amends the title of
  the section to Commercial Learners Permit (CLP)
  and further changes the referenced regulations,
  from 383.23 to 383.25, to accurately reflect the
  correct regulation applicable to the OOS
  conditions.

12
2013 OOSC Changes - Part I

• 4. DRIVER MEDICAL/PHYSICAL REQUIREMENTS
• b. Medical Certificate
• (4) Operating a property-carrying vehicle
  without a valid medical certificate in
  possession. If the driver fails to produce a
  medical certificate or has an expired medical
  certificate and has a previous history of
  failing to produce a medical certificate, or
  having an expired medical certificate, the
  driver shall be placed out-of-service.
  (391.41(a)) Declare driver out-of-service.
  Inspection Bulletin 2012-07 Driver Possession
  of a Valid Medical Certificate

13
2013 OOSC Changes - Part I

• 4. DRIVER MEDICAL/PHYSICAL REQUIREMENTS
• Justification This change informs the roadside
  inspector that Inspection Bulletin 2012-07
  Driver Possession of a Valid Medical Certificate
  has recently been created, providing additional
  clarification on how to place a driver
  out-of-service for not having a medical
  certificate.

14
2013 OOSC Changes - Part I

• 6. FATIGUE
• When so fatigued that the driver of a
  commercial motor vehicle should not continue the
  trip. (392.3) Declare driver out-of-service until
  no longer fatigued.

15
2013 OOSC Changes - Part I

• 6. FATIGUE
• Justification This change reflects an open
  September 21, 2011 Minnesota court case that
  rejected the use of the standard of reasonable,
  articulable suspicion to place a driver
  out-of-service, and authorized placing a driver
  out-of-service only on the basis of probable
  cause. On September 27, 2012, CVSA removed the
  standard of reasonable, articulable suspicion
  and has not adopted a more explicit standard due
  to the potential of creating unintended
  inconsistencies and potential problems with
  enforcement.
• The CVSA Fatigue Ad Hoc committee is
  continuing to study this issue.

16
2013 OOSC Changes - Part I

• 8. DRUGS AND OTHER SUBSTANCES AS IDENTIFIED
  UNDER SECTION 392.4(a).
• 9. INTOXICATING BEVERAGES
• 10. DRIVERS RECORD OF DUTY STATUS U.S.
• 11. DRIVERS RECORD OF DUTY STATUS CANADA
• 12. DRIVERS RECORD OF DUTY STATUS MEXICO

17
2013 OOSC Changes - Part I

• 8. DRUGS AND OTHER SUBSTANCES AS IDENTIFIED
  UNDER SECTION 392.4(a).,
• 9. INTOXICATING BEVERAGES,
• 10. DRIVERS RECORD OF DUTY STATUS U.S.,
• 11. DRIVERS RECORD OF DUTY STATUS CANADA, and
• 12. DRIVERS RECORD OF DUTY STATUS MEXICO
• Justification This change re-numbers the
  latter sections of Part I due to the
  reclassifying of and the elimination of the
  DRIVER DISQUALIFICATION section. No changes were
  made to the context of the above sections,
  other than to Footnote 10 of DRIVERS
  RECORD OF DUTY STATUS U.S. (See next slide.)

18
2013 OOSC Changes - Part I

• 10. DRIVERS RECORD OF DUTY STATUS U.S.
• Footnotes for drivers record of duty status
  U.S.
• 10. A driver who utilizes an electronic
  device other than those described in 395.15
  shall not be declared out-of- service if the
  device has the ability to print and sign
  previously completed record of duty status that
  comply with 395.8 upon demand.
• Inspection Bulletin 2012-05 Automatic
  On-Board Recording Devices (AOBRDs)

19
2013 OOSC Changes - Part I

• 10. DRIVERS RECORD OF DUTY STATUS U.S.
• Justification This change informs the roadside
  inspector that Inspection Bulletin 2012-05
  Automatic On-Board Recording Devices (AOBRDs) has
  recently been created. It provides a review of
  the requirements for devices used to record
  drivers hours of service according to 49 CFR
  395.15 Automatic On-board Recording Devices,
  identifies the minimum requirements for devices
  to be a compliant AOBR and identifies what
  information must be displayed and available to
  roadside enforcement for hours of service
  compliance.

20
2013 OOSC Changes - Part II

• Policy Statement
• When a vehicle is declared out-of-service for a
  condition resulting from an accumulation of
  violations, all violations that contributed to
  the specific out-of-service condition must be
  repaired (e.g. a vehicle, or vehicles in
  combination declared out-of service for 20
  percent defective brake violations must have all
  the 20 percent defective brake violations
  repaired prior to being released or, a vehicle
  declared out-of-service for two tires at less
  than 1/32 inch (0.8mm) tread depth must have both
  tire violations repaired prior to the vehicle
  being released, etc.).

21
2013 OOSC Changes - Part II

• Policy Statement
• Justification This change corrects the metric
  measurement equivalent used in the example.

22
2013 OOSC Changes - Part II

• Policy Statement
• A Critical Vehicle Inspection Item Violation(s)
  (OOS or otherwise) noted during a CVSA Level I
  Inspection that is successfully repaired on-site
  and re-inspected by the same inspector at the
  same inspection location will qualify for a CVSA
  decal as long as all previously noted Critical
  Vehicle Inspection Item violation(s) have been
  properly repaired. In such instance, only a
  re-inspection of the repaired violation(s) shall
  be done with decal(s) being applied to the
  vehicle(s) and properly noted upon the original
  inspection.

23
2013 OOSC Changes - Part II

• Policy Statement
• Any vehicle that is repaired off-site or
  inspected by a different inspector shall be
  required to have a complete inspection conducted
  in order to obtain a CVSA decal.
• Justification This change updates and
  clarifies the Part II NORTH AMERICAN STANDARD
  VEHICLE OUT-OF-SERVICE CRITERIA POLICY STATEMENT,
  reflecting the changes to the Qualifying for CVSA
  Decals Vehicle Re-Inspections policy concerning
  when a vehicle will and will not qualify for a
  CVSA decal after a Critical Vehicle Inspection
  Item violation(s) is discovered during
  a CVSA Level I Inspection.

24
2013 OOSC Changes - Part II

• 1. BRAKE SYSTEMS
• a. Defective Brakes
• (5) Drum (Cam-Type and Wedge) Air Brakes
• (c) Defective Lining Conditions
• vi. The friction surface of the brake drum
  and the brake friction material are
  contaminated by oil or grease.
  (393.47(a))

25
2013 OOSC Changes - Part II

• 1. BRAKE SYSTEMS
• Justification This change removes brake fluid
  as a listed contaminant and makes the OOSC
  consistent with the fact that drum air brakes do
  not utilize brake fluid.

26
2013 OOSC Changes - Part II

• 1. BRAKE SYSTEMS
• o. Hydraulic Brakes
• Inspection Bulletin 2012-04 Hydraulic Brake
  System Inspection Procedures

27
2013 OOSC Changes - Part II

• 1. BRAKE SYSTEMS
• Justification This change informs the roadside
  inspector that Inspection Bulletin 2012-04
  Hydraulic Brake System Inspection Procedures has
  recently been created describing inspection
  procedures and operating information for
  commercial vehicles with hydraulic brake systems.
  It is written for the purpose of supporting
  roadside vehicle inspections and is primarily
  intended to identify OOS conditions.

28
2013 OOSC Changes - Part II

• 2. COUPLING DEVICES
• e. Drawbar/Tongue
• (1) Slider (Power/Manual)
• (c) Movement of more than ¼ inch (6.4 mm)
  between the slider and housing. (Trailer
  393.70(c) or Driveaway 393.71(h))

29
2013 OOSC Changes - Part II

• 2. COUPLING DEVICES
• Justification This change corrects the metric
  measurement equivalent.

30
2013 OOSC Changes - Part II

• 2. COUPLING DEVICES
• e. Drawbar/Tongue
• (2) Integrity
• (b) Movement of ¼ inch (6.4 mm) between
  subframe and drawbar at point of
  attachment. (Trailer 393.70(c) or
  Driveaway 393.71(h))

31
2013 OOSC Changes - Part II

• 2. COUPLING DEVICES
• Justification This change corrects the metric
  measurement equivalent.

32
2013 OOSC Changes - Part II

• 2. COUPLING DEVICES
• f. Safety Devices
• (4) Chain or Wire Rope Damaged or defective to
  the same extent as the criterion used for chain
  or wire rope defects described in the
  Securement of Cargo Tiedown Defect Table.
  (Trailer 393.70(d) or Driveaway
  393.71(h)(10))

33
2013 OOSC Changes - Part II

• 2. COUPLING DEVICES
• f. Safety Devices
• (4) (Continued)
• Exception Quick-link(s) that are fully
  engaged, and marked with a manufacturers
  minimum breaking strength/force (MBS/MBF) rating
  on the link that is equal to or greater that the
  GVW of the trailer(s), are acceptable for use in
  a safety device.

34
2013 OOSC Changes - Part II

• 2. COUPLING DEVICES
• Justification This change authorizes the use
  of a quick-link marked with a manufacturers
  minimum breaking strength/force on a trailer
  safety device. This change does not change the
  fact that a quick-link is not acceptable for
  the purpose of cargo securement.

35
2013 OOSC Changes - Part II

• 2. COUPLING DEVICES
• g. Hitch Systems (Excluding Fifth Wheels and
  Pintle Hooks)
• Mounting and Integrity
• (1) Loose mounting, missing, or
  ineffective fasteners, or insecure latch.
  (Trailer 393.70(c) or Driveaway 393.71(h))
• NOTE A fastener is not considered missing if
  there is an empty hole in the device but no
  corresponding hole in the frame and vice versa.

36
2013 OOSC Changes - Part II

• 2. COUPLING DEVICES
• g. Hitch Systems (Excluding Fifth Wheels and
  Pintle Hooks)
• Mounting and Integrity
• (2) Cracks anywhere in the hitch system
  including mounting surface and frame cross
  member. (Trailer 393.70(c) or Driveaway
  393.71(h))

37
2013 OOSC Changes - Part II

• 2. COUPLING DEVICES
• g. Hitch Systems (Excluding Fifth Wheels and
  Pintle Hooks)
• Mounting and Integrity
• (3) Any welded repairs to the ball,
  ball-socket, pin or eye. (Trailer 393.70(c) or
  Driveaway 393.71(h))

38
2013 OOSC Changes - Part II

• 2. COUPLING DEVICES
• Justification This change creates a new
  section in the COUPLING DEVICES section of the
  OOSC that addresses hitch systems, other than
  fifth wheels and pintle hooks, such as ball
  hitches and pin hitches. In some cases, the
  previous OOSC did not cover such hitches, as
  language was specific to pintle hook type
  assemblies.

39
2013 OOSC Changes - Part II

• 2. COUPLING DEVICES
• h. Saddle-Mounts (Method of Attachment)
• (4) Horizontal movement between upper and
  lower saddle-mount
• halves exceeds ¼ inch (6.4 mm). (Upper
  393.71(j) or Lower
• 393.71(k))

40
2013 OOSC Changes - Part II

• 2. COUPLING DEVICES
• Justification This change corrects the metric
  measurement equivalent.

41
2013 OOSC Changes - Part II

• 7. SECUREMENT OF CARGO
• Inspection Guidance Interpretation 6

42
2013 OOSC Changes - Part II

• 7. SECUREMENT OF CARGO
• Justification This change inserts a reference
  to the newly created Inspection Guidance
  Interpretation 6. This directs the roadside
  inspector to guidance that has been issued
  addressing bungee cords and tarp straps being
  unsuitable for use as tiedowns, and equally being
  unsuited to having an assigned WLL. Furthermore,
  there is no intention to prohibit the use of
  these devices as supplementary restraint for
  light weight cargo and equipment.

43
2013 OOSC Changes - Part II

• 10. TIRES
• a. Any Tire on Any Front Steering Axle(s) of a
  Power Unit
• (6) Presence of rubber coated cord or
  cured rubber plug in the sidewall. (396.3(a)(1))

44
2013 OOSC Changes - Part II

• 10. TIRES
• Justification This change identifies the use
  of a rubber coated cord or cured rubber plug as
  an unapproved method to repair the sidewall of a
  tire and furthermore constitutes an imminent
  hazard.

45
2013 OOSC Changes - Part II

• 10. TIRES
• a. Any Tire on Any Front Steering Axle(s) of a
  Power Unit
• Re-numbering of conditions (7), (8),
  (9) and (10) due to the adoption and insertion
  of (6) Presence of rubber coated cord or cured
  rubber plug in the sidewall. (396.3(a)(1)). No
  change to conditions (7), (8), (9) and (10) was
  involved in this re-numbering.

46
2013 OOSC Changes - Part II

• 10. TIRES
• b. All Tires Other Than Those Found on the
  Front Steering
• Axle(s) of a Powered Unit
• (10) Presence of rubber coated cord or
  cured rubber plug in the sidewall.
  (396.3(a)(1))

47
2013 OOSC Changes - Part II

• 10. TIRES
• Justification This change identifies the use
  of a rubber coated cord or cured rubber plug as
  an unapproved method to repair the sidewall of a
  tire and furthermore constitutes an imminent
  hazard.

48
2013 OOSC Changes - Part II

• 10. TIRES
• b. All Tires Other Than Those Found on the
  Front Steering
• Axle(s) of a Powered Unit
• Re-numbering of condition (11) due to the
  adoption and insertion of (10) Presence of
  rubber coated cord or cured rubber plug in the
  sidewall. (396.3(a)(1)). No change to condition
  (11) was involved in this re- numbering.

49
2013 OOSC Changes - Part II

• 10. TIRES
• Inspection Guidance Interpretation 2

50
2013 OOSC Changes - Part II

• 10. TIRES
• Justification This change inserts a reference
  to Inspection Guidance Interpretation 2. This
  directs the roadside inspector to guidance that
  has been issued addressing the presence of an OOS
  condition on a tire or rim and the driver or
  owner has either singled out the axle or has
  removed the wheels and chained up the axle.

51
2013 OOSC Changes - Part II

• 14. EMERGENCY EXITS AND/OR ELECTRICAL
  CABLES AND SYSTEMS IN ENGINE AND BATTERY
  COMPARTMENTS (BUSES)
• a. Emergency Exits
• Required and/or marked emergency exits that
  are missing, inoperative (does not open,
  close, and/or secure as designed), or
  obstructed. (393.62)

52
2013 OOSC Changes - Part II

• 14. EMERGENCY EXITS AND/OR ELECTRICAL
  CABLES AND SYSTEMS IN ENGINE AND BATTERY
  COMPARTMENTS (BUSES)
• Justification This change ensures that all
  marked emergency exits are in working order and
  further provides clarification on what conditions
  constitute an inoperative emergency exit.

53
2013 OOSC Changes - Part II

• 14. EMERGENCY EXITS AND/OR ELECTRICAL
  CABLES AND SYSTEMS IN ENGINE AND BATTERY
  COMPARTMENTS (BUSES)
• b. Electrical Cables and Systems in Engine and
  Battery Compartments
• Removal of (2) Loose or corroded
  connections at battery posts. (393.28) as
  an OOS condition.

54
2013 OOSC Changes - Part II

• 14. EMERGENCY EXITS AND/OR ELECTRICAL
  CABLES AND SYSTEMS IN ENGINE AND BATTERY
  COMPARTMENTS (BUSES)
• Justification This change was adopted since
  loose or corroded connections at battery posts do
  not constitute an imminent hazard and are not
  likely to cause an accident, breakdown or fire.

55
2013 OOSC Changes - Part II

• 14. EMERGENCY EXITS AND/OR ELECTRICAL
  CABLES AND SYSTEMS IN ENGINE AND BATTERY
  COMPARTMENTS (BUSES)
• b. Electrical Cables and Systems in Engine and
  Battery Compartments
• Re-numbering of conditions (2), (3), (4)
  and (5) due to the removal of (2) Loose
  or corroded connections at battery
  posts. (393.28). No change to conditions (2),
  (3), (4) and (5) was involved in this
  re-numbering.

56
2013 OOSC Changes - Part IV

• 1. OPERATING AUTHORITY
• Operating a motor vehicle without the required
  operating authority or beyond the scope of the
  motor carriers operating authority. (Authority
  Required 392.9a(a)(1) or Beyond Scope
  392.9a(a)(2)) Declare vehicle out-of-service
  until the proper operating authority is obtained.

57
2013 OOSC Changes - Part IV

• 1. OPERATING AUTHORITY
• Justification This change clarifies that a
  motor carrier is required to obtain the proper
  operating authority that the movement or cargo
  requires, rather than proper operating authority
  required for a different movement or cargo.

58
2013 OOSC Changes - Part IV

• 2. MEXICO DOMICILED CARRIERS OPERATING IN THE
  U.S.
• A Mexico-domiciled carrier (USDOT X Number)
  granted provisional operating authority pursuant
  to 49 CFR 365 operating a commercial motor
  vehicle in the United States that does not
  display a current CVSA decal on the power unit.
  (385.103(c)) Declare vehicle out-of-service until
  the vehicle satisfactorily passes an inspection
  and a CVSA decal is issued.

59
2013 OOSC Changes - Part IV

• 2. MEXICO DOMICILED CARRIERS OPERATING IN THE
  U.S.
• Justification This change corrects the conflict
  between the OOSC and the specific direction
  outlined in the Federal Motor Carrier Safety
  Administrations (FMCSA) August 29, 2011
  Inspection Policy Memo. In this memo, the FMCSA
  has interpreted the CVSA decal requirement
  outlined in the law established by the U.S.
  Congress under the previous Demonstration
  Project to mean only power units, and not
  trailers, would require a valid CVSA decal.

60
2013 OOSC Changes - Part IV

• 3. U.S. FEDERAL OUT-OF-SERVICE ORDERS
• Operating a commercial motor vehicle while an
  existing motor carrier out of service order,
  issued by the Federal Motor Carrier Safety
  Administration (FMCSA) is in effect. (Choose from
  the list of fourteen Sections of the Federal
  Motor Carrier Safety Regulations (CFRs) listed
  below.) Declare vehicle out-of-service until such
  time as the motor carrier out-of-service order
  issued by FMCSA has been satisfied.

61
2013 OOSC Changes - Part IV

• 3. U.S. FEDERAL OUT-OF-SERVICE ORDERS
• Justification This change serves as
  clarification and removes confusion as it relates
  to inspecting a combination of vehicles and a
  U.S. Federal Out-of-Service Order has been issued
  for the motor carrier.

62
2013 OOSC Changes Qualifying for CVSA Decals

• Raised Lift Axle(s)
• Raised lift axles are to be inspected to ensure
  all components are secure and for conditions that
  adversely affect the vehicles operation (i.e. air
  leaks, etc.). If a Critical Vehicle Inspection
  Item defect is discovered on the raised axle, the
  vehicle is not eligible to receive a CVSA decal
  and the defect should be documented in the notes
  section of the inspection report. The raised lift
  axle shall not be included in determining the
  total number of brakes in a vehicle combination
  for the 20 percent service brake calculation. If
  the raised lift axle is required to be lowered to
  comply with regulatory requirements in order
  to continue operation, the operator has the
  option to adjust or offload cargo. Otherwise the
  axle is subject to inspection.

63
2013 OOSC Changes Qualifying for CVSA Decals

• Raised Lift Axle(s)
• Justification This change adds CVSAs Raised
  Lift Axle(s) policy to the OOSC, providing
  guidance to the roadside inspector on how a
  raised lift axles should be treated when
  encountered during an inspection.

64
2013 OOSC Changes Qualifying for CVSA Decals

• Vehicle Re-Inspections
• A Critical Vehicle Inspection Item violation(s)
  (OOS or otherwise) noted during a CVSA Level I
  inspection that is successfully repaired on-site
  and re-inspected by the same inspector at the
  same inspection location will qualify for a CVSA
  decal as long as all previously noted Critical
  Vehicle Inspection Item violation(s) have been
  properly repaired. In such instances, only a
  re-inspection of the repaired violation(s) shall
  be done with decal(s) being applied to the
  vehicle(s) and properly noted on the original
  inspection.

65
2013 OOSC Changes Qualifying for CVSA Decals

• Vehicle Re-Inspections
• Any vehicle that is repaired off-site or
  inspected by a different inspector shall be
  required to have a complete inspection conducted
  in order to obtain a CVSA decal.
• Justification This change updates and
  reflects the changes to the Qualifying for CVSA
  Decals Vehicle Re-Inspections policy and when a
  vehicle will and will not qualify for a CVSA
  decal after a Critical Vehicle Inspection Item
  violation(s) is discovered during a CVSA Level
  I Inspection.

66
2013 OOSC Changes Inspection Bulletins

• Inspection Bulletins
• 2012-07 Driver Possession of a Valid Medical
  Certificate (Created 09-27-12)
• 2012-06 Intermodal Equipment Provider Marking
  Options
  (Revised 08-15-12)
• 2012-05 Automatic On-Board Recording Devices
  (AOBRDs) Hand-Held
  (Created 06-06-12)

67
2013 OOSC Changes Inspection Bulletins

• Inspection Bulletins
• 2012-04 Hydraulic Brake System Inspection
  Procedures (Created 04-26-12)
• 2012-03 Antilock Brake Systems (ABS)
  Inspections (Revised
  04-26-12)
• 2012-02 Brake Pedal (Valve Treadle Assembly)
  Inspections
  (Created 02-01-12)

68
2013 OOSC Changes Inspection Bulletins

• Inspection Bulletins
• Justification This change updates the list of
  inspection bulletins in the OOSC with the new
  inspection bulletins that have been either
  created or revised in 2012.

69
2013 OOSC Changes Inspection Guidance

• Frequently Asked Questions
• INTERPRETATION 6 Can a bungee cord or tarp
  strap be used as a primary means of securing an
  article of cargo and does it need to be rated and
  marked with a working load limit (WLL)?
• ANSWER Bungee cords and tarp straps are not
  suitable for use as tiedowns, and are equally
  unsuited to having an assigned WLL. There is no
  intention to prohibit the use of these devices as
  supplementary restraint for light weight cargo
  and equipment.

70
2013 OOSC Changes Inspection Guidance

• Frequently Asked Questions
• Justification This change updates the OOSC
  with new guidance for the roadside inspector
  relating to cargo securement and the use of
  bungee cord or tarp strap.

71
2013 OOSC Changes

• END OF 2013 OOSC UPDATES