If you haul cargo on a flatbed, you have undoubtedly heard of the 10-foot rule: you need at least one tie-down for every 10 feet of cargo, plus an extra one if the cargo is not placed against a bulkhead. Although this “10-foot rule” (found in 393.10) addresses only how many tie-downs you need, it is generally understood to be a good directive about where to place your tie-downs as well. That is, most drivers believe you must have a tie-down situated within each 10-foot section of the load. As discussed below, that belief is not necessarily true.
First, let’s look at the rules themselves. In general, the North American Standard Cargo Securement Rules require you to use enough tie-downs so that their combined working load limit (WLL) is equal to at least one-half the weight of the cargo (or the full weight when using “direct” tie downs). Then, you may need additional tie-downs, based on the cargo’s length and weight, and whether or not the cargo is placed against a bulkhead. If the cargo is prevented from moving forward by being placed against a front-end structure, then you need to use at least one tie-down for every 10 feet or part thereof.
If your cargo is loaded in a way that it is not prevented from moving forward by a bulkhead or other front-end structure, there are some additional requirements. If the load is 5 feet or shorter and 1,100 lbs. or lighter, use at least one tie-down. If the load is 5 feet or shorter and over 1,100 lbs. then use at least two tie-downs. If the load is between 5 feet and 10 feet, no matter the weight, then use at least two tie-downs. And lastly, if the load is longer than 10 feet, use at least two tie-downs plus one additional tie-down for every additional 10 feet or part thereof.
So, how is the 10-foot rule enforced in the real world? Historically, the rule has been open to interpretation, with some officers claiming that tie-downs must be positioned every 10 feet no matter what, and/or that you must have two tie-downs within the first 10 feet if you don’t have a bulkhead. Guidelines from the CVSA (Commercial Vehicle Safety Alliance) of which I was a past member, should help clarify the rules and make the enforcement (hopefully) more uniform. The CVSA produces the Out-of-Service (OOS) Criteria, which are used to guide inspectors in determining whether a vehicle is safe to be on the road. The OOS Criteria says that tie-downs can either be spaced 10 feet apart along the length of the vehicle or positioned in every 10-foot segment of the cargo. The criteria also says that tie-downs should be spaced or grouped at lengths greater or less than 10 feet, to accommodate anchor points or prevent cargo damage.
This guidance is in agreement with the regulations which, again, do not specifically state that tie-downs must be positioned at every 10 feet. Of course, tie-downs should be evenly spaced whenever possible, and having one every 10 feet may make sense in most cases, but at least the CVSA recognizes that sometimes drivers need some flexibility when placing tie-downs. Now is a good time to review your cargo securement practices and make sure your drivers are aware of the 10-foot rule and the enforcement guidelines because cargo securement issues have the highest average per violation of CSA points.
Keep on mind there are many factors affecting cargo securement and many ways to secure cargo. In addition to the general information presented here, you can also take a number of official cargo securement courses that are offered by the US DOT’s Transportation Safety Institute on the NTA’s website. For all of the rules regarding proper cargo securement, refer to the federal regulations in Part 393 for all of the details. And remember, it never hurts to go beyond the minimum and err on the side of safety when securing cargo.
If you are registered in the International Fuel Tax Agreement (IFTA) and/or the International Registration Plan (IRP), you are required to keep distance records including the highways, cities and states/provinces where your vehicles are operating. The records must clearly show where the vehicle was operating and the distance it traveled in each jurisdiction. Because these records are used to complete IFTA returns and establish your IRP registration fees for the year, they must be detailed, legible and accurate. In the event of an audit, an IFTA/IRP auditor would compare your reported distances to those kept in your records. Given your current recordkeeping procedures, do your distance records sufficiently back up your IFTA and IRP reports? If not, you may want to take a closer look at how you can make sure you will be covered if an auditor comes to visit.
When auditing IFTA licenses and IRP registrants, auditors will look at the carrier’s internal control. For example, when drivers submit their trip reports, are the trips verified for accuracy? If there are no controls or checks on this information, auditors may want to dig further into your tax records or may question the validity of your records as a whole. In addition, auditors may want to verify that you are doing what you are saying you are doing. In other words, you might have a policy that clearly outlines what is expected of all parties responsible for IFTA/IRP recordkeeping, but are all of the parties actually following the policy?
Auditors may expect to see some level of checks and balances on the information you use for IFTA and IRP reporting. Some things you should look for in your distance records include: 1) missing odometer or hubometer readings; 2) “gap miles” as a result of missing odometer or hubometer readings or missing personal use distances; 3) inconsistent dates on trip reports; 4) a deviation between actual distances and distances on a map (or electronic mapping system); 5) fuel and other receipts that do not match up with the states stated on the trip report; 6) missing information on the driver’s trip report that may affect the accuracy of distance reports; and 7) errors related to incomplete or inconsistent routes due to illegible records. Remember, incomplete and/or erroneous distance records may open you up to severe assessments and penalties under both IRP and IFTA. Be safe!
