Question 1: When securing cargo, is the use of a tiedown every 10 linear feet, or fraction thereof, adequate?

Guidance: Yes, as long as the aggregate strength of the tie-downs is equal to the requirements of §393.102, and each article is secured.

Question 2: Are CMVs transporting metal objects required to use option C?

Guidance: Only those CMVs which cannot comply with options A, B, or D, are required to conform to option C (see §393.100(c)).

Question 3: Are the requirements of §393.100 the only cargo securement requirements motor carriers must comply with?

Guidance: No. A motor carrier, when transporting cargo, must comply with all the applicable cargo securement requirements of subpart I and §392.9.

Question 4: Do the rules for protection against shifting or falling cargo apply to CMVs with enclosed cargo areas?

Guidance: Yes. All CMVs transporting cargo must comply with the applicable provisions of §§393.100-393.106 (subpart I) to prevent the shifting or falling of cargo aboard the vehicle.

Question 5: How many tiedowns are required for the transportation of logs on pole trailers with trip-bolsters or other stanchions?

Guidance: The regulations do not specify a minimum number oftiedowns.§393.100(b) provides motor carriers with several options for complying with §393.100. Although option B specifically addresses the use of tiedowns for each 10 linear feet of lading or fraction thereof (with certain exceptions), option D indicates the motor carrier may use ‘‘other means * * * which are similar to, and at least as effective * * *’’ as options A, B, and C. Therefore, the trip-bolsters or other stanchions in conjunction with securement devices meeting the requirements of §393.102 may (depending on the amount by which the logs exceed the length of the trailer) be used to satisfy option D.

Question 6: Are logs which are bundled together with tie-downs and transported on pole trailers with trip-bolsters or stanchions required to be fastened to the vehicle?

Guidance: Yes. Generally, cargo is not considered to be secured in accordance with subpart I of part 393 unless tiedowns or other securement devices prevent the cargo from moving relative to the vehicle. Two rules in §393.100 are directly applicable to the transportation of logs on a pole trailer.

Sec. 393.100(b)(2), Option B, requires one tiedown assembly for each 10 linear feet of lading or fraction thereof. However, ‘‘a poletrailer* * * is required only to have two * * * of those tie down assemblies at each end of the trailer,’’ i.e., at the stanchions, because the cargo cannot effectively be secured at mid-trailer where its structure is limited to the pole or boom.

Sec. 393.100(b)(4), Option D, allows the motor carrier to use a securement system that is similar to, and at least as effective as Option B.

Sec. 393.100(d) states that the rules in §393.100 do not apply to the transportation of ‘‘one or more articles which, because of their size, shape, or weight, must be carried on special purpose vehicles or must be fastened by special methods.’’ However, since pole trailers are explicitly included in §393.100(b)(2), they are not special purpose vehicles and logs must be secured in accordance with §393.100(b).