In an update to an earlier news item (from the August issue of its newsletter "The Pulse") the Canadian Association of Recycling Industries (CARI) has recently reminded members of the new requirements of the North American Cargo Securement Standard (NACSS) that will come into force January 1, 2004. In particular, the securement and containment requirements for “flattened” automobiles were discussed.
In an effort of clarification and standard application, ISRI wrote to and received a response from the U.S. Department of Transportation. The following is a brief summary of the department’s reply.
Although no definition of a flattened or crushed car was included in the standard, vehicles that have been compressed into a solid log of fused metal using an Auto Logger or Logger/Baler are not subject to the section on flattened or crushed cars. It is assumed that this process will ensure that fused logs do not fall apart or shed metal during transport. Such “logs” are, however, subject to the general cargo securement requirements, which require that the cargo be secured to prevent it from leaking, spilling, blowing or falling from the commercial motor vehicle. This means any loose parts such as broken glass or plastics must be contained.
Similarly, vehicles that are being transported as a result of being wrecked in a crash or accident are not subject to the section on flattened or crushed cars. They are subject to the general cargo securement requirements.
“Sides” and “sideboards” are considered vertical barriers on vehicles used to transport flattened or crushed cars. If such vertical barriers are used as the means for preventing loose parts from falling from the vehicle, then they must not have any opening large enough to allow loose parts to fall from the vehicle. In other words the maximum size openings would correspond to the smallest loose parts or articles that the sides or sideboards are intended to prevent from falling from the vehicle. ISRI has provided its members with the example of using a containment barrier that has maximum openings of one inch. Even if no loose parts have fallen from a vehicle, an inspector could reasonably expect that a loose part of one inch diameter or less, on the floor of the trailer or on the load, could pass through the containment barrier, thereby contravening the standard.
It was also confirmed that the section of the regulation pertaining to roll-on/off and hook-lift containers does not apply to vehicles equipped with an integral securement system. An integral system is one whereby the roll-on/roll-off or hook-lift container is secured to the vehicle by front and rear hold down devices on the vehicle that are mated to the container and that provide securement of the complete vehicle.
Since the department considered a lugger box as “hoist-type” equipment, which is “separate and distinct from roll-off equipment”, it is not considered subject to the new regulation.
These are the expected interpretations that will come into effect in the U.S. starting on January 1, 2004. Since this is supposed to be a North American standard, CARI has requested Canadian officials confirm that the same interpretations will be used in Canada and will keep members informed.
To learn more about the Canadian Association of Recycling Industries (CARI-ACIR) Association Canadienne Des Industries du Recyclage, contact, Donna Turner 905 426-9313 or visit www.cari-acir.org