Since November 1998, the Canadian Association of Recycling Industries (CARI) has kept members informed about the developments of the North American Cargo Securement Standard (NACSS). This new standard is meant, as the name implies, to have one standard that is acceptable in all jurisdictions in Canada, the US and Mexico. This standard has been accepted in both Canada and the US and is in various stages of being implemented. Mexico has just recently become involved.
Essentially, cargo on commercial vehicles transported on public roads must be loaded in such a way that the cargo does not leak, spill, blow or fall off the vehicle and the cargo must be secured such that it does not shift and affect the vehicles stability and manoeuvrability. Specific sections on flattened and crushed vehicles and roll-on/off and hook lift containers impact the scrap industry. The standard can be found at www.ab.org/ccmta/ccmta (open the January 2003 Model Regulation Draft 5). Provinces are currently drafting their own regulations to implement this standard but consistent and uniform interpretation seems to be becoming a problem.
In the US the Federal Motor Carrier Safety Administration (FMCSA), the US Federal agency responsible for this regulation, has written to ISRI and, among other things, stated that vehicles that have been compressed into "logs" with logger/balers are not considered flattened or crushed vehicles and therefore are not subject to containment requirements. At a recent interpretation meeting in Albuquerque the FMCSA stated that it was in the process of completing a new "rule" which would incorporate such an interpretation. This interpretation has not been accepted by any Canadian jurisdiction. At that meeting it was also agreed that "lugger boxes" were not the same as roll-on/off and hook lift containers.
Recently Manitoba members raised the issue of "lugger boxes" since some CARI members have been stopped by provincial officials. The Manitoba official responsible for the NACSS confirmed that the loads had been stopped pursuant to NSC Standard 10, which can be found at www.gov.mb.ca/tgs/alerts/index This is the Manitoba form of the NACSS. He stated that Manitoba was working on a standard for luggers and that it could be in effect in September. At that time a company would receive one warning and then be subject to fines. The concern for Manitoba officials stems from the general provisions of the NACSS and they feel that luggers may not be secure.
CARI subsequently spoke with the Canadian Council of Motor Transport Administrators (CCMTA), who is the secretariat for the Canadian representatives. It plans to set up a conference call for the Canadian representatives of the NACSS (Region 5) to discuss interpretations as soon as the minutes of the Albuquerque meeting are received. CARI expressed its concerns about getting the same interpretation for the implementation of this standard as the US. Different interpretations could impact our competitiveness with US firms and may even, eventually, impact the availability of flattened vehicles. CCMTA confirmed that Manitoba had sent in some photographs of lugger boxes and had placed that issue on the agenda for discussion during the conference call meeting.
CARI was further told that it could make representation to the group at some point and, like some other industry sectors; CARI could propose a standard for lugger boxes, if there was determined to be a need.
CARI has and continues to work with ISRI on this standard. Presently, CARI is monitoring the interpretations of this standard and its application in different states and provinces. CARI seeks a consistent application in all jurisdictions.
Contact Len Shaw at firstname.lastname@example.org