Interpretation Response #19-0039
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
August 6, 2019
Director, Hazardous Materials Compliance
Landstar Transportation Logistics, Inc.
13410 Sutton Park Drive South
Jacksonville, FL 32224
Reference No. 19-0039
Dear Mr. Pace:
This letter is in response to your March 26, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the package securement requirements for highway transportation. Specifically, you include three photographs of packages containing hazardous material shrink-wrapped onto wooden pallets. The pallets are loaded side-by-side in a motor vehicle, with gaps of at least several inches between the pallets and between the pallets and the walls of the trailer. The pallets are not secured to the vehicle using straps, tie-down, load locks or other means, although you indicate that a means of securement will be used to prevent the pallets from shifting backwards toward the doors of the trailer. You ask whether the arrangement depicted in the photographs meets the requirements of § 177.834(a).
Based on the photographs and information provided in your email, we cannot definitively determine whether the load is secure. Section 177.834(a) requires any hazardous material package that is not permanently attached to a motor vehicle to be secured against shifting, including relative motion between packages, within the vehicle on which it is being transported under conditions normally incident to transportation. Conditions normally incident to transportation include vehicle starting, stopping, cornering, accident avoidance, and varied road conditions. Thus, the securement of hazmat packages requires that such packages do not shift when experiencing these conditions.
As shown in the photographs, the voids between the pallets and between the pallets and the sides of the trailer could allow the pallets to shift, and there is no securement mechanism in place to prevent the pallets from shifting in this way. Specific methods for securing packages in a motor vehicle are not provided in the HMR. However, various methods, such as tie-downs, using dunnage or other cargo, shoring bars, jack bars, or toe-boards would be acceptable to secure the pallets as long as they prevent shifting within the trailer.
I hope this information is helpful. Please contact us if we can be of further assistance.
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division