Train the Trainer 101: Enforcement of Vehicle Weight and Load Securement Rules
In the past few months, I have received comments and inquiries from all over the U.S. regarding what appears to be stepped-up enforcement of both load securement and vehicle weight rules. It’s not unusual that these topics garner attention from the U.S. Department of Transportation when it comes to carriers, but this recent uptick seems to be for smaller commercial vehicles, mechanics trucks, pressure diggers, and bucket and digger derrick trucks.
Not all utility safety professionals may be up to date on this topic because DOT issues are not front-burner issues. Typically, the human resources department handles a driver’s qualification file and drug testing for the DOT. Drivers at utilities only spend a few hours a week on the road between calls and jobs, idling most of the workday. We recognize that there are utilities with rigorous DOT management programs for equipment and drivers, but generally we find a more lax daily inspection protocol among utilities and contractors than you would find with a carrier. That might be justified considering the time a utility truck spends in transit compared to a carrier that is preparing to put a rig on the road with two drivers for 20 hours a day over the next two weeks. But it’s not the rule, and mistakes or latitude over trucks can suddenly become a serious liability when one of those overlooked trucks loses a steering link as it is driven through a school zone full of first-graders.
Craft Worker Compliance
Recently there have not been any changes of note in the rules for vehicle weight and load securement; however, it appears that some of the latitude taken by utilities, if not given by the DOT, has caught the attention of those responsible for enforcement of the rules.
In the last couple of years, state enforcement agencies used local media to inform local commercial businesses – that are not carriers – that they would be stopped if they did not appear to comply with loading and marking standards for their class of vehicles. In Arizona, New Mexico, Washington and Colorado, my colleagues and I began to hear of roadside stops involving lawn maintenance companies and small construction concerns that were pulling dual-axle, 5-ton trailers behind a Ford F-350, carrying loaders, backhoes and super lawn machines. That soon extended to power company trucks, especially those loaded with large wire reels. I even heard of one instance in which state enforcement set up scales in a shopping center parking lot on a well-known route out of a power company service center. Within 40 minutes they cited 22 vehicles for being overweight. You would think drivers would have warned others, but the DOT waved them into the parking area before they started weighing and inspecting the vehicles, so no one knew what to expect. It shouldn’t have been – but it was – a big surprise for that utility’s fleet management to learn what kind of loads lineworkers were putting on those trailers.
That is part of the problem. Craft workers – meaning lineworkers, cable splicers and tree workers – are licensed as CMV Class A operators. They take the same exams and demonstrate the same skills to become licensed as any other commercial truck driver. However, skilled craft workers who also are CDL drivers seem to lack the level of driver safety compliance of full-time carrier drivers. It’s informal, but as we have surveyed colleagues in the utility and utility contractor industry, the frequency and types of violations reported in the Federal Motor Carrier Safety Administration’s Safety and Fitness Electronic Records (SAFER) System (https://safer.fmcsa.dot.gov) show a troubling lack of compliance among craft drivers. The top violations of the Behavior Analysis Safety Improvement Category (BASIC) among utility drivers are vehicle inspections, trailer brakes, vehicle weight, lighting and reflectors. These compliance violations are an easy problem to remedy with training and reminders. Craft workers must understand that when they settle into the seat of that Class 7 vehicle, they are DOT drivers, not craft workers.
Fleet managers should also be aware that, as of July 2017, Federal Motor Carrier Safety Regulations (FMCSR) have been updated and violation codes have been added. Among them are speed and weight class violations for tires, including de-rating of speed and weight class of tires for underinflation. Overloading of tires brings us to both an existing problem and an emerging problem. The existing problem is drivers’ understanding of vehicle and trailering weights, as well as load balancing on trailers. Without being too critical of craft workers, it seems that if a load will fit on a trailer, it goes to the worksite. As a longtime safety auditor, I have found numerous instances of heavily overloaded trailers. In those cases, I found some fairly common reasons for the conditions. For instance, there is an unsafe tongue weight, usually starting at about 15 percent of the trailer’s loaded weight. Yet I have seen trailers loaded with 10 45/5 wood poles, all laying in the same orientation on the trailer, placing some 35 percent of the trailer weight on the tongue. Someone may have done it, but I have never seen a lineworker or operator turn one layer of poles in the opposite direction to balance the trailer load. Just because the pintle will hold the weight doesn’t mean it’s a safe plan.
Misunderstanding of GVWR
Misunderstanding a truck’s gross vehicle weight rating (GVWR) is easy to do. Power units are relatively simple. They are designed to trailer by fifth wheel, and the gross combined vehicle weight rating (GCVWR) is listed right there on the door. Utility trucks often are purchased as chassis cabs with doorplates defining the GCVWR and curb weight of the chassis. Some chassis manufacturers – but not all – list the GCVWR, which is the chassis, payload for the chassis and maximum towing capacity. Once the truck is configured with booms and bodies, the curb weight changes dramatically and so does the payload capacity. Not all equipment manufacturers replace the doorplates, so the truck arrives with the wrong information on the door. Without curb weight, the trailering capacity is unknown. If the chassis does not have GCVWR listed, no one will know the capacity of the vehicle for trailering. Add to that the loading of storage bins, and the curb weight is not known. Since the combination weight rating is established by the braking capacity, this issue of overweight truck-trailer combinations can be a serious one on the road.
There is another issue with trailers and loading. Each truck’s GVWR is a combination of curb weight and payload. Payload also includes trailer tongue weight on the truck’s hitching system. Tongue weight is ideally suited to be 10 to 15 percent of the total and trailer load weight. If a trailer always carries the same load, such as a backhoe, the trailer can be configured for the weight, and the stops on the deck can assure the load on the trailer is properly balanced for the tongue weight of 10 to 15 percent. However, if utility trailers are used, they can be loaded in any number of loads and balances, often overloading tongues. Overloading a trailer tongue can compromise steering and stopping and increase risks, especially in emergency maneuvers.
Fleet managers should have a program for loading and rating that makes it easy for drivers to match trailers with trucks. Truck doorplates should have GVWR, GCVWR and curb weight of the straight truck with booms mounted and bins loaded. Truck bumpers should be labeled with the maximum trailer weight. Ideally, a single-point scale should be placed in the yard so that drivers can pull up and drop the trailer’s landing gear onto the trailer to see what the tongue weight is.
For trailers, GVWR, curb weight and load rating should be marked. Tires should be purchased to meet the weight/speed loads expected on both trucks and trailers. Finally, locate a scale to weigh trucks and axle loads, whether in the yard or off-site. Drivers and foremen should be trained, and each truck should have an information card to show axle weight limits for that specific truck.
CDL Operator Class
The FMCSR as well as most state driver’s license books have pictograms that show silhouette shapes of trucks represented in GVWR classes. With advances in suspension, engine output and rear-end ratios, trucks can haul more than ever. This can lead to some surprise roadside inspection outcomes and really mess with your BASIC scores. For instance, trucks under 10,001 pounds are GVWR Class C and are not regulated by FMCSR. In the past, Ford F-350s and Chevrolets were generally considered exempt from FMCSR. However, a quick look at the load and trailering schedules on these manufacturers’ websites show that F-350s and the GM 3500 series, with the right combinations of suspension, transmission, power plant and rear-end ratios, now can trailer 30,000 pounds. That means that in these extreme rigs, the chassis are now rated as GVWR Class 7 vehicles. If that’s the case, your F-350s must meet all of the requirements of any CMV for inspections, safety equipment, markings, driver qualifications and so on.
Load securement – as it pertains to miscellaneous small items laying in truck beds – is the last item we’ll discuss in this issue. Even though all vehicles under city codes can be cited for losing loads, we must look at load securement from the FMCSR perspective. Load securement has gained focus in large part due to two events that occurred in early 2018 and made national news. Materials from commercial vehicles left the beds of trucks, bounced across narrow medians and entered the windshields of cars passing in the opposite direction. On both occasions, the cars’ drivers were struck in the head; one of the drivers died and the other is permanently disabled. The items that bounced out of the truck beds were a steel wedge about 14 inches long and a 5/8-inch-by-22-inch DA bolt. The owners of the lost materials were never identified, but load securement enforcement for lighter trucks is ramping up across the nation. My colleagues and I recently heard that in New Mexico, enforcement informed a utility contractor that a 2-inch-by-6-inch plank is not considered load securement. These planks often are fitted across the tail-end of crew trucks, bucket trucks, mechanics trucks and line trucks, as well as stair and ladder access points. The rule of thumb is if an item can bounce off, it is not secured. Fleet managers should look at their trucks for these small-item control issues and get ahead of the enforcement curve, not in the least to prevent injuring someone from the loss of a pole-top pin at 60 mph. The solutions are many, but we have seen larger solid barriers on sides and rear decks, as well as cargo nets and tarps fitted over pickup, crew and mechanics trucks.
About the Author: After 25 years as a transmission-distribution lineman and foreman, Jim Vaughn, CUSP, has devoted the last 20 years to safety and training. A noted author, trainer and lecturer, he is a senior consultant for the Institute for Safety in Powerline Construction. He can be reached at email@example.com.
Editor’s Note: “Train the Trainer 101” is a regular feature designed to assist trainers by making complex technical issues deliverable in a nontechnical format. If you have comments about this article or a topic idea for a future issue, please contact Kate Wade at firstname.lastname@example.org.