Changing Procedures for Transporting Auto Hulks Possible

Transporting auto hulks could become a trickier proposition if a policy being implemented passes through its hearings. The policy, while being debated in Canada, will cover all three NAFTA countries – the United States, Canada and Mexico. Spokespersons for both ISRI and the Canadian Association of Recycling Industries (CARI) say that Mexico has already indicated that its government will “sign off” on any policy adopted by its two northern neighbors.

For shippers of auto hulks, the policy, if implemented in its existing form, could affect the way companies move flattened cars to shredder yards. 

Background

Trade and quasi-governmental organizations have been working together this decade to compile a set of rules and regulations with the aim of maximizing safety standards when shipping large, heavy or otherwise difficult loads by truck. The Commercial Vehicle Safety Alliance (CVSA), Bethesda, Md., and the Canadian Council of Motor Transport Administrators (CCMTA), Ottawa, were the two lead groups that combined to author and administer the North American Cargo Securement Standard.

The North American Cargo Securement Standard is a proposed set of regulations that would apply to shippers in the U.S., Canada and Mexico. Early this year the proposal began to gain momentum, as backers of the proposal attempted to get the new issue on the books within the next year. The primary goal of the proposal would be to create standards for transporting various materials on flatbed vehicles. Although much of the initial discussion has taken place with representatives from Canadian transportation agencies, any final decision will have an impact on the transportation of a wide range of materials in the NAFTA countries. 

Commodity types included in the proposal were: logs; dressed lumber; metal coils; paper rolls; concrete pipe; intermodal containers; automobiles, light trucks and vans; heavy vehicles, equipment and machinery; roll-on/roll-off containers; large boulders; and—important for scrap processors—flattened or crushed vehicles.

The proposed regulation, being discussed by the Canadian Council of Motor Vehicle Administrators, would require all cargo carried by a motor vehicle with a gross vehicle weight, gross vehicle weight rating or gross combination weight rating in excess of 10,000 pounds be secured in accordance with the provisions of this standard when the vehicle is operated on a highway. 

The CCMTA is the official organization in Canada for coordinating all matters dealing with the administration, regulation and control of motor vehicle transportation and highway safety. The group includes members from the federal government and all Canadian provincial and territorial governments, as well as associate members from more than 330 transportation-related organizations.

For trucks and the cargo they are hauling, the policy requires all cargo to be contained or secured so that it will not leak, spill, blow, fall from, fall through or otherwise become dislodged from the vehicle; or shift upon or shift within the vehicle to such an extent that the vehicle’s stability is adversely affected.

The Institute of Scrap Recycling Industries and the Canadian Association of Recycling Industries, in a hearing last month (May 8), concurred with most of the drafting committee on four options to secure flattened vehicles. However, the two trade associations feel that in addition to the four options, there should be an alternative method to cover crushed vehicles. These methods would still restrict parts and pieces from falling from the vehicle.

The options now available are having flattened or crushed automobiles transported in vehicles that meet one of the following criteria:

l have structural walls on four sides which extend to the full height of the load and block against movement of the cargo in the forward, rearward and lateral directions

l have structural walls on three sides that extend to the full height of the load and which block against movement of the cargo in the forward, rearward and one lateral direction. In addition, a minimum of two indirect tie-downs are required per vehicle stack with every tie-down having a minimum working load limit of 5,000 pounds.

l Or, it is acceptable to have structural walls on two sides which extend to the full height the load and which block against movement of the cargo in the forward and rearward directions. In addition, there is a minimum working load limit of 5,000 pounds

l A shipper can also employ a minimum of four indirect tie-downs per vehicle stack with every tie-down having a minimum working load limit of 5,000 pounds.

Additionally, according to the proposal, measures must be taken that prevent loose parts from falling from all four sides of the vehicle and which extend to the full height of the cargo. This system can be based on use of structural walls, sides or sideboards, or suitable covering material, alone or in combinations. The use of synthetic material for containment of loose parts is permitted.

Mike Mattia, director of risk management for ISRI, questions whether the use of sideboard would even be effective, considering the procedure has no background on which to be based.

Len Shaw, CARI’s executive director, also sees some uncertainty with the step. “There is no structural integrity. Is it going to be effective?” he asks.

According to the CCMTA, tiedowns, except for steel strapping, must be designed, constructed and maintained so that the driver of the vehicle can tighten them. All tiedowns and other components of a cargo securement system must be located inboard of the rub rails when a platform body is equipped with such a device. The requirement, however, does not apply when the width of the load extends to or beyond the rub rails.

According to Len Shaw, a proposal jointly submitted by ISRI and CARI is based on good crushing and loading practices and procedures.

While the associations were able to ask for modifications, the CCMTA—while not outright rejecting or approving the option—did not accept the proposal as presented, according to Shaw.

Although ISRI and CARI are looking for the inclusion of the scrap-based proposal, not all scrap processors are in agreement. One large handler of auto hulks feels it is time for the two associations “to move away from the rhetoric. They can and should be proactive.” He feels that if the scrap associations contest the regulation as it is right now they could delay the implementation of the policy, something, he feels, would not be beneficial to anyone. “It would slow down the process. In the interest of safety they should allow the regulation to continue through.”

The scrap company spokesman also notes that all other associations affected by the policy are on board and in agreement.

What is disconcerting for both ISRI and CARI was the way in which the two groups became aware of the position. Both Mattia and Shaw say that the “last minute” notification given to them prevented the two associations from working with their member firms to further define what would be considered good standards and practices as an alternative to tie-downs and the use of sideboards.

Despite not having enough time to compile the full complement of standards and best practices, Mattia noted one obvious step that transporters of auto hulks must take is to make sure trunks and hoods of vehicles being transported are either secured or removed prior to shipment.

Another step is to make sure there are no loose parts around the wheels, brake linings and molding, as well as other parts of the vehicle that may fall off the crushed car during transit.

While the group failed to accomplish its goal of getting its provision included, the two groups expect the issue to be revisited, if not with the CCMTA, then in the rulemaking portion of the case.

Shaw says it is unfortunate that the industry (scrap recyclers) was not able to participate. What the group has to do, he adds, “is educate the committee about what we do. Had they brought in the stakeholders we could have described in practice what it means to implement these rules.”

WHERE THE ISSUE STANDS

According to The Pulse, a newsletter published by CARI, the CCMTA plans to prepare a fourth draft with input from the Canadian consultations, other subsequent work and input from the meeting that was held last month. The information will be presented to the group’s board of directors and then passed on to the U.S.

The Pulse added that U.S. federal officials expect to release a Notice of Proposed Rule Making by this fall, and hope to have the standard complete by the middle of next year.

ISRI and CARI are anticipating continued discussions with the rulemaking parties in both Canada and the United States in this regard. Further discussions are expected in both subsequent CCMTA meetings, as well as during the comment period, tentatively scheduled for this fall.

The author is senior editor of Recycling Today.