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THE TLC COMPANIES Preventing Material Handling Accidents Driver Handout Preventing Material Handling Accidents Driver Handout Revised 09/01 DC00071

THE TLC COMPANIES Preventing Material Handling Accidents

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Page 1: THE TLC COMPANIES Preventing Material Handling Accidents

THE TLC COMPANIES Preventing Material Handling Accidents Driver Handout

Preventing Material Handling Accidents

Driver Handout

Revised 09/01 DC00071

Page 2: THE TLC COMPANIES Preventing Material Handling Accidents

Definitions:

Material Handling – Lifting or otherwise moving and/or securing materials for transport or removal from the vehicle.

Preventing Material Handling Accidents

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!

R e m e m b e r!

" If you see a problem, do something about it.

" That means, if you can’t

lift it, get help or use mechanical means for movement or transport. Don’t take chances. This will often cost you a serious injury.

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Causes of Material Handling Accidents

ccidents from material handling are often caused from the following:

" Getting in an out of the cab

" Lifting hoods

" Pushing and lifting materials

" Pulling Hand Trucks

" Lifting and Lowering Bay Doors

" Handling Lift Gates

" Securing Materials

Getting In and Out of the Cab This is perhaps the most dangerous task for truck drivers, since 1) it occurs often, 2) most drivers do not take the time to perform this task properly, and 3) drivers tend to be in a hurry when performing this task. Prevention Tips: " Never jump out of the cab, and be sure you have a secure grasp and

footing when doing this task.

" Use three points of contact, either one hand and two feet, or two feet and one hand.

" Be aware of outside conditions such as weather, condition of steps, handholds and deckplates, and ground condition that could cause you to slip or strain yourself.

" If you need to carry something into the cab or remove it, place it into a strapped bag for easier lifting and transport. Always maintain three points of contact.

" Maintain your balance

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1 A

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Lifting Hoods This task is often difficult, especially with older trucks in your fleet. Truck hoods can weigh more than 200 lbs., and this task must be done correctly to minimize injury. Prevention Tips: " Before lifting, unlatch the hood and pull up the corners to break the seal of

the hood alignment parts.

" Get a good grip on the hood and take a wide leg stance.

" Use your body’s momentum to bring the hood toward you so it opens safely.

" Always keep your back straight and maintain good balance.

" Be sure and check that your landing area is free from debris and slippery fluids.

Pushing There are many circumstances where drivers must load or unload by pushing carts, cages, dollies or other devices. Pushing requires use of many muscle groups, so it is important to take precautions in performing this task. Prevention Tips:

To get into your cab safely, you should have both hands free. Put anything you’re carrying into the cab first, and then climb in. Don’t try getting in with an armful; that’s asking for trouble. Most importantly, keep three points of contact with the vehicle at all times. To get out of your cab safely, never jump! Use the same procedures used to get in: exit with your body facing the vehicle, using the three-point rule. You also need to avoid bad habits such as swinging down from the cab or trailer, skipping or missing steps, and stepping up or down on fuel tanks and tires. And, slow down and take extra precautions—especially in bad weather.

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Coupling/Uncoupling " Do not step over air and electrical lines because you could lose your

footing or trip. It’s better to go under the lines or climb down and walk around to the other side.

" You need to be on firm footing when pulling the release handle, not only to avoid slipping, but also to avoid a back injury.

" Take precautions when adjusting the fifth wheel. Watch fingers, bumping heads, and slip/trips under the tractors. Walk around rather than jumping over air and electrical lines.

" Be aware that a tractor or trailer can sometimes move even with the brake on. Always chock the wheels.

If you need to climb up onto the tractor or trailer, maintain a secure footing and use three points of contact with handholds or other grips.

Loading/Unloading Special care needs to be taken on and around flatbeds. Whether loading, unloading, securing the load, checking tarps or other activities, you need to have at least three points of contact and be certain of your footing. Also:

" Use handholds and step up or down on the under-ride bar at the rear.

" Don’t jump or swing down from a flatbed.

" Never attempt to get onto the trailer by

putting one leg all the way into the trailer while the other is still on the ground. You could over-stretch and strain or even rupture your groin. Instead, use steps, bars

and a firm grip. Inspect the supports and take your time. On other types of trailers, such as van types, use the three-point rule with steps, rails and handholds.

" Use a flashlight in a dark trailer to avoid tripping on unseen objects.

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" Avoid walking backward, because by doing so you’re asking for trouble. If you must walk backward, stop and check your pathway frequently. When guiding another driver who is backing, check behind you often so you don’t trip.

" When climbing on a tanker, use care on ladders and walkways.

Remember, ladders and walkways are exposed to the elements and may become wet, icy and slippery, making footing unsafe.

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Weather Drivers will encounter a variety of weather conditions on a long haul. Before getting out of the cab, test footing by sliding a foot across the step or deck before climbing down. If it seems icy or slippery, use a long handled ice scraper or other appropriate tool to loosen and clear the surface. Take your time and use extreme

caution when exiting.

Housekeeping It is important to keep your truck’s windows and lights clean, but not at the expense of a slip or fall. Don’t climb on your vehicle to reach them, but carry a portable ladder. It is preferable to use a long-handled brush or squeegee rather than to climb a ladder. Keep one of these accessible for your use.

" Take action to identify and clean up spills when you see them. If it is not your responsibility, be sure to report them so action can be taken.

" Be aware of spills and debris in your trailer, loading

dock and in the shipping/receiving areas.

Housekeeping is the most common cause of accidents, and many of these involve slips, trips and falls. Be proactive in identifying and removing such hazards so that you or others do not experience accidents.

Loading Docks " Use handrails, rings and grips

" Never run up or down stairs

" Don’t carry objects obstructing your view

" Report unlit, poorly lit areas and unfavorable conditions to the shipping/receiving manager.

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" Other hazards to consider includes the “creeping” of your trailer away from the dock, leaving a gap between the dock and the trailer. Always chock your wheels. The height of your trailer may lower as cargo is loaded or rise as cargo is unloaded, creating a tripping hazard between the dock and the trailer. Also, make sure that the dock plate is properly positioned to avoid tripping.

Clothing

Clothing is another factor to consider in minimizing hazards. Avoid loose shirts, jackets and pants—clothing that could become snagged on projections, causing you to fall. Keep your shirt tucked in. Don't wear shorts, as shorts won’t offer any protection in the event of a fall.

Although wallet chains are popular, be aware the chain could catch on something and cause problems.

Footwear Good traction between your shoes and any surface is essential. Your shoes or boot soles should have ridges or ribs for better traction.

The best advice is to watch where you step so that you don’t get slippery liquids on your soles. It’s also best to avoid shoes with laces, but if yours have them, the laces should be double-tied or short enough to discourage tripping on them.

" Rubber-soled shoes with a tread provide some traction, but use caution.

" Spikes, studs and bolts in shoes provide good traction, but also damage floors.

" Shoes with grit-covered soles provide good, all-around traction, even on snow and oil.

To increase snow traction, consider strap-on cleats and non-skid sandals and boots that clip over shoes. They should be used when tying down loads in unfavorable weather. Plan outside loading/unloading during favorable conditions.

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Other Areas Where Slips, Trips and Falls May Occur Slips, trips and falls are not just limited to your rig, trailer or the loading dock. Be cognizant of those areas where many people are injured, not just drivers. These include the following: " Parking lots and sidewalks - look for:

! Cracked pavements and sidewalks

! Parking lot dividers

! Speed bumps

! Changes in elevation

" Stairways and ramps ! Poor lighting

! Damaged or uneven stairs

! Loose handrails

! Clutter or debris

" Public restrooms ! Watch out for water on slippery tile from sinks and showers

Key Tips for Avoiding Slips, Trips and Falls The two most important factors in avoiding slip, trip and falls are: " Awareness " Prevention Awareness means following a simple rule: If you see a hazard, correct it or report it so it can be corrected. " Always be on the lookout for potential problems and stay alert. " Become aware of changing weather conditions.

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bout 25% of all cases of workers being disabled result from back injuries. Back injuries are expensive to treat, account for more than 31% of all injury costs, and result in more than 900,000 back injuries each year.

As a truck driver, be aware of the following conditions and situations that make you vulnerable to strains, sprains and overexertion injuries: " Climbing in and out of your cab, and on and off trailers and docks. " Lifting and carrying materials " Pushing or pulling carts and dollies. Also, material handling results in a number of other injuries besides strains, including the following: " Slips, trips or falls " Striking against or stepping on materials and protrusions " Struck by falling materials " Caught in, on, or between object being handled The following information will help you, the driver; understand how material handling incidents occur, and how to prevent them. Remember; take responsibility for your own safety during situations and conditions that commonly cause these accidents – material handling accidents!

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4 A

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Purpose The purpose of this program is to train drivers in the importance of preventing injuries from material handling. The program and training will help to reduce strains, sprains and other over-exertion injuries, as well as struck by, against and caught-in, on, or between accidents. In addition, drivers become aware of the potential hazards involved with their job, even when they are not behind the wheel. The material handling program is designed to help drivers understand their role in accident prevention when loading/unloading, or otherwise moving materials either manually (by hand, using dollies, carts, etc.) or by use of mechanical means (hoists, forklifts, conveyors, etc.). The program is designed to assist both the experienced and “non-experienced” driver in avoiding or controlling those situations that will minimize material handling accidents.

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Objectives The objectives of this program are to provide key information to assist drivers in recognizing potential situations and conditions that cause material handling accidents, how and why these injuries occur, and measures to prevent them. For this program to be effective in reducing strains, struck by/against, caught in/on/between, and other accidents, drivers must: " Understand the responsibilities for handling and moving materials.

" Learn good body mechanics and lifting techniques.

" Learn correct methods for using material handling equipment (dollies, carts, forklifts, etc.).

" Receive training on this program and other related programs. Each driver

should: 1. Receive a copy of this program and sign-off acknowledging they read it, 2. Go through the training module either in a group or by individual, 3. View back injury prevention and load securement videos to assist in

understanding methods outlined in this program, and 4. Complete the materials handling exercise.

" Take action to implement measures to avoid conditions causing materials

handling accidents, and exercise proper methods and techniques to prevent injuries.

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Why Preventing Material Handling Accidents is Important to You You are a professional and you drive a truck for your livelihood, but in order to continue your job, you must be healthy – this means staying injury free, both in driving and non-driving situations. Drivers are very vulnerable to conditions and situations leading to material handling accidents and these often result in injuries such as cuts, lacerations, punctures, contusions, strains, sprains, etc. The consequences of a serious accident can be extreme pain, paralysis and even death. So don’t think this will not happen to you, because it happens to professional drivers every day, and is one of the leading causes of driver injuries at TLC Companies.

Keep in mind that the reason you will not learn this program or take this program seriously for one key reason: You think this type of accident will not happen to you. We can assure you that without understanding and implementing prevention measures, these injuries will happen, and hopefully they will not happen to you! Just think about the number of near miss or close-call accidents you experienced or the amount of pain you often live with simply because you do not exercise good lifting techniques, body mechanics and other methods to handle your loads properly.

We encourage you to take the time to read, understand and follow this program. It is for your benefit and safety. We also ask for any feedback and input you have regarding this program. Our goal is to keep it effective, up-to-date, and successful in our effort to reduce injuries among our drivers.

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Back Safety for Truck Drivers This section outlines key tasks for drivers in exercising special care to avoid back strains. The section also gives drivers specific methods, based on medical interpretation, to accomplish these tasks in a safe manner. Below are a summary of tasks that nearly all drivers perform, and tips for performing the task in a safe manner.

Driving

Driving can be strenuous since it involves sitting for long periods of time. Sitting creates pressure in the lower back region, and without stretching and periodic adjustments, can result in soreness or even permanent injury to your lower back. This also creates tension in the shoulder, forearm and upper arm.

Tips for performing this task:

" Stretch before and after you enter the cab. Perform stretching exercises reviewed in Appendix A, or follow your Doctor’s prescription.

" Maintain good posture while driving. Adjust seat properly and maintain lower back support. You should use a cushion, or if

unavailable, use a rolled-up towel. " Adjust eye movement each 3-5 seconds. " Vary posture periodically to reduce static positioning. " Take periodic breaks and stretch. Getting In and Out of the Cab

This is perhaps the most dangerous task for truck drivers, since 1) it occurs often, 2) most drivers do not take the time to perform this task properly, and 3) drivers tend to be in a hurry when performing this task. Although this requires the driver to pull him or herself up, you should also let your legs and knees, not your back, do most of the work.

Tips for performing this task:

" Never jump out of the cab, and make sure you have a secure grasp and footing when doing this task.

" Use the three-point contact, either one hand and two feet, or two feet and one hand.

" Be aware of outside conditions such as weather, condition of steps, handholds and deck plates, and ground condition that could cause you to slip and strain yourself.

" Keep your back straight. " Use a firm grip and be aware of your footing. " Maintain your balance.

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Lifting Hoods

This task is often very difficult and strenuous, especially with older trucks in your fleet. Truck hoods can weigh more than 200 lbs., and this task must be done correctly to minimize injury.

Tips for performing this task:

" Before lifting, unlatch the hood and pull up on the corners of the hood to break the seal of the hood alignment parts.

" Get a firm good grip on the hood and take a wide leg stance. " Use your body’s momentum to bring the hood toward you so it opens safely. " Always keep your back straight, and maintain good balance. " Be sure and check that your landing area is free from debris and slippery

fluids. Pushing

There are many circumstances where drivers must load or unload by pushing cages, carts and other devices. Pushing requires use of many muscle groups, so it is important to take precautions in performing this task.

Tips for performing this task:

" Determine the weight of the items you will be pushing and obtain the appropriate cart for the task.

" Place your arms shoulder length apart. " Use good leg extension so the big leg muscles do more work than your arms

and shoulders. " Maintain your balance. " Chart your course around obstructions and in a safe direction. " Keep good footing and get a good grip. " Lift with your shoulders and keep your back straight. " Remember, even though pushing can cause injuries, it is still better to push

correctly, than to pull. Pulling Hand Trucks

Drivers are often required to pull different types of dollies, hand trucks and hand jacks. Doing this increases the possibility of strain and sprain injuries, as well as other types. Pulling is generally more hazardous than pushing; so follow

these tips to minimize the possibility of injury.

Tips for performing this task:

" Use your legs, shoulders and back when pulling. " Get a firm grip, maintain good balance, and keep a wide stance.

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" Maintain good momentum when you are underway so you don’t get hung up on dock plates or inclines.

" Remove all obstacles from your path of travel. Chart your course. Lifting and Lowering Bay Doors

Sometimes a relatively simple task could leave people injured. Lifting and lowering trailer bay doors is a common task, but many drivers injure their shoulder or back. Sometimes they also experience struck by/against from falling cargo. Follow some good common sense principles in completing this task.

Tips for performing this task:

" Maintain a good stance. " Test the door so you know the amount of pressure you will need to apply. " Peek under the door to determine objects and cargo that have shifted or

fallen, so you can be prepared. " Use straps if available. " Get a firm grip. " Keep good balance. " Keep your back straight, using your legs as you are lifting or lowering the door. Handling Lift Gates

This is one of the more dangerous tasks involving material handling for drivers. If your trailer is equipped with a lift gate, you especially need to maintain good posture. Also, it is best to obtain assistance when possible.

Tips for performing this task:

" Place your legs shoulder width apart. " Keep good posture, maintaining a squat position when lifting and lowering the

gate. " Get a good grip. " Use proper footing. " Keep your back straight. " Get help when possible.

Two people completing this task are better than one!

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Key Back Safety Principles Back Safety For Truck Drivers (the previous section) outlined key tasks for drivers. Obviously drivers are not limited to these tasks, and driver potential for back strains will occur in a varied number of circumstances. These situations are different for all drivers and are usually dependent on the following: " Type of truck " Type of trailer " Responsibilities for loading and unloading " Types of products and materials, including weight and load " Equipment and tools available and used for product/material movement " Manual or mechanical means to move loads " Driver condition " Weather conditions " PPE (personal protective equipment) such as gloves, footwear, hard hats, etc. This section will outline key elements in back injury prevention for which all drivers should become aware. The summary or guide reviews important items concerning background, circumstances and preventative measures to assist you, the driver, to become more comfortable at your job, and to avoid injury. Back Disorders, Problems and Common Causes of Injury

The following causes most back and neck problems: " Poor body mechanics " Physical environment " Physical condition " Previous injuries " Attitudes/stress " Physical trauma Common Causes of Muscle Strains

" Lifting and twisting materials with your back versus pivoting with your feet " Prolonged static bent postures, or sitting in the driver seat for extended

periods of time, without movement, adjustments and stretching. " Sudden, jerking motions " Lifting beyond one’s strength, i.e., lifting materials that are too heavy without

help " Exceeding one’s flexibility limits by stretching or bending too far " Going to work or getting into the cab without warming up " Failure to stretch before moving cargo and other materials

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The Correct Way to Lift

The first way is to use your head (common sense), but also follow this guideline:

" Size up the load " Plan the job and check the path " Establish a base of support and get loose " Bend your knees

" Get a good grip " Keep the load close " Lift with your legs and keep the curves " Pivot, don’t twist Other Key Points to Remember

" Push, don’t pull " Keep loads away from danger zones (above shoulders and

below the knees increase chances of strains) " Plan rest stops; avoid muscle fatigue " Lift and lower the load slowly, using proper lifting techniques " Choose the safest and quickest route to your destination, but do not take

shortcuts through areas with hazards. " Do not reach to pick up an object " Tighten abdominal muscles to improve support of the spine " Don’t obstruct your view " Use assistive devices such as carts, dollies, pulleys, winches, forklifts, pallet

jacks, etc. when you have the opportunity " Break the load into smaller loads when possible " Ask for help and obtain help as often as possible, especially when moving

heavy and/or awkward objects " Good housekeeping is paramount to minimize back injuries as well as many

other types of injuries " Don’t twist, but move the load in a smooth motion. Don’t jerk the load. Exercise

Don’t forget, but you must consider some form of exercise, as this will minimize your chance of injury. Keep these points in mind, and follow this regimen: " Always warm up before you enter and after you exit your truck " Warm up periodically throughout the day, stretch each 1-2 hours " Vigorous exercise for 15-30 minutes 3 times a week (aerobics, running,

swimming, etc.) " Muscle tone exercise for 15-30 minutes 3 times a week (calisthenics, weight

training, etc.)

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General Health and Safety

" Diet $ Eat healthy food $ Limit the amount of fat, cholesterol and salt intake $ Avoid too much sugar

" Avoid/Minimize Smoking " Control Stress – Plan your trip and take breaks First Aid for Minor Back Pain

" Prompt Treatment Will Reduce Pain $ Ice pack on top of cloth for 20 minutes $ Use anti-inflammatory medication (ibuprofen)

" Rest is Important

$ Take pressure off your back $ Log rolling out of bed $ Bed rest for 24-48 hours, generally not longer

" Physical Activity

$ Restores function $ Reduces pain

" Questions for your Doctor – You must be informed!

$ What drugs have you prescribed for me, what are their effects and potential complications?

$ What can I do to prevent this from happening again? $ How long will you be treating me? $ When can I expect an update?

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Load Securement and Safe Material Handling Cargo damage and accidents are very real; with cargo damage claims (measured losses alone) surpassing 200 million annually. Injuries from material handling and improper securement are an obvious concern on both flatbeds and closed trailers, and result in a number of accidents. Typical types of accidents include the following:

" Strains, many to the back, but also to other areas of

the body. These are caused mainly by from lifting and moving materials, supplies and tarps.

" Sprains to the ankle(s), wrists, knees and other body parts.

" Struck-By from shifting and falling loads. " Caught-in, on, between materials.

" Slips, Trips and Falls These types of accidents cause a number of injuries, both minor and severe. Nearly all are caused by being in a hurry or inattention and cause the trucking industry billions of dollars each year. They have a definite impact on TLC Companies and its clients. Clearly, efforts must be made to reduce injuries from load movement and improper cargo securement. Cargo securement training can help drivers better understand and respond to factors that can reduce cargo damage and help to prevent accidents. Improper load securement is a major reason for rising costs to cargo damage, and loss of control of the tractor-trailer. Shifting cargo also causes many driver injuries. The importance of training for load securement is three-fold:

" Prevent cargo damage " Prevent vehicle accidents from shifting cargo, and " Prevent injuries caused by shifting and movement of poorly stacked secured

cargo. Drivers must become aware of the importance of cargo securement and their responsibility to protect and safely deliver their cargo without damage or injury.

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Why cargo securement is important and suggestions to prevent accidents Drivers should always follow good company practices for safe loading and unloading. In many instances, it may be your customer’s responsibility (i.e., warehouse or dock employee) to load or unload trailers. Regardless who loads or unloads, it is still your responsibility as the driver to check proper load securement and safety. These guidelines will help you. " Housekeeping is one of the least liked and often ignored tasks. Drivers must

get into the habit of checking empty trailers for debris before loading. Grab a broom and sweep out the debris. Nails, slivers of wood from pallets, broken objects and other materials are often culprits when it comes to cargo damage and injuries.

" Check all aspects of the load, from front to back. This includes damage,

stability, securement and general condition. If you are not loading, watch others so you are aware of the configuration. You may have to assist the loader with proper securement techniques. Refer to Federal Regulations for load securement (Part 393.100, Subpart I of FMCSR). This information is reviewed in Appendix A.

" Document all damage before you leave, but make it a habit to correct or

replace unsafe or damaged items. " The driver may not be involved in the selection of what goes into a trailer, but

if there is any apprehension about the loading or securement process, contents of the load, or other issues, bring them to the attention of the shipper, loading supervisor, dispatcher and/or other appropriate person.

" Effectively plan the load according to critical securement guidelines. This will

help prevent shifting cargo. The driver can often correct a shifting cargo problem by tightening tie downs, re-blocking and bracing or moving dunnage to add more protection. If you are unable to correct the problem on the road or at a scheduled stop, reposition and secure the cargo at the next delivery point.

" Be especially aware of the dangers of securing loads on flatbeds or any open

trailer. Here are just some of the hazards you will encounter: $ Slips/Trips/Falls from trailers $ Slips/Trips/Falls on trailers (particularly watch falling through tarps

between cargo and slipping on tarps) $ Falling and shifting materials $ Weather, including high winds

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Communication All drivers must be aware of cargo securement and how it influences them during the loading/unloading process and while driving. Among the measures to prevent cargo damage and injuries include the following:

" All employees should receive periodic cargo securement training.

This training should cover basic methods and procedures for loading, inspecting and unloading cargo.

" Once it is signed for, each driver is fully responsible for cargo. The driver must account for any loss or damage.

" Secure and protect cargo and people. Make sure you chain, block, brace, tie down and use other devices as required.

" Inspect cargo as good common sense and per FMCSR requirements and additional company guidelines. If in doubt, always ask for help and be certain the cargo is secure prior to leaving.

" Review and follow all company guidelines and policies regarding cargo securement.

" Schedule effectively. Less stops and less time on the road helps cargo reach its destination undamaged. When hauling fragile cargo, if possible, avoid known bad roads and routes with dangerous hills and curves. This will reduce the chances of falling cargo and an accident.

Driver Training Program

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Appendix A Federal Regulations for Load Securement Refer to Part 393.100 Subpart I of FMCSR. The regulations are briefly paraphrased in the driver’s workbook, but are reviewed in their entirety below: (b) Basic protection component. Each cargo-carrying motor vehicle must be equipped with devices providing protection against shifting or falling cargo that meet the requirements of either paragraph (b), (1), (2), (3), or (4) of this section. 1. Option A. The vehicle must have sides, sideboards or stakes, and a rear

endgate, endboard or stakes. Those devices must be strong enough to assure that cargo will not shift upon, or fall from the vehicle. Those devices must have no aperture large enough to permit cargo in contact with one or more of the devices to pass through it.

2. Option B. The vehicle must have at least one tie down assembly that meets the requirements of 393.102 for each ten linear feet of lading or fraction thereof. (However, a pole trailer or an expandable trailer transporting metal articles under the special rules in paragraph (c) of this section is required only to have two or more of those tie down assemblies at each end of the trailer.) In addition, the vehicle must have as many additional tie-down assemblies meeting the requirements of 393.102 as are necessary to secure all cargo being transported either by direct contact between the cargo and the tie-down assemblies or by dunnage which is in contact with the cargo and is secured by tie down assemblies. Tie down assemblies or dunnage in contact with sufficient exterior (including topmost) pieces of the cargo and securely holding each interior or lower piece will comply with this requirement.

3. Option C. (for vehicles transporting metal articles only) A vehicle transporting cargo which consists of metal articles must conform to either the rules in paragraph (b) (1), (2), or (4) of this section, or the special rules for transportation of metal articles set forth in paragraph (c) of this section. Paragraph (c) is special rules for metal articles. These rules apply to a number of metal items, such as coils (393.100 (3) AND Miscellaneous Metal Articles (393.100 (4). See both regulations for complete details, since securement of coils and metal articles are complex.

4. Option D. The vehicle must have other means of protection against shifting or falling cargo which are similar to, or at least as effective as, those specified in paragraph (b) (1), (2), or (3) of this section.

Revised 09/01 DC00071

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