7.       Why was this added to the Loading Performance Standards? This statement implies that there are circumstances where the 0.2g vertical

acceleration can be ignored; and raises further questions:

8.       Where does 0.2g vertical acceleration now not apply?

9.       What does “limited vertical displacement” mean? Does the displacement refer to the load, vehicle, restraint system, or other, and where is

this defined?

10.      Is the displacement relative or absolute and what are its limits?

11.      Why was the definition of “g” removed from the Loading Performance Standards? This now enables the selection of any published

variation of “g”.

B)    Documentation of the Loading Performance Standards

 

LOADSAFE DISCUSSION PAPER 2

 

Ref:  Load Restraint Guide (Third Edition) and National Heavy Vehicle Law

 

The contents of this document are provided as complementary information to the Public, Industry and Government.


Loadsafe Australia has no vested or conflict of interest in relation to the NTC, National Heavy Vehicle Regulator or other stakeholders. 

 

Our intention is to continue to advocate for Load Restraint Standards and Guidance that allow Australia to remain a world-leader in the safe restraint of loads on heavy vehicles.

 

In early 2018, the National Transport Commission (NTC) published the 3rd Edition Load Restraint Guide. The following discussion paper contains questions and comments about the technical content, documentation and legal interpretation of the new Loading Performance Standards introduced with the Guide.

 

A)    Technical Content of the Loading Performance Standards

 

“(1) A load on a heavy vehicle must be restrained by a load restraint system that prevents the load from moving in relation to the heavy vehicle.”

 

1.       What is the definition of a “load”? Does it include all small components of a total load and parts of a vehicle that may dislodge or protrude

(spare wheels, gates, tyre tread, outriggers etc.)? Industry and Enforcement will benefit if this is defined and not debated.

 

​2.       Why were the load movement requirements changed from “limits” to “prevents"?

It is technically impossible to prevent load movement due to the flexible nature of all loads and vehicle decks.

 

Regulations of the 1980’s used this “no movement” concept, which Australia discarded in 1994 with the adoption of the Load Restraint Guide

 

“(2) However, a load may move in relation to a heavy vehicle if:

(a) the vehicle’s stability and weight distribution are not adversely affected by the movement; and

(b) the load does not become dislodged from the vehicle.”

 

3.      Why were these load movement requirements changed from those in the previous 2nd Ed. and Draft 3rd Ed. Performance Standards by the

introduction of the word “may”, (thereby adding further confusion for Industry and Enforcement)?​

“3. a bulk liquid load contained within the sides or enclosure of the heavy vehicle”.

 

Why was the previous reference to “limited liquid movement” removed?

 

4.       Why did the load movement requirements in (1) need to state, “a load restraint system that prevents the load from moving” and then in the

next paragraph (2) state the opposite “a load may move” and later in (3) state “must prevent the load from moving”?

 

5.       Why was the previous requirement that “the load restraint system must be capable of withstanding the forces that would result if th laden

vehicle were subjected to each of the following separately” changed? It now says in effect, that the load restraint system must prevent

load movement that is allowed!

 

“(3) The load restraint system must prevent the load from moving in relation to the heavy vehicle (other than movement allowed under (2)) if the loaded vehicle were subjected to:”

“(a) any of the following:

(i)  0.8 g deceleration in a forward direction;

(ii)  0.5 g deceleration in a rearward direction;

(iii) 0.5 g acceleration in a lateral direction; and”

 

6.       Why was the word “separately” in the 2nd Ed. and Draft 3rd Ed. Performance Standards deliberately replaced with the word “any”?  Does

this mean that “any one”, “any two”, or “any three” of the accelerations can be applied?

The Loading Performance Standards are now written in a way that diligent engineers would argue that accelerations should be added vectorially resulting in maximum horizontal requirements of 0.94g in the forward/sideways direction and 0.71g in the rearward/sideways direction.

However, the Loading Performance Standards are written in a way that individuals could argue for their own purposes that accelerations should be subtracted vectorially.  This would result in a reduced maximum horizontal requirement of 0.3g deceleration in the forward direction only.

 

“(b) if friction or limited vertical displacement is relied on to comply with (a), 0.2 g acceleration in a vertical direction relative to the load”.

New Loading Performance Standards

Questions Not Frequently Asked

“(2) However, a load may move in relation to a heavy vehicle if:

(a) the vehicle’s stability and weight distribution are not adversely affected by the movement; and

(b) the load does not become dislodged from the vehicle.

Examples of load movement that may be permitted under (2)”

 

12.     Why are the “Examples of load movement” examples of loads?

13.     Why use confusing paragraph numbering and presentation? (two “2’s” referenced)

 

“1. load contained within the sides or enclosure of the heavy vehicle that is restrained from moving horizontally may be able to move vertically;”

 

14.     Why use such grammar? (Is “load” or the “vehicle” restrained?)

 

15.     Why isn’t the terminology consistent with content of page 13 of the 3rd Ed. LRG? (“contained” should be changed to “contained or blocked”).

 

“2. a load of very light objects, or a loose bulk load, that is contained within the sides or enclosure of the heavy vehicle may be able to move horizontally and vertically;”

 

16.     Why replace “lightweight” of previous 2nd Ed. and Draft 3rd Ed. Performance Standards with “light”? (“lightweight” was previously used to

prevent confusion with loads of lights and loads of dark objects :)

C)    Legal Interpretation of the Loading Performance Standards

Page 8 of the LRG, refers to “Legal obligations”. Parts of this page are misleading because it is implied that the advice is linked to the Loading Performance Standards, but some of it is not.

It does not stick out of the vehicle in a way that could injure people, damage property or obstruct others’ paths.”

 

17.     Why was the above (third) “Legal Obligation” included without reference to its relevant Regulation?

 

“(3) The load restraint system must prevent the load from moving in relation to the heavy vehicle (other than movement allowed under (2)) if the loaded vehicle were subjected to:

 

18.     Has the Heavy Vehicle Regulator defined “loadas used in the Loading Performance Standards in Heavy Vehicle Law and where is this

published?

 

19.     Has the Heavy Vehicle Regulator defined “dislodgedas used in the Loading Performance Standards in Heavy Vehicle Law and where is

this published?

 

20.    Where is “g” now defined in National Heavy Vehicle Law, (it was defined in the 2nd Ed. Performance Standards)?

 

21.    What is the effective date (required for prosecution, litigation, certification, refund of fines etc.) of introduction of the new Loading

Performance Standards and where is this published?

The 3rd Edition LOADING PERFORMANCE STANDARDS

 

3rd Edition LOAD RESTRAINT GUIDE Page 4

Read More

KNOW YOUR LEGAL OBLIGATIONS

 

3rd Edition LOAD RESTRAINT GUIDE Page 8