No bulkhead? Don’t forget to use a penalty strap

If your flatbed trailers are not equipped with bulkheads, header boards, or any other type of front-end structure that prevents the cargo from sliding into the cab, did you know that you need to use an extra strap or chain to hold the cargo in place?

Often referred to as a “penalty strap,” this extra tiedown helps secure the cargo to the deck and prevents it from sliding forward into the cab. The federal cargo securement rules in 49 CFR §393.110 require this extra tiedown if you’re not using a front-end structure to secure the cargo.

You may be asking, “But aren’t bulkheads required?” The answer is no, there are no federal regulations saying that trailers need bulkheads or any other kind of front-end structure. Under 49 CFR §393.114, front-end structures have to meet certain standards ONLY if you actually use them to help secure your cargo (i.e., by placing cargo up against them to help prevent forward movement). If you place your cargo up against the bulkhead, refer to that section to make sure your bulkhead is up to spec.

If your trailers don’t have bulkheads or you’re not placing your cargo up against them, then that extra strap or chain is required. The following table specifies the minimum number of tiedowns needed, based on cargo length, weight, and placement (and not taking into account the strength of the tiedowns):

IF the cargo: and it is: THEN use at least:
IS NOT prevented from moving forward by a bulkhead or other front end structure 5 feet (1.52 m) or shorter, AND
1,100 pounds (500 kg) or lighter
1 tiedown.
5 feet (1.52 m) or shorter, AND
over 1,100 pounds (500 kg)
2 tiedowns.
longer than 5 feet (1.52 m) but is 10 feet (3.02 m) or less, no mat­ter the weight 2 tiedowns.
longer than 10 feet (3.02 m) 2 tiedowns, plus 1 additional tiedown for every additional 10 feet (3.02 m) or part thereof.
IS prevented from moving forward by being placed against a front-end structure 1 tiedown for every 10 feet (3.04 m) or part thereof.

As you can see, for anything over 5 feet or 1,100 pounds, an extra strap is required if the cargo is not placed against a bulkhead to prevent forward movement.

Review your cargo securement practices and make sure your drivers are using the penalty strap when required. If they aren’t, they could be facing a costly “penalty” of their own — from roadside enforcement!

Other factors

Keep in mind that there are many factors affecting cargo securement — and many ways to secure cargo — in addition to the information presented above. Refer to the federal cargo securement rules in Part 393 for all the details. And remember that it never hurts to go beyond the minimum and err on the side of safety — use additional securement devices so the cargo remains secure even if one component of the system fails.