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Issues Archives: Volume 1 – Issue 3

Issue 3

Road hazards—high visibility clothing and other PPE

Protecting employees working on or near a roadway should always be a number one safety concern. One way to do so is to provide your employees with the proper personal protective equipment (PPE). Selecting the proper PPE is more involved than employers may understand.

Hazard assessment

To determine the need for PPE, OSHA requires employers to conduct a hazard assessment per 29 CFR 1910.132(d). This hazard assessment must determine if hazards are present, or are likely to be present, that require the use of PPE. If such hazards are discovered, then you must select, and have each affected employee use, the types of PPE that will protect them.

When an employee is dispatched to assist/tow a vehicle there are several issues to consider:

  • What are the conditions? What is the visibility, weather, temperature, traffic?
  • What will the tow driver do at the scene? Work on the disabled vehicle onsite or tow it to a different location?
  • How close to the moving traffic will the employee be?

Answers to these questions will help you perform your hazard assessment.

Next, you have to communicate those PPE selection decisions to the workers and then find and fit the PPE for each affected employee.

Types of PPE

The hazard assessment should determine the need for the specific types of PPE. Some of those could include:

  • High-visibility apparel
  • Eye protection
  • Head protection
  • Foot protection
  • Hand protection
  • Cold-weather clothing
  • Hot-weather clothing
  • Other types of PPE

High visibility apparel—all workers (ANSI 107-2004)

When you dispatch a driver and tow vehicle to an accident scene make sure you provide the driver with the appropriate high-visibility safety clothing. This would include apparel that meets the Performance Class 2 or 3 requirements of the ANSI/ISEA 107–2004 publication.

The 2009 Edition of the Manual on Traffic Control Devices (MUTCD) states at Section 6D.03 Worker Safety Considerations, Standard 04:

All workers, including emergency responders, within the right-of-way who are exposed either to traffic (vehicles using the highway for purposes of travel) or to work vehicles and construction equipment within the TTC zone shall wear high-visibility safety apparel that meets the Performance Class 2 or 3 requirements of the ANSI/ISEA 107–2004 publication entitled “American National Standard for High-Visibility Safety Apparel and Headwear” (see Section 1A.11), or equivalent revisions, and labeled as meeting the ANSI 107-2004 standard performance for Class 2 or 3 risk exposure, except as provided in Paragraph 5. A person designated by the employer to be responsible for worker safety shall make the selection of the appropriate class of garment.

If you also dispatch a flagger to assist your driver, the MUTCD has specific requirements. Section 6E.02 High-Visibility Safety Apparel Standard 01 states:

For daytime and nighttime activity, flaggers shall wear high-visibility safety apparel that meets the Performance Class 2 or 3 requirements of the ANSI/ISEA 107–2004 publication entitled “American National Standard for High-Visibility Apparel and Headwear” (see Section 1A.11) and labeled as meeting the ANSI 107-2004 standard performance for Class 2 or 3 risk exposure. The apparel background (outer) material color shall be fluorescent orange-red, fluorescent yellow-green, or a combination of the two as defined in the ANSI standard. The retroreflective material shall be orange, yellow, white, silver, yellow-green, or a fluorescent version of these colors, and shall be visible at a minimum distance of 1,000 feet. The retroreflective safety apparel shall be designed to clearly identify the wearer as a person.

Any employee that is dispatched to an accident or breakdown scene must wear high-visibility safety apparel that meets ANSI 107-2004 standard performance for Class 2 or 3 risk exposure.

High visibility apparel—emergency responders (ANSI 207-2004)

The 2009 MUTCD also has an option for emergency and incident responders and law enforcement personnel. Section 6D.03 Worker Safety Considerations, Option 05 says:

Emergency and incident responders and law enforcement personnel within the TTC zone may wear high visibility safety apparel that meets the performance requirements of the ANSI/ISEA 207-2006 publication entitled “American National Standard for High-Visibility Public Safety Vests” (see Section 1A.11), or equivalent revisions, and labeled as ANSI 207-2006, in lieu of ANSI/ISEA 107-2004 apparel.

There is also a newer version of ANSI/ISEA 207-2006. It is the 2011 edition (ANSI/ISEA 207-2011). In Appendix B there are three examples of what is called the “public safety sector” vest. Examples one and two have areas on the vest where the identification text (Fire Service, EMS, Police, etc.) can be placed. The third option does not show any identification text.

What types of personnel are considered to be “emergency and incident responders and law enforcement personnel?” ANSI/ISEA 207-2011 discusses “Identification of Personnel” at section 6.3, which says that, “Public safety industries may be identified with the specific names and colors: Red: Fire Service; Green: Emergency Medical Service (EMS); Blue: Law Enforcement.”

With this said, it appears that only public safety personnel can wear the ANSI 207 class vests. Other employees must wear the ANSI 107 class vests.

These types of high-visibility safety apparel will help protect your employees. When an employee is getting a vehicle ready to be towed, the drivers in oncoming vehicles must be able to see, and take measures to avoid, that employee.

Eye protection

OSHA requires that appropriate eye protection be provided when there is a hazard from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation.

If you have employees that are working near moving traffic they could be exposed to road debris being picked up and thrown around. Also, crawling under and around vehicles can exposed them to dirt, road salt, and fumes that can fall into or enter the eyes.
Keeping the debris and related particles out of workers eyes is one of the main reasons to wear eye protection.

Safety glasses (either spectacles or goggles) are a common form of eye protection. If there is a severe hazard from flying objects then a face shield may also be necessary. At the least, safety glasses with side shields should be used.

OSHA requires that eye and face protection devices comply with the ANSI Z87.1-1989 or ANSI Z87.1-2003 consensus standards (American National Standard Practice for Occupational and Educational Eye and Face Protection).

Head protection

Hard hats must be worn when there is the potential for injury to the head from falling objects or bumping the head on an object. Crawling around and under vehicles can expose employees to these hazards. Every call may not require a hard hat to be worn; however, they should be available when needed.

OSHA requires that head protection comply with:

  • ANSI Z89.1–2003, American National Standard for Industrial Head Protection; or
  • ANSI Z89.1–1997, American National Standard for Industrial Head Protection; or
  • ANSI Z89.1–1986, American National Standard for Personnel Protection—Protective Headwear for Industrial Workers—Requirements.

Foot protection

Protective footwear must be worn by employees working in areas where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole, and where employees’ feet are exposed to electrical hazards. Wrecked vehicles shed parts and pieces that could certainly fall into these categories.

Protective footwear must comply with any of the following consensus standards:

  • ASTM F–2412–2005, Standard Test Methods for Foot Protection and ASTM F–2413–2005, Standard Specification for Performance Requirements for Protective Footwear; or
  • ANSI Z41–1991 or ANSI Z41–1999, American National Standard for Personal Protection—Protective Footwear.

Slipping and falling is another hazard that could be encountered, especially when working in icy conditions. There are specific types of devices that attach to boots that provide added traction in these conditions.

Hand protection

Appropriate hand protection must be used when employees’ hands are exposed to hazards such as those from skin absorption of harmful substances, severe cuts or lacerations, severe abrasions, punctures, chemical burns, thermal burns, and harmful temperature extremes. Wrecked vehicles often have hazards like these. In addition, handling chains and wire rope used to upright and tow vehicles can be hazardous.

Cold-weather clothing

Depending on location of your operations, the winter season may bring cold temperatures, rain, wind (and accompanying low wind chills), and snow and sleet. These hazards can lead to frostbite; hypothermia; and slips, trips, and falls.

In the winter months provide employees working outdoors with the proper outerwear, boots, headwear, and hand protection. In addition, certain winter conditions can result in reduced visibility, so high-visibility safety apparel can be a necessity.

Hot-weather clothing

The summer season can start early for some parts of the country. Hot-weather clothing is a must for employees working outdoors. Avoid dark-colored clothing and clothing that doesn’t breathe. Hats are recommended to be worn when working in direct sunlight.

Other types of PPE

In addition to the types of PPE mentioned, there may be additional categories needed. Examples of these could include respiratory protection and clothing treated with insect repellant.

Wrap up

Employee well-being is always a concern, especially for those working on or near a roadway. Your hazard assessment will determine which hazards are present, or likely to be present, that require the use of PPE by employees. Properly sizing and providing that PPE can send those workers home safely each and every day.

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A Star is Born

Western Star is known for providing the ultimate chassis solution for heavy wrecker applications.  To help promote their capabilities, the company decided to build a “monster wrecker” to display as its showcase truck during the 2012 Mid-America Trucking Show (MATS) and Florida Tow Show. Featuring superior cab room, nearly unlimited options for rear axle spacing and various front axle configurations including factory installed twin steer, the showcase wrecker demonstrates first-hand why Western Star is the premium solution in the towing and recovery market.

“I’ve interviewed a number of wrecker operators over the years that own Western Star trucks, and they all agree they don’t want to drive anything else,” said Guy Lemieux, segment manager, Western Star. “Many of these owners tell me that a 15-year-old Western Star cab remains rattle-free better than a one-year-old competitive model.”

Western Star coordinated with Don Trower of Tow Truck Country, a Dubuque, IA-based division of Western Star/JerrDan dealer Truck Country along with JerrDan engineers to spec the chassis for a 50-ton straight boom truck.

Starting with the engine, Western Star equipped its 4900EX, 132-inch BBC wrecker with a Detroit DD16® engine – the most powerful Detroit engine available – featuring 600 hp and 2,050lb-ft of torque, and an Eaton Fuller 20918B 18 speed transmission, which puts power to the rear axles. Cooling is provided by a 1750 sq/in copper & brass radiator.  The 4900EX wheelbase is 324”and features taperleaf front suspension rated at 20k with Airliner rear tandem suspension rated at 46k.  A 20k Hendrickson pusher is factory mounted to assist with heavy loads.

Customizing an equally impressive exterior, Chris Jory, manager, concept and prototype, Daimler Trucks North America, worked with Mick Jenkins of Twins Custom Coaches in Pomona, CA to create a custom scheme to further set it apart from others.  The layers of custom metal flake and clear were expertly applied by So-Cal’s legendary painter Pete Santini.  “Having the paint done by Pete, who hot rodders consider to be the best in the industry, was very important to the statement we wanted to make with this truck” said Andy Johnson, Western Star brand manager.  The severe service cab features Western Star’s plush, enhanced premium interior in green and grey.

Western Star’s classic traditional styling has always turned heads and the ‘60’s retro paint scheme takes this truck over the top.  And if that wasn’t enough, all the features that make a Star so durable like the galvannealed steel cab with two-piece windshield, rugged frame and bolted cross members ensure this truck will continue to turn heads for a long time.  The best way to put it, this is one badass wrecker!

For more information on Western Star’s 4900EX series and wrecker applications, visit: www.westernstar.com.

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Which Winch is Which?

Merriam – Webster defines a winch as a machine for hauling or pulling.  Specifically, a winch is a powerful machine with one or more drums on which to coil a rope, cable, or chain for hauling or hoisting.  In industry, winches stand at the heart of machines as diverse as tow trucks, large industrial cranes, heavy hauling equipment and off road vehicles requiring self-recovery.  The more elaborate designs have gear assemblies that can be powered by electric, hydraulic, pneumatic or internal combustions drives.

The two most common designs of winches used in the Industrial Marketplace are the Worm Gear Winch and the Planetary Winch. Worm gear winches, by design, provide a very rugged platform for heavy duty applications. The planetary winch design offers higher speed and higher efficiency when compared to its counterpart.  However a separate breaking system is required with the planetary design. Which type of winch is better?  It depends on the application.  This is where a winch professional comes in; to help with the specification of the proper winch.

Most US manufactures design to the Industry Standard:  SAE J706 Rating of Winches:  SAE J706 is a voluntary standard for intermittent duty winches.  Winches meeting this standard must comply with design guidelines for the free spool mechanism, brake holding force, drum diameter in relation to the cable diameter (8:1), cable anchor pocket and other design guidelines.  As part of the testing procedure, all winches must be tested to a two times load test.

Worm Gear Winch

Worm gear winches have fewer moving parts than other designs and are known for their superior endurance and high reliability.  The gear box of a Worm Gear Winch has two major parts, the worm and the main or bull gear. It is generally accepted in the industry that worm gear winches have a slower line speed and are less efficient than other designs. However, they are also generally self-braking, meaning that they stop when the driving worm gear stops and are extremely robust.  Due to some new highly efficient gearing technology, there are some worm gear winches that have line speeds that are equal to their planetary counterparts for the same line pull.  Reference:  Ramsey Winch HSW 10,000 Worm Gear Winch has the same line speed as the HD-P 10,000.

Planetary Winch

The planetary winch has gained popularity because of its compact size, smooth operation and good resistance to torque loads.  This design also allows for generally higher efficiency gear ratios than the standard Worm Gear Winch. The planetary winch gear box is made up of the sun gear surrounded by a number of planetary gears that engage the ring gear.  The planetary winch is also more efficient than its worm gear counterpart.  However this device does require a braking system to safely hold the load.

Other Major Components of the Winch:  Although the basic industrial winch design is named after the winch gearbox, there are other components that make up the total winch product.  The major ones of these are the Rope (Synthetic or Wire Rope); the Drum; the Clutch Assembly; the Braking System; and the Driving Motor (generally electric or hydraulic.)

Rope and Drum

The winch rope is stored on the drum in layers.  The published rating of the winch is the “rated line pull on the first layer of rope on the drum.”  The first layer is the layer closest to the drum.

Clutch Operation and Maintenance:  There are several defining factors in the operation of a winch.  One of the most important of these is the operation, inspection and care of the “Clutch Assembly.”  The clutch is used to engage and disengage the gear and drum assemblies of the winch.

Clutch Disengaged

When the clutch is disengaged, the cable on the drum may be pulled off by hand, commonly known as “free spooling”.  There are a number of specified ways to disengage the clutch assembly based on the type of winch, its design and the procedure for operation that is detailed in the winch owner’s manual.

To Disengage Clutch: Run the winch in the reverse direction until the load is off the cable.  Pull outward on the clutch handle, rotate counterclockwise 90 degrees and release. With other designs, the clutch handle can be moved toward the drum until the clutch disengages.   The Clutch is now locked out and the cable may be pulled off by hand. (Free Spool.)

To Re-engage the clutch, pull outward on the handle; rotate clockwise 90 degrees and release. In the other design shown, to reengage the clutch, the handle is pulled away from the drum to the, “IN” position.  The drum is then rotated until the clutch jaws engage the drum jaws.

Important Note:  The most important rule with respect to winch operation: The Clutch must be fully engaged before starting any winch operation. Failure to do so may result in the dropping of the load, with the potential for injury.

Clutch Re-Engaged

Clutch Inspection and Maintenance:  As part of the normal maintenance procedure of the winch, the clutch assembly should be inspected regularly.  These inspection procedures are detailed in the Winch Operation Manual provided by the winch manufacturer.  As an example, on the Ramsey Winch HSW-10000 model, an inspection plug is provided on the top of the clutch housing.  During the inspection procedure, this plug should be removed with the clutch engaged.

The jaw clutch must be fully engaged with the drum jaw to see if the Jaw clutch shows wear.

Drum jaws and clutch Jaw should have square edges.  If the Drum jaws are rounded, the drum must be replaced. It is important to note that the drum should not be welded or machined in an attempt to eliminate round edges.  If the drum jaws are rounded, the drum must be replaced.  This is just one example of a clutch inspection procedure.  The procedure can and will vary depending on the winch design.  See the winch operation manual for the specific winch model and design.

The important thing to remember about the Winch Clutch Assembly:

  • A fully engaged and properly maintained clutch will not release under load.  The operator is responsible for ensuring the clutch is fully engaged before starting winching operations.
  • A partial engagement of the clutch can result in a sudden loss of load and damage to the clutch mechanism, and the possibility of injury.

Summary:  An industrial winch is a robust and reliable device that is used in a variety of industrial applications e.g., towing and recovery, heavy hauling etc.  If properly maintained and operated correctly, it will provide service for a long time.

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Light Bar Basics

Todd K., AWDirect Technical Product Support

Trying to call attention to yourself and your recovery – in traffic filled with cars designed to filter out noise and reduce road glare – can be a very daunting and dangerous task. You would think a lightbar on the roof and some flashing beacons would be sufficient to capture the attention of any driver, on any freeway, in the U.S. But I have memories that suggest otherwise…I recall a fully loaded tractor-trailer sliding past two flashing patrol cars, my casualty in the ditch and my flashing rollback while I stood nearby, all due to the driver not paying attention to the road. This was the first time I thought, “How do people not see this pack of flashing vehicles?” Unfortunately, it wasn’t the last time. With cell phones, laptops, GPS screens and a multitude of other distractions in today’s vehicles, it is a wonder more people in the recovery and emergency response industry are not hurt or killed.

There are many choices when it comes to emergency lighting these days, but one rule holds true for me: purchase lights that are CLASS ONE RATED! Class One lights are the minimum primary warning devices for use on authorized emergency vehicles (i.e. fire trucks, police cars, etc.) that respond to emergency situations. Still, CLASS TWO rated lighting is all that’s required for an unauthorized maintenance or service vehicles (i.e. tow trucks). However, my experiences have shown me that Class Two may not always be enough in today’s world.

There are just as many choices of light styles and foundations as there are locations to put them. LED lights are the newest technology and are the most durable, waterproof and least power-consuming lighting today. Technology has made the newest LED modules super bright and they can be seen at distances previously unheard of. The only pitfall of the LED is that the initial purchase costs more than the older technology of strobes and rotators. However, you’ll eventually see cost savings by not having to replace pricey strobe tubes and power supplies. Plus, the playing field is becoming more level as new manufacturing processes have helped to drastically reduce prices of LEDs over the past few years.

Strobe tube-based lighting products are a staple of the emergency response industry. Strobe tubes are intensely bright and have fully directional output without the use of cut mirrors. Strobe-based lighting is mid-priced, with the drawback of having strobe tubes and power supplies that are prone to expire within a couple of years, depending on usage. These are fairly pricey to replace and create a lot of heat.

Finally, there is the Rotator. This light foundation has been used by everyone from Andy Griffith on his Mayberry squad car to some 50-ton rotators. These lights have been around as long as emergency service itself and have long been an affordable staple of the industry.

In my experience, LED lighting is the winner for safety, longevity and looks. But whatever lighting you have on your truck, you need to make sure you and your crew are visible. Visibility is one of the most important factors for safety on the roadside. If drivers see you from a distance, they have a much better chance of making the decision to “slow down and move over.”

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Winch Basics and Not-so-Basics

Todd K., AWDirect Technical Product Support

Coming from a life working in (and owning) collision centers, repair shops, tire shops and now working in the marketing and technical side of the industry, my human hard drive of stories, mistakes, accomplishments and knowledge of the towing industry is reaching critical mass.

I think back to the beginning of my recovery days when it seemed fine to wrap the wire rope around the frame of an overturned casualty, attach the hook back to the wire rope, idle up and jerk the vehicle back to its correct “top-side-up” position. I compare that situation to the knowledge I have now of doing it correctly and safely, all while saving money from having to replace damaged parts. It seems as though it should be easy to teach the new guys not to make the same mistakes I made. WRONG. Now, I do not proclaim to be a psychologist or even know much about the human thought process, but 20+ years in the recovery industry has taught me that most of us have a hard time admitting we have done things wrong or do not know something recovery related.

This leads me to why I am writing this article. When we think of winches and wire rope, we assume they’re super-strong and nearly indestructible. WRONG again. That was the impression I had when I started out in the recovery field. For quite some time, I had the impression that if something broke within the winching system then it had to be a manufacturer’s defect. And…I was WRONG again. Are you seeing a pattern here?

Let’s start with wire rope. First off, we need to think of our wire rope as a running machine with moving parts. How’s that you ask? Think of a 4×4 truck on dry pavement. The truck hops and chirps when you make a really tight turn. This is because the outside wheel is traveling much farther than the inside wheel while being locked together, which wears rubber off of the outside tire. Wire rope behaves the same. When it goes around a sheave or the winch drum, the outside wire strands of the rope rub against the slower-moving inside strands. This wears on the small metal strands of the wire rope the whole time. It’s a sound practice to replace wire rope at least every six months on a regularly used recovery vehicle, even if there are no obvious signs of wear. The wear could be taking place, unseen, inside the rope where the small wire strands have worn on each other, leaving breakage to occur anytime with no warning. A six-month replacement schedule should keep you, your employees, your equipment and your customers safe.

There are a host of other damages and problems one can inflict upon wire rope. These include, but are not limited to: bending, smashing and kinking. For instance, a 3/8″ wire rope should never be run around anything less than a 4″-diameter sheave, or across sharp edges (such as the edge of your carrier bed). Plus, we all know we should never wrap the wire rope and hook around an object and attach the hook back to the wire rope itself. Most of these problems can be avoided by using a synthetic rope, but that is an article all by itself and we will leave that for a future writing.

Now on to the winch. The winch is the heart of your truck. Just like the heart that beats in your chest, you are bound to have problems with it if you neglect it long enough, and probably at the most unfortunate times. You do not have a heart attack at the hospital and your winch will not give out at the shop. So…Lubricate! Lubricate! Lubricate! Lubrication is the lifeblood of your winch. Be sure to change the lubricant at least every season to prolong the internal parts of your winch. The type and weight of lubricant can be found in your winch’s manual. (AHHH! No manual? Manuals for most common name brand winches can be found on the manufacturers’ websites).

Check for leaks at the gear and motor side of your winch. The hydraulic motor mount usually has a weep hole. If there is any fluid dripping from it, replace the seal between the motor and the mount. Check for leaks at any gear case seams and replace the gaskets as necessary. Check for loose bolts in the winch frame and for excessive play in the winch drum from side to side. Last, but certainly not least, check the clutch side of the winch. This usually has a fairly simple design—a handle hooks to a clutch fork that slides the jaw clutch’s two teeth in and out of the two teeth in the side of the drum. This allows the winch to free-spool. The simplicity of this design is also what causes the most problems with user error. That’s right, here is where a lot of us go wrong.

There’s that pattern again. Since I was one of the largest violators of the correct clutch disengagement-engagement procedures, I can explain it well! It is 18 degrees outside. We are picking up a stranded mid-size car in 15″ of snow. We pull up, hit the MICO lock, engage the PTO and idle up. We jump out, pull the clutch release and raise the bed. We shovel the snow from the front of the car, attach our V-strap and proceed up the bed to pull the winch cable out. We find ourselves sliding down the snow and ice on the bed until we stop abruptly at the snow-covered V-strap and attach the hook. Now shivering and slightly shaken from the unintended luge trip down the carrier bed, we check traffic then hurry back to the side of the carrier. We tap the clutch release lever back in and pull on the “winch in” handle until the clutch engages into the spool. WRONG again. Rounded jaw clutch teeth are the single largest repair to winches that I see and are easily the most dangerous condition to have with your winch.

It all stems from the clutch engagement method mentioned before. When we power in to engage the clutch, the pressure and speed of the drum rotation can catch the jaw clutch before it is fully engaged, leaving only a 1/4″ or less of the teeth engaged. This situation causes the teeth to round out if done repeatedly. Once rounded, it may cause the winch to disengage at any time, allowing your casualty to freely roll down the bed and over anything and anyone behind it. The correct procedure for engaging the jaw clutch is to release the clutch lever, then tug on the wire rope until the jaw clutch engages into the drum and stops the free-spooling. Then and only then should power be applied to the winch. I want to stress this: we can prevent damage to our machines and customer vehicles, or even prevent the loss of life by simply using machines the way they were designed to be used—safely and correctly.

Give someone a winch and they will pull stuff around. Teach someone recovery and they will be an asset to our industry and society.

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What Safety Regulations Apply to Me?

This is a common question asked by many types of motor carriers. Who is a motor carrier? Basically, it is anyone that uses a “commercial vehicle” to conduct business on the roadways. This, in most cases, includes tow operators.

FIRST QUESTION, ‘DO YOU OPERATE COMMERCIAL VEHICLES’?

For the purposes of the federal Department of Transportation and its agency that oversees interstate motor carrier safety (the Federal Motor Carrier Safety Administration, or FMCSA), a commercial vehicle is a vehicle used in interstate commerce that:

  • Has an actual or rated weight (single or combination) of 10,001
    pounds or more,
  • Is designed to seat either more than 8 or more than 15 people,
    depending on how compensation is handled, or
  • Is carrying a placardable amount of a hazardous material.

“Interstate commerce” is business that crosses state lines. In the case of carriers, it means either the vehicle or the cargo is destined to, or has, crossed a state line as part of the carrier’s movements. In the case of a tow operation, the “cargo” is the vehicle being towed. If the commercial vehicle is used in intrastate commerce, then the state’s definition of a commercial vehicle applies. Many states have adopted the FMCSA’s definition, but other states use their own definition.

SO YOU OPERATE COMMERCIAL VEHICLES. THE NEXT QUESTION IS, ‘WHAT RULES APPLY’?

If you operate vehicles that meet the FMCSA or state definition of a commercial vehicle, the FMCSA or state’s safety regulations will apply to your operation. If you are an intrastate carrier, you need to be aware that most states have adopted the majority of the FMCSA safety regulations for their intrastate carriers. Therefore, the FMCSA regulations or a slight variation of them may very likely apply to you. The key areas that these regulations cover are carrier credentialing, driver licensing and qualifications (and possibly drug testing), vehicle parts and accessories, hours of service, and vehicle inspection and maintenance. In this article we will discuss these requirements, and following each requirement will be the FMCSA regulation number involved if you want to look up the details.

CARRIER CREDENTIALS

Carriers that operate in interstate commerce must file an MCS-150 and be issued a USDOT number (see §390.19). If the carrier is charging the public for the service they provide (not just hauling cargo the company owns), the carrier must also have “for-hire authority.” Most states have a similar structure when it comes to their intrastate carriers. In addition, some states and municipalities have additional requirements on tow operators under their jurisdiction. In the case of a for-hire carrier, the company may also be subject to specific insurance minimums (see Part 387).

Once the company becomes a registered carrier, the vehicles must be marked in accordance with the regulations (see §390.21) and the company must maintain an “accident register” where all accidents the company is involved in are recorded. The FMCSA considers an accident to be an occurrence involving a company vehicle that resulted in a death, an injury requiring immediate treatment away from the scene, or a vehicle having to be towed away from the scene due to disabling damage (see §390.15).

DRIVERS

Drivers must have the correct license for the vehicle being operated. If the vehicle qualifies as a CDL Class A vehicle (a vehicle weighing or rated at 26,001 pounds or more pulling a towed unit weighing or rated for 10,001 pounds or more) the driver must have a Class A CDL. If the unit being towed is a combination vehicle that has multiple units, the driver would also need to have the “double/triple” endorsement as well as a Class A CDL. If the towing unit weighs more than 26,001 pounds and the towed unit is under the 10,001 pound threshold, then a Class B CDL is required. If the combination is 26,000 pounds or less, and the towed unit is 10,000 pounds or less (and is carrying no placarded hazardous materials), a regular driver’s license is all that is required in most states (see §383.91).

If the vehicle being towed would require the driver of the vehicle to have a special endorsement to his/her CDL (hazardous materials, tanker, etc.) then the tow truck driver would need to have that endorsement as well (see §383.93).

The driver must also have passed a physical and have a valid medical card (see §391.43). The company must have a driver qualification file showing that the driver meets the driver qualification requirements. This file would need to include the driver’s application (§391.21), the background checks done when the driver was hired (§391.23), annual MVR checks (§391.25), annual reviews of driver’s performance (§391.27), road test certificate or equivalent (§391.31 and §391.33), and a copy of the driver’s medical card (§391.43).

Some jurisdictions have additional driver qualification requirements for drivers of tow truck drivers (such as a tow operator certification). If the driver operates a vehicle requiring a CDL to operate, the driver must have been provided a copy of the company’s drug and alcohol policy (see §382.601), and the company must have gotten a verified negative test result and have it on file before using the driver (see §382.301). The company must also have the driver on the random drug and alcohol testing selection list (see §382.305).

Last, the driver is covered by the hours-ofservice regulations. These regulations limit how many hours a driver can drive, how many hours the driver can be on duty, and how many hours of break time the driver must take. The basic rules include not driving after the driver has reached (see §395.3):

  • 11 hours of driving since the last break of 10 hours or more
  • 14 consecutive hours since the last break of 10 hours or more
  • 60 hours on duty in the last 7 days (70 hours in the last eight days if the company operates vehicle 7 days a week and the company chooses to use this option)

To record their hours-of-service compliance, drivers must maintain a “record of duty status,” better known as a “log” (see §395.8). There are exceptions for drivers that operate in “short haul” operations that can allow the company to use time records in place of the driver having to complete a log. The details of these exceptions are in the FMCSA regulations at §395.1(e). The key is that the driver cannot drive once one of these limits is reached, whether the driver is keeping a log or operating under one of the exceptions that allow time records to be kept in place of logs. The driver can still work, just not drive.

VEHICLES

Just like the drivers, once a vehicle is a commercial vehicle, certain regulations apply. To begin with, the vehicle needs to be equipped in accordance with Part 393 of the regulations. These regulations mandate what parts and accessories are required and what condition they must be in. The vehicle then must be inspected and maintained by the company in accordance with Part 396, and maintenance records must be kept showing that the vehicle has been systematically inspected, maintained, lubricated, and repaired when necessary (see §396.3). The vehicle and cargo also must be inspected by the driver at the beginning of the workday and the driver must submit a report stating the condition of the vehicle at the end of the day (this is referred to as a driver vehicle inspection report or DVIR). These requirements are covered in the regulations at §392.7, §392.9, §396.11, and §396.13.

Finally, the vehicle must pass a very specific inspection called a “periodic inspection” (commonly called an “annual inspection”) as required by §396.17. If the state has an equivalent inspection that the commercial vehicle must undergo, this can take the place of this required inspection.

EMERGENCY OPERATIONS

One point about these regulations: If the driver is operating in support of an emergency, then some or all of the regulations do not apply. An emergency in the case of towing includes:

  • A request from law enforcement to assist in clearing an accident or disabled vehicle from traffic.
  • Operating in support of a declared disaster.

When responding to a request from law enforcement or in the case of a declared disaster, the driver and vehicle are only exempted from the regulations when he/she is responding to, operating in direct support of, and returning from the event. In both cases, the regulations in Parts 390 to 399 are the regulations the driver and vehicle are exempted from, meaning that, if the vehicle requires a CDL driver to operate it, the drug and alcohol regulations in Part 382 and CDL regulations in Part 383 still apply. What it comes down to is, if the driver is doing “every day towing” (such as customer called- in tows, dealer tows, or auction tows) and not operating in one of the two emergency situations discussed above, all of the rules that normally apply to a commercial vehicle and its driver apply. The driver is only exempt from the rules in Parts 390 to 399 when the driver is involved in emergency or disaster relief operations.

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Does It Really Matter

Cargo Control for Tow Professionals

Cargo Control for Tow Professionals

B/A products has been manufacturing and distributing towing and recovery products since 1978. We have come a long way since our start, increasing our product line, doing more manufacturing in house, larger space and more employees. Product quality is our top priority, and to ensure quality, we do a lot of testing.

If you have been to one of our open houses, you may have seen some of the testing we do. Random samples of all inbound chain, wire rope and forgings, snatch blocks and more are tested. While we receive documentation from our manufacturers, we test to verify that documentation. Does it matter? Yes!

In the course of testing, we occasionally find product that does not meet our specifications. We received a batch of chain that was not breaking properly. While the chain made minimum break strength, there was little to no elongation, the chain was too brittle. After discussing the problem with the chain manufacturer, it was discovered the chain had been heat treated to the wrong specification. The chain was returned, annealed and reheat treated, and now met spec. Did it really matter? In this case, yes.

We also test finished product to verify that the ratings we give them are accurate. When we started making tie downs for the auto hauling industry, there was a lot of debate on what the Work Load Limit of the straps should be. One side wanted to rate it based on the weakest component. The other side said in use, the load would be distributed and it would withstand a higher load. How to settle the debate? We built a mock up of a car hauler deck to use on our Crosby National CN22 flat bed tester, strapped a tire in, and tried to pull it out from under the strap.

The result? At 15,400 lbs, the test was stopped. The tire was still under the tie down, and as you can see in the photo, we compressed the tire a few inches. The strap got the higher work load limit, and we are confident the strap is suitable for the job. Did it really matter? Once again, yes.

We also get customer driven requests. A customer asked us to document the differences in the breaking strength of ratchet type load binders depending on how far in or out the hooks were relative to the ratchet mechanism. Test parameters were set up, and the testing began.

Load Binders at the Beginning of the Test

Load Binders at the Beginning of the Test

For the first round of testing, a 5/16”-3/8” load binder with a Work Load Limit of 6600 lbs and a Minimum Break Strength of 19,800 lbs was tested. Three samples were tested: one with the hooks wound all the way in, one with the hooks 1/3rd of the way out, and one with the hooks 2/3rd of the way out.

The samples were then hooked onto a section of 3/8” grade 80 chain. Each end of the chain had a clevis grab hook, and loops were formed over the hooks of the test bed.

Load Binder and Chain in a Test Bed

Load Binder and Chain in a Test Bed

Force was applied to the point of failure, the results were graphed and photographed. So what happened? Here are the results:

Hooks all the way in: one grab hook on load binder opened at 23,275 lb

Hooks 1/3rd of the way out: one grab hook on load binder opened at 23,711 lb

Hooks 2/3rd of the way out: one grab hook on load binder opened at 21,396 lb

So did it really make a difference? In this case, no. Regardless of the hooks position, the load binders exceeded their Minimum Break Strength, and nearly four times their work load (remember: NEVER exceed a products Work Load Limit!).

Just to confirm our results, another group of load binders was tested. These were 3/8” G100 binders, with a Work load limit of 8800 lbs, and a minimum break of 26,400 lbs. The test set up was the same, using 3/8” grade 80 chain. This time the results were a little different:

Hooks all the way in: chain broke at 29,889 lbs

Hooks 1/3rd of the way out: chain broke at 22,089, where binder was hooked

Hooks 2/3rd of the way out: chain broke at 22,029 where binder was hooked

GRAPH OF TEST. CHAIN FAILED AT 22,029 LBS

Graph of initial test

Graph of initial test

So what happened? First, the Work Load Limits were mismatched. Binder Work Load Limit is 8800 lbs, 3/8 Grade 8 chain WWL is 7100 lbs. One test went above the Minimum Break Strength of the chain (28,400 lbs); two were below the MBS. In both cases, one of the links the binder was hooked to failed. This is known in the chain industry as a Preferential Failure. Because of the way force is applied to the link by the grab hook; it can fail at up to 20% below the chains MBS. Chain is designed to be pulled in a straight line, not from the side. Also remember, that an assembly is rated by its weakest component, and once again, NEVER exceed the products Work Load Limit.

So did it really matter in this test? I’ll have to say yes and no. No because the position of the load binder hooks did not affect the result of the test. Yes because the differences of the Work Load Limit of the components did affect the test, as well as the Preferential Failure.

I’ve asked the question does it really matter several times, and answered some with yes and some with no. The answer to all of them should be yes. We test to make sure you get the best product available, every time. It matters because when we ship a product, any product, we want there to be no question it will do the job for which it was designed., every time. Yes, it really does matter.

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Winch Basics and Not-so-Basics

Todd K., AWDirect Technical Product Support

Coming from a life working in (and owning) collision centers, repair shops, tire shops and now working in the marketing and technical side of the industry, my human hard drive of stories, mistakes, accomplishments and knowledge of the towing industry is reaching critical mass.

I think back to the beginning of my recovery days when it seemed fine to wrap the wire rope around the frame of an overturned casualty, attach the hook back to the wire rope, idle up and jerk the vehicle back to its correct “top-side-up” position. I compare that situation to the knowledge I have now of doing it correctly and safely, all while saving money from having to replace damaged parts. It seems as though it should be easy to teach the new guys not to make the same mistakes I made. WRONG. Now, I do not proclaim to be a psychologist or even know much about the human thought process, but 20+ years in the recovery industry has taught me that most of us have a hard time admitting we have done things wrong or do not know something recovery related.

This leads me to why I am writing this article. When we think of winches and wire rope, we assume they’re super-strong and nearly indestructible. WRONG again. That was the impression I had when I started out in the recovery field. For quite some time, I had the impression that if something broke within the winching system then it had to be a manufacturer’s defect. And…I was WRONG again. Are you seeing a pattern here?

Let’s start with wire rope. First off, we need to think of our wire rope as a running machine with moving parts. How’s that you ask? Think of a 4×4 truck on dry pavement. The truck hops and chirps when you make a really tight turn. This is because the outside wheel is traveling much farther than the inside wheel while being locked together, which wears rubber off of the outside tire. Wire rope behaves the same. When it goes around a sheave or the winch drum, the outside wire strands of the rope rub against the slower-moving inside strands. This wears on the small metal strands of the wire rope the whole time. It’s a sound practice to replace wire rope at least every six months on a regularly used recovery vehicle, even if there are no obvious signs of wear. The wear could be taking place, unseen, inside the rope where the small wire strands have worn on each other, leaving breakage to occur anytime with no warning. A six-month replacement schedule should keep you, your employees, your equipment and your customers safe.

There are a host of other damages and problems one can inflict upon wire rope. These include, but are not limited to: bending, smashing and kinking. For instance, a 3/8″ wire rope should never be run around anything less than a 4″-diameter sheave, or across sharp edges (such as the edge of your carrier bed). Plus, we all know we should never wrap the wire rope and hook around an object and attach the hook back to the wire rope itself. Most of these problems can be avoided by using a synthetic rope, but that is an article all by itself and we will leave that for a future writing.

Now on to the winch. The winch is the heart of your truck. Just like the heart that beats in your chest, you are bound to have problems with it if you neglect it long enough, and probably at the most unfortunate times. You do not have a heart attack at the hospital and your winch will not give out at the shop. So…Lubricate! Lubricate! Lubricate! Lubrication is the lifeblood of your winch. Be sure to change the lubricant at least every season to prolong the internal parts of your winch. The type and weight of lubricant can be found in your winch’s manual. (AHHH! No manual? Manuals for most common name brand winches can be found on the manufacturers’ websites).

Check for leaks at the gear and motor side of your winch. The hydraulic motor mount usually has a weep hole. If there is any fluid dripping from it, replace the seal between the motor and the mount. Check for leaks at any gear case seams and replace the gaskets as necessary. Check for loose bolts in the winch frame and for excessive play in the winch drum from side to side. Last, but certainly not least, check the clutch side of the winch. This usually has a fairly simple design—a handle hooks to a clutch fork that slides the jaw clutch’s two teeth in and out of the two teeth in the side of the drum. This allows the winch to free-spool. The simplicity of this design is also what causes the most problems with user error. That’s right, here is where a lot of us go wrong.

There’s that pattern again. Since I was one of the largest violators of the correct clutch disengagement-engagement procedures, I can explain it well! It is 18 degrees outside. We are picking up a stranded mid-size car in 15″ of snow. We pull up, hit the MICO lock, engage the PTO and idle up. We jump out, pull the clutch release and raise the bed. We shovel the snow from the front of the car, attach our V-strap and proceed up the bed to pull the winch cable out. We find ourselves sliding down the snow and ice on the bed until we stop abruptly at the snow-covered V-strap and attach the hook. Now shivering and slightly shaken from the unintended luge trip down the carrier bed, we check traffic then hurry back to the side of the carrier. We tap the clutch release lever back in and pull on the “winch in” handle until the clutch engages into the spool. WRONG again. Rounded jaw clutch teeth are the single largest repair to winches that I see and are easily the most dangerous condition to have with your winch.

It all stems from the clutch engagement method mentioned before. When we power in to engage the clutch, the pressure and speed of the drum rotation can catch the jaw clutch before it is fully engaged, leaving only a 1/4″ or less of the teeth engaged. This situation causes the teeth to round out if done repeatedly. Once rounded, it may cause the winch to disengage at any time, allowing your casualty to freely roll down the bed and over anything and anyone behind it. The correct procedure for engaging the jaw clutch is to release the clutch lever, then tug on the wire rope until the jaw clutch engages into the drum and stops the free-spooling. Then and only then should power be applied to the winch. I want to stress this: we can prevent damage to our machines and customer vehicles, or even prevent the loss of life by simply using machines the way they were designed to be used—safely and correctly.

Give someone a winch and they will pull stuff around. Teach someone recovery and they will be an asset to our industry and society.

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