{"operation":"document","citation":"04-0147","title":"MHF Logistical Solutions — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2004-06-18","effective_on":null,"summary":"04-0147 response to MHF Logistical Solutions concerning 173.427.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0147.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0147.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0147","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2004/040147.pdf","body":"<<<PAGE 1>>>\n\nf Transportatio\nS. Departmer\n400 Seventh St., S.W.\nWashington, D.C. 20590\nResearch and\nSpecial Programs\nJUN 18 2004\nAdministration\nMr. Kurt Colborn\nReference No.: 04-0147\nMHF Logistical Solutions\nDirector, Technical Services\n300 Cranberry Woods Drive, Suite 45\nranberry Township, PA 16066\nDear Mr. Colborn:\nThis is in response to your June 1, 2004 letter regarding the applicability of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you seek\nconcurrence that your Super Load WrapperTM (SLW) gondola lining system meets the\ngeneral design requirements of § 173.410.\nBased on the information you provided, it is our opinion that a gondola railcar with a\nSLW lining system would satisfy the general design requirements of § 173.410.\nI trust this satisfies your request.\nSincerely\nHate z. pitchels\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n113.427 64)\n040147\n\n<<<PAGE 2>>>\n\nBetts\n$173.427(6)(4)\nRAM\n04-0147\n800 Cranberry Woods Drive, Suite 450, Cranberry Township, PA 16066 T 724.772.9800 F W www.mhfis.com\nMr. Edward Mazzullo\nDirector of Hazmat Standards\n400 7\" Street, SW\nWashington, DC 20590-3012\nJune 1, 2004\nSUBJECT: Interpretation for Package Compliance with 49 CFR 173.427(b)(4)\nDear Mr. Mazzullo,\nThe purpose of this letter is to request confirmation of our interpretation of the\nrequirements of 49 CFR 173.410 and as cited by 173.427(b)(4). Specifically, this letter\nseeks concurrence that the packaging described herein meets the subject requirement.\nWrapper\nMHF Logistical Solutions' Packaging Solutions Division manufactures the Super Load\nliterature and specifications (Attachment 1).\n(SLW) gondola lining system. The SLW is described in the enclosed\nWhen used as a liner in a gondola (nominally 53' or 65' foot gondolas), the\n(such as soils and debris). The SLW/gondola system has been used successfully in\nSL W/gondola system provides a strong, durable, sift-proof packaging for bulk materials\nthousands of railcar shipments in accordance with the current 173.427(c)(1).\nWe believe that the SLW, in combination with a standard rail gondola, also meets the\ngeneral design requirements of 173.410. Our evaluation of the package against the\ndesign criteria is attached (Attachment 2). We recognize that certification and acceptance\nof the package is our responsibility as the shipper. However, this package includes\ndisposable components, is not equipped with some of the features described in 173.410,\nso we are requesting USDOT concurrence with our evaluation of the package as\npresented in this document.\n\n<<<PAGE 3>>>\n\nMHF-LS has obtained verbal concurrence with our package assessment from Kurt\nPlease consider this letter and its attachments in your response to the following packaging\nEichenlaub of your Office, this letter seeks confirmation in a written interpretation.\nassessments, subject to usage limitations described in our package evaluation:\n1. The MHF-LS Super Load Wrapper™ qualifies as a packaging when used in\nconjunction with a gondola for LSA material in accordance with 49 CFR\nBond W spr a supposed the Super Load a aper on dal so pose..\n2. The Super Load Wrapper™\ncontents, but either the Super Load Wrapper™ or the gondola may be marked and\nprovides the required barrier for release of package\nlabeled as the package at the shipper's discretion.\nPlease feel free to contact me at (724) 772-9800, ext. 5560 if you have any questions\nabout this request. Thank you for your assistance.\nRespectfully submitted,\nKurt Colborn\nDirector, Technical Services\nMHF Logistical Solutions\n\n<<<PAGE 4>>>\n\nATTACHMENT 1\nSuper Load Wrapper\nDescriptive Literature and Specification\n\n<<<PAGE 5>>>\n\nSOLUTIONS\nPhone: 724.772.9800 Ext: 5542 Fax: 724.772.9850\n800 Cranberry Woods Drive, Suite 450, Cranberry Township, PA 16066\nErin Grimm, Transport Plastics Program Manager\nE-mail: erin outam@mails.com Web: www.mhis.com\nJune 1, 2004\nTo: Kurt Colborn, MHF-LS\nFm: Erin Grimm, MHF-PS\nCc: Shelia King, MHF-PS, File\nRe: MHF-PS Super Load Wrapper\nKurt-\nThe Super Load Wrapper (SLW) is just one of the products that MHF Packaging\nSolutions' facility in Sweetwater, TN has been manufacturing for more than ten years.\nThe SLW is considered the premier gondola railcar liner in the industry. The SLW is\ndesigned for shipments of bulk material in a gondola railcar to meet the US DOT\ndefinition of a \"strong tight\" shipment. It is the proven design and material strength of\nthe SLW that has allowed more than 10,000 gondola railcar shipments to ship their bulk\nmaterials with less than ½ of 1% liner puncture or failure.\nThe dynamic design of the SLW sets itself apart from the traditional static gondola\nrailcar liner. A traditional liner merely covers the inner walls and floor of the railcar\nleaving enough material to cover the top of the load. These liners are used primarily to\nprotect the railcar from contaminatior by the loaded bulk material and reduce potential\nclean out requirements.\nThe SLW is designed and manufactured to \"seal\" and \"protect\" a bulk gondola railcar\nload. The design and proper use of the SLW closure system allows the shipper to seal\nthe bulk load in the SLW and protect the load from wind and weather elements.\nAdditionally, the proprietary closure system of the SLW dynamically reacts and protects\nthe bulk load from breaching the liner when the load shifts within the railcar during rail\ntransit.\nMHF-PS does manufacture and fabricate the \"traditional\" gondola railcar liners and the\ncost difference due to the quality of materials used in the construction and assembly is\nanother good indicator of the difference in strength and quality.\nPlease feel free to contact me should you have additional questions regarding the SLW\nor any MHF-PS product.\n\n<<<PAGE 6>>>\n\nLOGISTICAL\nSOLUTIONS\nPhone: 1.877.452.9300 Fax: 724.772.9850 Web: www.mhfls.com\n800 Cranberry Woods Drive, Suite 450, Cranberry Township, PA 16066\nPRODUCT\nNFORMATION\n• Super Load Wrapper™ Gondola Lining System\nMHF Packaging Solutions Division\nSpecifications\n• Liner sizes accommodate 53' and 65' gondolas\n• 7.5 oz./SY Nominal woven and coated high density\n(custom sizes are also available)\n• Reference thickness 18 mils. nominal\npolypropylene fabric\n• Color - black\n• Weight approximately 160 Ibs.\nEquipment Features\n• Our Super Load Wrapper™ is the premier gor dola car\n• The Super Load Wrapper™ System allows a shipment\ndefinition of \"Strong-Tight\" shipment\nof bulk material in a rail gondola to meet the US DOT\n• The design and strength of the Super Load Wrapper™\nthat other liner systems cannot withstand\nallows it to be used for debris and aggressive materials\n• All supplies required to install and secure the liner for\nThe application of this product also aids in keepin\nshipment are included\nne car clean and provides for easier off-loadin\n• Lining system has been in use successfully since 1988\n• Form-fit in car design\n\n<<<PAGE 7>>>\n\n190 Transport Drive • PO Box 12 • Sweetwater, TN 37874 • 800-603-8277 • 423-337-2184 (Fax)\nTransport Plastics, Inc.\nProduct Specification Number:\n100040\nRevision:\nDate: 10-24-03\nSuper Load Wrapper Rail Car Liner\nProduct Information\nItem Number:\n10-SLW5310\nItem Description:\nSuper Load Wrapper Rail Car Liner\nFinished Size:\n53.5 ft. x 10.5 ft. x 6 ft. x (10 ft. top flaps x 2) +/- 1\"\nFinished Package:\nFolded and taped to form fit into car and for easy installation\nFlaps:\n2 end flaps\n2 fully overlapping top flaps\nClosure System:\n33 tie closures consisting of ¼\" braided black polypropylene rope and\ncorresponding receiver holes.\nTare Weight:\n160 Ibs.\nFabric Information\nMaterial Type:\nWoven & coated high density polypropylene (HDPP)\nWeave:\nNominal 12 X 12 ppi woven black HDPP scrim using 1600 denier tapes\nWeight:\nNominal 7.5 oz./ square yard +/- 10%\nReference Thickness:\n18 mil\n(Grab Method)\nTensile Strength:\nWarp - 325 lbs\nASTM D5034\nWeft - 310 lbs\n(Trapezoidal Tear Method)\nTear Strength:\nWarp - 85lbs\nASTM D4533\nWeft - 85 Ibs\nMullen Burst:\n540 psi\nASTM D3786\nCoating Thickness:\n2.0 mil average, 2 sides\nScrim Type:\nBlack PP tapes, 1600 Denier\nColor:\nBlack\nThease cal tor pertisid in to copy or elstriute to alyoro oth of fran the tandie recipina Thah ky demed to be Contidential and Proprietary.J\n\n<<<PAGE 8>>>\n\nATTACHMENT 2\nQualification of the MHF Logistical Solutions' Super Load Wrapper™\n(in conjunction with a standard gondola car)\nto 49 CFR 173.410 and 173.24\nRequirement: 49 173.410(a) The package can be easily handled and properly secured in\nor on a conveyance during transport.\nFulfillment: The Super Load Wrapper™\nreadily installed into a standard gondola car. The SLW is self-securing to the gondola\nvhen filled, the bulk load ensures the SLW is stable and secure within the confines of th\ncondola. The SLW/gondola package is as readily handled as a standard railcar. Th\ngondola is viewed as a required part of the package system, but for the purposes of\ncompliance with this section is seen as external, removable and reusable handling device.\nRequirement: 49 CFR 173.410(b) Each lifting attachment that is a structural part of the\npackage...\nFulfillment: The SLW is not equipped with lifting attachments of any kind; this\nflaps of the SLW cannot be readily mistaken for lifting attachments. Further, these\nrequirement does not apply. The rope lacing closure system used to secure the closure\nlightweight ropes would fail before damaging the package or allowing any movement at\nall in the filled 80-100 ton SLW. The gondola car is not equipped with lifting\nattachments and is not designed for iifting.\nRequirement: 49 CFR 173.410(c) The external surface, as far as practicable, will be free\nfrom protruding features and will be easily decontaminated.\nFulfillment: The woven and coated high-density polypropylene construction of the SLW\nis readily wiped free of non-fixed contamination should its external surface become\ncontaminated during loading. Further, the SLW is disposable and need not be\ndecontaminated. The SLW provides a durable barrier to material release, and is\nintended to minimize or prevent the potential contamination of the gondola car from the\nSLW contents. Finally, destination disposal facilities are generally equipped to perform\ndecontamination of gondola car surjaces as a routine matter if necessary.\n\n<<<PAGE 9>>>\n\nRequirement: 49 CFR 173.410(d) The outer layer of packaging will avoid, as far as\npracticable, pockets or crevices where water might collect.\nFulfillment: The smooth surface of the SLW sheds water readily. Thousands of\nshipments of material have been successfully shipped to disposal sites having strict\nprohibitions against free liquids. Stondard gondola cars are reasonably free of water-\ntrapping features. In addition, MHF-LS gondolas are equipped with drain ports to allow\nwater drainage from rain and snow melt.\nRequirement: 49 CFR 173.410(e) Each feature that is added to the package will not\nreduce the safety of the package.\nFulfillment: The SLW/gondola package is not generally amenable to the addition of\nfeatures of any kind. Some shippers may wish to add a tarp cover or hard lid to the\ngondola to supplement containment. Standard gondola covers, properly installed and\nsecured, will not adversely impact the safety of this package.\nRequirement: 49 CFR 173.410(f) The package will be capable of withstanding the\neffects of any acceleration, vibration, or vibration resonance that may arise under normal\nconditions of transport without any deterioration in the effectiveness of the closing\ndevices on the various receptacles or in the integrity of the package as a whole and\nwithout loosening or unintentionally releasing the nuts, bolts, or other securing devices\neven after repeated use.\nFulfillment: The SLW is a single use packaging. The SLW has been proven effective in\nthousands of shipments of bulk material without degradation or the loss of material due\nto acceleration, vibration, or vibration resonance. The closure system, effected in\naccordance with manufacturer-supplied instructions (Attachment 3), has proven effective\nagainst the release of contents in rail transportation, and against wind and rain\npenetration.\nRequirement: 49 CFR 173.410(g) The materials of construction of the packaging and\nany components or structure will be physically and chemically compatible with each\nother and with the package contents. The behavior of the packaging and the package\ncontents under irradiation will be taken into account.\nFulfillment: The nominal 18 mil thickness of the woven SLW has been demonstrated to\nprovide excellent physical integrity during normal rail transportation. The SLW is\nwidely used for shipment of large quantities of radioactively-contaminated soil and\ndebris. Degradation due to radiation exposure is not an issue for disposable SLWs used\nfor LSA materials. The chemical resistance and suitability of the SLW for other-than-\nradiological contaminants will be evaluated by the manufacturer and shipper on a case-\nby-case basis.\n\n<<<PAGE 10>>>\n\nRequirement: 49 CFR 173.410(h) All valves...\nFulfillment: The SLW is not equipped with valves. The closure system can only be\ndefeated by deliberate action.\nRequirement: 49 CFR 173.410(i) For transport by air...\nFulfillment: The SLW is not suitable for air transportation, and for qualification to\n173.410 the gondola is considered to be a component of the packaging, providing\nstructural support to to the SLW.\nRequirement 49 CFR 173.24(a) Applicability.\nFulfillment: The requirements are applicable.\nRequirement 49 CFR 173.24(b) Each package used for the shipment of hazardous\nmaterials shall be designed, constructed, maintained, filled, its contents so limited, and\nclosed, so that under conditions normally incident to transportation -\nwill be no identifiable (without the use of instruments) release of hazardous materials to\nRequirement 49 CFR 173.24(b)(1) Except as otherwise noted in this subchapter, there\nthe environment;\nFulfillment: The SLW properly installed and closed within a standard gondola car has\nbeen specifically designed to provide a barrier against the release of its contents.\nsuccessful in meeting this requirement. MHF-LS maintains that a lid for the gondola is\nThousands of rail shipments using the SLW/gondola packaging system have been\nnot a required addition to the package to meet 49 CFR173.410; lids are a feature of\ngondolas meeting more stringent IP-? requirements in exemptions such as DOT-E-\n12800. Use of the packaging is limited to the rated capacity of the gondola car. The\nSLW provides the barrier to release of contents; the gondola car provides required\nstructural support for the SLW package.\nRequirement 49 CFR 173.24(b)(2) The effectiveness of the package will not be\nsubstantially reduced...during transportation.\nFulfillment: As discussed in the fulfilment of 49 CFR 173.410(g) (above) the SLW\nrepresents a strong and durable liner, and an effective leak preventing package when\nused in conjunction. with a standard rail gondola.\n\n<<<PAGE 11>>>\n\nRequirement 49 CFR 173.24(b)(3) There will be no mixture of gases or vapors in the\npackage which could... reduce the effectiveness of the packaging.\nFulfillment: The SLW is typically used for bulk soil and building material in LSA\nshipments of radioactive material. Gases or vapors are not normally present, and would\nnormally be released from the package through its overlapping closures if they were\npresent. The impact of gases and vapors on the package performance will be evaluated\nby the shipper and manufacturer on a case-by-case basis as contents warrant.\nRequirement 49 CFR 173.24(b)(4) There will be no hazardous material residue adhering\nto the outside of the package during transport.\nFulfillment: The internal surface of the overlapping closure of the SLW covers the sides\nof the gondola during filling; hence, external surfaces are protected from contamination.\nIn the event external contamination does occur, the external surfaces are (and will be)\nreadily decontaminated.\nRequirement 49 CFR 173.24(c) Authorized packagings. A packaging is authorized for a\nhazardous material only if -\nRequirement 49 CFR 173.24(c)(1) The packaging is prescribed or permitted ...or\nFulfillment: This evaluation of requirements is intended to qualify the package to the\ngeneral design requirements of 49 173.410 for shipment of LSA materials as permitted by\n172.101 and described in 173.427(b)(4).\nRequirement 49 CFR 173.24(c)(2) [or] The packaging is permitted under, and conforms\nto, provisions contained in 171.11, 171.12, 171.12a, 173.3, 173.4, 173.5, 173.7, 173.27,\nor 176.11 of this subchapter.\nFulfillment: The packaging is permitted in accordance with 173.24(c)(1)\n171.11\nV/A transport by air not appropriate for the packagin\n171.12\nV/A international shipping not planned, appropriate certifications anc\nshipping documentation will be provided on a case by case basis if\n171.12a\nSee 171.12\n173.3\n(a) SLW manufacture is available for inspection; (b) SLWs are used in rail\n173.4\nransport only; (c) NiA, pertains to salvage drums/packagin\nSmall quantity exceptions N/A - the SLW/gondola is a bulk packagin\n173.5\nN/A - pertains to agriculture\n173.7\nNo DOD-specific qualification of this package is proposed, this package\n173.27\n176.11\n\n<<<PAGE 12>>>\n\nRequirement 49 CFR 173.24(d) Specification packagings and UN standard\npackagings...\nFulfillment: N/A, 19 CFR 173.427(b)(4) permitted packaging requires compliance with\n173.410 and 173.24and is the subject of this evaluation.\nRequirement: 49 CFR 173.24(e) Compatibility. (e)(1) Even though certain packagings\nare specified in this part, it is, nevertheless, the responsibility of the person offering a\nhazardous material for transportation to ensure that such packagings are compatible with\ntheir lading. This particularly applies to corrosivity, permeability, softening, premature\naging, and embrittlement.\nFulfillment: The nominal 18 mil thickness of the woven SLW has been demonstrated to\nvidely used for shipment of large quantities of radioactively-contaminated soil an\nrovide excellent physical integrity during normal rail transportation. The SLW i\nfor LSA materials. The chemical resistance and suitability of the SLW for other-than-\ndebris. Degradation due to radiation exposure is not an issue for disposable SLWs usea\nradiological contaminants will be evaluated by the manufacturer and shipper on a case-\nby-case basis.\nRequirement: 49 CFR 173.24(e)(2) Packaging materials and contents must be such that\nthere will be no significant chemical or galvanic reaction between the materials and\ncontents of the package.\nFulfillment: The HDPE construction of the SLW is reasonably inert, has no identifiable\nreaction with gondola materials of construction, and no significant reaction with\nradioactively contaminated bulk soil and debris.\nRequirement: 49 CFR 173.24(e)(3)(i) Plastic used in packagings and receptacles must be\nhazardous condition is likely to occur during transportation, handling, or refilling.\nof a type compatible with the lading and may not be permeable to an extent that a\nFulfillment: See fulfillment of 49 CFR 173.24(e) above. Also, \"refilling\" is N/A for the\nSLW, a single-use container.\nRequirement: 49 CFR 173.24(e)(3)(ii) Each plastic packaging or receptacle which is\nused for liquid hazardous materials...\nFulfillment: N/A. Qualification of the SLW for liquids is not proposed at this time.\n\n<<<PAGE 13>>>\n\nRequirement: 49 CFR 173.24(e)(4) Mixed contents. Hazardous materials may not be\npacked or mixed together in the same outer packaging with other hazardous or non-\nhazardous materials if such materials are capable of reacting dangerously with each\nother....\nFulfillment: Qualification of the SLW as a packaging meeting 173.410 is proposed for\nhomogenous bulk solids. No mixing of hazardous materials within the packaging is\nproposed.\nRequirement: 49 CFR 173.24(e)(5) Packagings used for solids, which may become\nliquid at temperatures likely to be encountered during transportation, must be capable of\ncontaining the hazardous material in the liquid state.\nFulfillment: N/A. Qualification of the SLW is proposed only for bulk solids which\nremain solid at temperatures likely to be encountered in transport.\nRequirement: 49 CFR 173.24(f)(1) Closures. Closures on packagings shall be so\ndesigned and closed that under conditions (including the effects of temperature, pressure,\nand vibration) normally incident to transportation -\n(i) Except as provided in paragraph (g) of this section, there is no identifiable release of\nhazardous materials to the environment from the opening to which the closure is applied;\nand\n(ii) The closure is leakproof and secured against loosening. For air transport...\nflaps against opening during transport. The closure is similar to that used on MHF-LS\nFulfillment: The SLW flaps self seal the contents when closed. A rope-lacing secures the\nto meet 173.410, provides protection of the SLW closure, as well as a sturdy secondary\nIP-1 and IP-2 tested packagings. In addition, the gondola, which is part of the packaging\ncontainment. A standard procedure ias been developed to instruct users in proper\nfor the gondola is not a required addition to the package to meet 49 CFR173.410; lids\nclosure of the package, and is provided as Attachment 3. MHF-LS maintains that a lid\nare a feature of gondolas meeting more stringent IP-2 requirements in exemptions such\nas DOT-E-12800.\nRequirement: 49 CFR 173.24(g) Venting.\nFulfillment: N/A. The SLW/gondolapackaging is not intentionally vented, not utilized for\nair transport, and not currently proposed for containment of flammable gases.\n\n<<<PAGE 14>>>\n\nRequirement: 49 CFR 173.24(h) Outage and filling limits.\nFulfillment: N/A. The SLW/gondola packaging is not proposed for liquids, compressed\ngases, or cryogenic liquids.\nRequirement: 49 CFR 173.24b Additional General Requirements for Bulk Packagings\nFulfillment: N/A. The SLW/gondola packaging is not a tank, and proposed for liquids,\ncompressed gases, or cryogenic liquids.\n\n<<<PAGE 15>>>\n\nATTACHMENT 3\nSuper Load Wrapper\nStandard Operating Procedure for Installation and Closure\n\n<<<PAGE 16>>>\n\nTRANSPORT PLASTICS, INC.\nStandard Operating Procedure\nProcedure for Installing Super Load Wrapper Into Gondola Rail Car\n1.0\nScope\ndesignated Super Load Wrapper.\nThis procedure provides the instructions to properly install and secure the rail car\n2.0\nProcedure\n2.1\nEnsure a minimum of two personnel participate in the liner installation\nand closure.\n2.2\nOpen package with care not to damage the liner and remove the outer\npackaging.\n2.3\nPlace the load wrapper in the center of the rail car.\n2.4\nUnroll the wrapper to each end of the rail car.\n2.5\nWalk down the center aisle of the single layer of material and pick up the\nhem of liner and place over the side of the car. Repeat on the other side of\ncar. Note: Direction labels are on the edge of side flaps.\n2.6\nPlace the end flaps over the ends of the rail car. There should be a 6\"\nadjust as nedang over the corners. Check for uniform fit in the car and\n2.7\nLoad the car with material. Make sure the loader is not dragging the sides\nf the wrapper down into the car. Heap the pile in the center trom tr\nides and the ends. The pile should be recessed at each side and en\nforming a slope to the center but not above top edge of car.\n2.8\nOnce the car is loaded, fold the end flaps into the car. Make sure there are\nith coils of robe attacher\no sharp objects protruding into to liner surface. Tie end flaps opposin\n\n<<<PAGE 17>>>\n\nProcedure for Installing Super Load Wrapper (Continued)\n2.9\nRemove the two end ropes from the surface of each end flap and\ntemporarily place over the ends of the car. These are the final end tie\nropes.\n2.10\nFold the first flap, the side with short ropes attached, into the car and over\nthe material. Make sure the flap crests the top of the heap and there are no\nsharp objects protruding into the liner surface.\n2.11\nRemove the 8 ropes, with bungee cords, that are taped to the inside of the\nsecond flap (opposite of the load side flap). Tie them to the 8 receiver\nole, looping the rope and rethreading the rope back through the receivin\noles of the first (loading end) flap by threading each through the receive\nhole again, pulling snug, and tying the rope back to itself.\n2.12\nUntape the ends of the 23 cross (short) ropes affixed to the surface of the\nbottom flap and temporarily place over the car (load side)\n2.13\nFold over the top flap (opposite of load side) and thread the 15 continuous\nthe hem, loop, and rethread the rope through the receiver holes, pull snug,\ncross ropes with bungee sections (out of 23) through the receiver hole in\nand tie to the opposite (previously over the end of the car) cross rope's\nbitter end.\n2.14\nTie the 8 intermittent ropes (placed temporarily over the end of the car; no\nbungee sections; no mating rope at the opposite side) through the receiver\nhold in the hem, loop, rethread through the receiver hole, pull snug, and tie\n2.15\nTie each of the final end ropes (two on each end) to the most convenient\nof the four crossing ropes near each end of the rail car.","truncated":false,"body_characters":25075}