Recent guidance from USDOT/FMCSA provides some relief from the cargo securement regulations for accessory devices

Recent guidance from USDOT/FMCSA provides some relief from the cargo securement regulations for accessory devices. The guidance, reprinted below, impacts the application of Section 393.130 of the Federal Motor Carrier Safety Regulations (FMCSR). The photos were added as examples and were not part of the original guidance document.
Question 1: If an item of construction equipment which weighs less than 4,536 kg (10,000 lb.) is transported on a ; flatbed or drop-deck trailer, must the accessory equipment be lowered to the deck of the trailer? Guidance: No. However, the accessory equipment must be properly secured using locking pins or similar devices in order to prevent either the accessory equipment or the item of construction equipment itself from shifting during transport.
Question 2: How should I secure the accessories for an item of construction equipment which weighs 4,536 kg (10,000 lb.) or more, if the accessory devices would extend beyond the width of the trailer if they are lowered to the deck for transport? Guidance: The accessory devices (plows, trencher bars, and the like) may be transported in a raised position, provided they are designed to be transported in that manner. However, the accessory equipment must be locked in place for transport to ensure that neither the accessories nor the equipment itself shifts during transport.
Question 3: A tractor loader-backhoe weighing over 10,000 pounds is being transported on a trailer. The loader and backhoe accessories are each equipped with locking devices or mechanisms that prevent them from moving up and down and from side-to-side while the construction equipment is being transported on the trailer. Must these accessories also be secured to the trailer with chain? Guidance: No. However, if the construction equipment does not have a means of preventing the loader bucket, backhoe, or similar accessories from moving while it is being transported on the trailer, then a chain would be required to secure those accessories to the trailer.In the photo, note the blade being secured by the drop deck. Section 393.130(b) states that is must be “secured to the vehicle,” but does not specify how it is to be secured. This is an acceptable alternative under the regulations to applying tiedowns to the blade.