Partition and bulkhead requirements

From an NTEA member We are a truck equipment distributor that regularly installs partitions and bins and racks in cargo vans. A customer asked if our partitions are crash-rated for new vans, but we haven’t found any requirements directly related to partitions. Do partitions have crash ratings? As OEM van products continue to evolve, it’s a good opportunity to review existing requirements as they may apply to these upfits. It may seem like there is a test for just about everything in a vehicle, and some Federal/Canadian Motor Vehicle Safety Standards (F/CMVSS) that require dynamic tests can be indirectly affected by installation of equipment such as a partition. But there is no F/CMVSS performance test directly relating to the crashworthiness of a partition. However, similar requirements from other sources can be considered if seeking partition performance evaluation criteria. A bulkhead (or front-end structure) is one potentially similar structure with strength requirements on commercial vehicles, such as trailers. Federal Motor Carrier Safety Regulations (FMCSR) contain a set of requirements, found in 49 Code of Federal Regulations (CFR) Part 393.114, which apply to “commercial motor vehicles transporting articles of cargo that are in contact with the front-end structure of the vehicle.” While vans would not typically meet the definition of a commercial motor vehicle and fall under specifics of these regulations, the CFR includes size, strength and penetration resistance requirements (see reference section on page 10 at end of article). Lacking more specific requirements, these criteria can provide a basis for evaluating design performance. Canada has similar requirements for heavy trailers, and Canada Occupational Health and Safety Regulations require the country’s employers to equip vehicles up to 10,000 pounds gross vehicle weight rating (GVWR) with a partition of some form “where there is a likelihood that materials, goods or things will shift and endanger employees in a motor vehicle.” A similar requirement exists for passenger vehicles in Europe, which includes seating systems evaluation. ECE Regulation 17 evaluates performance of seat backs against “the displacement of luggage in a frontal impact.” This portion of the regulation also includes testing of partitioning systems, such as “netting or wire mesh located above the level of the seat-backs”. Since the term crash-rated can mean different things depending on customer perspective, finding the source of their concerns can help determine what to evaluate. Whether it involves partition integrity during a crash or other dynamic test-related issues, check with the partition manufacturer first to see if it performed testing that can provide some representation of crash performance to the customer. Such customer requests arise periodically, especially when newer vehicles are entering the market. Staying current with safety advancements incorporated by manufacturers of the products you install can help you prepare. Following are noteworthy indirectly-related F/CMVSS for partition installations that should be evaluated for potential effects. F/CMVSS 111: Rear Visibility F/CMVSS 201: Occupant Protection in Interior Impact F/CMVSS 202a: Head Restraints F/CMVSS 214: Side Impact Protection F/CMVSS 216a: Roof Crush Resistance FMVSS 226: Ejection Mitigation F/CMVSS 302: Flammability of Interior Materials Note these standards largely apply to vehicles with a GVWR of 10,000 pounds or less, consistent with the existing range of cargo van ratings, but F/CMVSS 301 and portions of F/CMVSS 111 also apply to vehicles above this GVWR. Cargo vans are typically completed vehicles and certified by the OEM to meet these F/CMVSS, so maintaining compliance with applicable requirements is generally achieved by thoroughly following partition manufacturer installation instructions. For reference “§393.114 What are the requirements for front end structures used as part of a cargo securement system? Applicability. The rules in this section are applicable to commercial motor vehicles transporting articles of cargo that are in contact with the front end structure of the vehicle. The front end structure on these cargo-carrying vehicles must meet the performance requirements of this section. Height and width. The front end structure must extend either to a height of 4 feet above the floor of the vehicle or to a height at which it blocks forward movement of any item or article of cargo being carried on the vehicle, whichever is lower. The front end structure must have a width which is at least equal to the width of the vehicle or which blocks forward movement of any article of cargo being transported on the vehicle, whichever is narrower. Strength. The front end structure must be capable of withstanding the following horizontal forward static load: For a front end structure less than 6 feet in height, a horizontal forward static load equal to one-half (0.5) of the weight of the articles of cargo being transported on the vehicle uniformly distributed over the entire portion of the front end structure that is within 4 feet above the vehicle’s floor or that is at or below a height above the vehicle’s floor at which it blocks forward movement of any article of the vehicle’s cargo, whichever is less; or For a front end structure 6 feet in height or higher, a horizontal forward static load equal to four-tenths (0.4) of the weight of the articles of cargo being transported on the vehicle uniformly distributed over the entire front end structure. Penetration resistance. The front end structure must be designed, constructed, and maintained so that it is capable of resisting penetration by any article of cargo that contacts it when the vehicle decelerates at a rate of 20 feet per second, per second. The front end structure must have no aperture large enough to permit any article of cargo in contact with the structure to pass through it. Substitute devices. The requirements of this section may be met by the use of devices performing the same functions as a front end structure, if the devices are at least as strong as, and provide protection against shifting articles of cargo at least equal to, a front end structure which conforms to those requirements.”

Partition and bulkhead requirements

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