msgjd
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In NY this is not the case anymore. It definitely is not being enforced and the Feds no longer require it.. Between 2016 and 2019 I ran mostly interstate for part of every year with a company that had about 60 units. Only a quarter of the tractors had headache racks and they were in dump trailer service or hauling logs... Their flatbed trailers do not have bulkheads and the tracs they assigned to flatbed service don't have headache racks .. I'm not saying this practice is wise, but I don't see a headache rack stopping certain common loads from coming thru your backside .. I would never want to run a flatbed load of layered material without a very sturdy bulkhead, or at least the means to make some sort of adequate securement across the front of the load.. The presence of a bulkhead on a flatbed truck or trailer allows the driver to legally place straps further apart (there is a spacing reg)... But I know many who practice "there's no such thing as too many straps." And of course see people with their Home Depot loads or whatever who throw on a strap or two and apparently say "good to go!"If your trailer has no headboard then your tractor needs a headache rack behind the cab. Have neither and prepared to be violated by hungry DOTs.
.. which reminds me of the fella I saw lay two freshly-filled 100-pound propane tanks in the back of his pickup, no straps, shutoff valve cover first .. The guy that had filled them suggested they be secured and turned around.. The driver blew him off.. Imagine what those torpedoes could do in an abrupt stop or head-on if those caps get torn off their threads.
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