Interpretation ID: aiam5270
FAX 1-615-459-0289 Dear Mr. Myburgh: This responds to your FAX o November 8, 1993, asking for an interpretation of the conspicuity mounting height requirement of Standard No. 108 as it applies to your curtainsided trailer. You state that there are no retroreflective tapes that can be affixed to the curtain material itself and ask whether the conspicuity material may be placed on the frame rail. The answer is yes. As you note, in that location the material will be located within the range of mounting heights specified in recent amendments to Standard No. 108. For your information, submissions to the docket during the course of this rulemaking indicate that there are conspicuity materials that can be affixed to curtain materials. Some trailer manufacturers may prefer this avenue to compliance. Sincerely, John Womack Acting Chief Counsel;