Interpretation ID: nht95-4.76

TYPE: INTERPRETATION-NHTSA

DATE: November 14, 1995

FROM: Terence J. Kann

TO: Ricardo Martinez -- Administrator, NHTSA

TITLE: NONE

ATTACHMT: 12/22/95 letter from Samuel J. Dubbin to Terence J. Kann (A43; Std. 108)

TEXT: I am writing to you concerning Standard No. 108, which amended 49 CFR Part 571 to require application of retro-reflective sheeting or reflex reflectors to provide for greater conspicuity of the sides and rear of trailers. I have the following question. Section S3, Application (a) provides that the standard applies to ". . . trailers (except pole trailers) . . .". Section S5.7 provides that "each trailer of 80 or more inches overall width and with GVWR over 10,000 pounds manufactured on or after 12/1/ 93, except a trailer designed exclusively for living or office use, shall be equipped with either retro-reflective sheeting . . . reflex reflectors . . . or a combination . . .".

My question is, are pole trailers such as those used in the logging industry, required to have retro-reflective sheeting, reflex reflectors, or a combination? If not, did the NHTSA issue any explanation for failing to extend the requirements to pole t railers? If yes, could you please provide a copy?

Thank you for your assistance. Please don't hesitate to call or write if you have any questions or comments regarding the above.