Interpretation ID: 9311
Operational Services
Genstar Container Corporation
505 Montgomery Street
San Francisco, CA 94111-2584
Dear Mr. Chung:
This responds to your letter of November 3, 1993, to Mr. Vinson of this Office, with respect to calculation of the application of conspicuity treatment to container chassis trailers.
The length of the gooseneck is included in determining the overall length of the trailer for purposes of calculating the half length that must be covered by the conspicuity treatment (which, of course, would be greater than half the length behind the gooseneck). For example, let us say that the overall length of the trailer is 40 feet, including an 8-foot gooseneck. The amount of the side to be covered is not less than 20 feet. The area to be covered is the 32 feet between the rear bolster to the point immediately behind the gooseneck's terminus. Thus, at least 20 feet of this 32-foot length must be covered in order to comply with Standard No. 108.
There is nothing in Standard No. 108 that precludes the application of retroreflective sheeting to the gooseneck. Indeed, some manufacturers may wish to do so to provide conspicuity of the trailer side when the trailer is traveling without its cargo. However, any conspicuity treatment on a gooseneck is not counted in determining whether at least half the trailer side is covered. I hope that this clarifies the matter for you.
Sincerely,
John Womack Acting Chief Counsel ref:108 d:11/29/93