Interpretation ID: 9595
Truck Trailer Manufacturers Association
1020 Princess Street
Alexandria, VA 22314
Dear Mr. Vierimaa:
This responds to your FAX of January 11, 1994, to Pat Boyd of this agency requesting an interpretation of the trailer conspicuity requirements of Standard No. 108. In the future, please address your requests for interpretations to the Chief Counsel.
You have asked "may a manufacturer install a 4 inch (100 mm) wide retrofrelective sheeting instead of 2 inch (50 mm) sheeting on the side of new trailers?"
Paragraph S5.7.1.3(d) of Standard No. 108 states that retroreflective sheeting shall have a width of 50 mm (Grade DOT-C2), 75 mm (Grade DOT-C3), or 100 mm (Grade DOT-C4). Paragraph S5.7.1.4.2(a), as amended on October 6, 1993 (58 FR 52021 at 52026), sets forth the requirements for application of retroreflective sheeting to the side of trailers. Without elaboration, it simply identifies it as "a strip of sheeting." This means that the manufacturer of the trailer is permitted his choice of Grade DOT-C2, -C3, or -C4 material. Therefore, a manufacturer may install sheeting that has a width of 100 mm on the side of a trailer.
Sincerely,
John Womack Acting Chief Counsel
ref:108 d.2/7/94