Interpretation ID: nht93-4.32

DATE: June 13, 1993

FROM: Charlie McBay -- Chief Engineer, Barrett Trailers, Inc.

TO: Office of Chief Counsel, NHTSA

TITLE: Conspicuity

ATTACHMT: Attached to letter dated 7-14-93 from John Womack to Charlie McBay (A41; Std. 108)

TEXT:

This letter asks that the Office of Chief Counsel review the enclosed drawings (Model 80MP6-DD & GNXS-207) for compliance of the upcoming conspicuity treatment.

As you can see, both models have "outside post" design and air gaps that run through the sides and rear of the trailer. Air gap quantity and locations vary with different designs.

2" red and white alternating pattern used on sides and rear. 2" white on upper rear corners.

Note: Location of side material as close to 4ft. off the ground as possible. In the center the location stays on the bottom rail (due to air gaps) and ranges from 14" to 20" off the ground.

Reflector material to be a 14" strip placed in center of each opening between side post. This length meets the 50% coverage requirements.

Note that post spacing throughout the length of the trailer is not the same. Evenly distributed material will be in most areas, but breaks between material vary. Will this suffice for evenly distributed? Also, if we have an area where a minimum 12" strip will not fit, can we install smaller material or must this area stay blank?

Note that white strips in upper rear corners do not meet. Must white be touching or can there be a gap between the strips? Our design makes it near impossible to make a nice continuous square corner. Installation of the white corners is also closer than 3" from red top rail lights. Is there any tolerance on the 3" dimensions? One full width red and white strip on rear of trailer on both models as close to 4ft. off the ground as possible.

Enclosed are drawings of proposed installation as close as we can get to meeting the requirements outlined. (The yellow hi-lited areas represent reflective Material)

I would welcome any comments and ask that our installation have your approval.

Attachments omitted:

Drawing of Model 80MP6-DD and drawing of GNXS-207.