Interpretation ID: nht93-7.49

DATE: November 3, 1993

FROM: Leo Chung -- Operational Services, Genstar Container Corporation

TO: Taylor Vinson -- Chief Counsel, NHTSA

TITLE: Re: Trailer Conspicuity Requirement of Federal Motor Vehicle Safety Standard no. 108: Lamps, Reflective Devices and Associated Equipment

ATTACHMT: Attached to letter dated 11/29/93 from John Womack to Leo Chung (A41; Std. 108)

TEXT:

We are one of the worldwide container leasing companies and I am writing to request any further interpretations of the captioned requirement which concerns our U.S. container chassis equipment operation due to the information we received from various sources giving different interpretations on the application of the side horizontal strip of conspicuity marking over 50% of the trailer length.

In order to comply with the law, please kindly clarify the actual definition of the trailer length and how the 50% computation applies to our container chassis because there are chances that this equipment will be running around with NO container being carried on top. Therefore, shall the gooseneck be included in the 50% computation and the length be the OVERALL length? (ie. measure from the very end point of one end to another)

Look forward to hearing from you soonest.