Interpretation ID: nht93-8.24

DATE: November 22, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Herman Myburgh -- Executive Vice-President, Allvan Corporation

TITLE: None

ATTACHMT: Attached to letter dated 11/8/93 from Herman Myburgh to John Womack (OCC-9292)

TEXT:

This responds to your FAX of November 8, 1993, asking for an interpretation of the conspicuity mounting height requirement of Standard No. 108 as it applies to your curtainsided trailer.

You state that there are no retroreflective tapes that can be affixed to the curtain material itself and ask whether the conspicuity material may be placed on the frame rail. The answer is yes. As you note, in that location the material will be located within the range of mounting heights specified in recent amendments to Standard No. 108.

For your information, submissions to the docket during the course of this rulemaking indicate that there are conspicuity materials that can be affixed to curtain materials. Some trailer manufacturers may prefer this avenue to compliance.