Interpretation ID: nht94-2.95

TYPE: INTERPRETATION-NHTSA

DATE: May 17, 1994

FROM: Larson, Victor -- P.E., Cryenco, Inc.

TO: Womack, John -- Acting Chief Counsel, NHTSA

TITLE: Reference: Conspicuity Striping Requirements

ATTACHMT: Attached To 10/14/94 Letter From Philip R. Recht To Victor Larson (A42; STD. 108)

TEXT: Cryenco is a manufacturer of cryogenic tank trailers. Our trailers are cylindrical in shape and in most cases, have no side mounting surface for striping that is perpendicular to the road, except at the center of the tank (at the 3:00 and 9:00 positions ). This is at a height of approximately 90" above the ground. Additional structures would have to be added to the sides of the trailer to provide lower mounting surfaces that are at the 1.25m height. In our interpretation of the rule, which is based o n phone calls with NHTSA and 3M striping performance specifications, the side striping 1.) Can legally be placed at a height of 90" above the ground, if that is the only available vertical mounting area, and 2.) it is not necessary to add additional stru cture for the sole purpose of providing a lower vertical mounting surface for the side striping. Please advise if this interpretation is correct.

Additional limited side mounting areas are sometimes available. For instance, some cryogenic transports have a rear cabinet that is approximately 4' long. Some also have a midship undermounted cabinet. These locations provide limited lower areas for si de striping to amount to, approximately 4' to 6' length each, that could be used for striping location. However, if striping is mounted to these surfaces and to the remaining areas above, (on the tank at the 3:00 and 9:00 positions and 90" height), the result is a fragmented, non-aligned striping pattern that is not visually pleasing, and which Customers object to. Since transporters are highly interested in visual impact they sometimes find this pattern unacceptable. Would compliance be satisfied if the side striping was placed only at the higher (90" above the ground) location, where the predominant available vertical mounting surface is found?

Requests to mount the side striping lower on the tank, to better fit-in with their graphics, have been received. In one instance, if this were done, the side striping would be rolled down from the 3:00 and 9:00 positions to about the 4:30 and 7:30 posit ions. This would place the side striping on an area of the tank that angles downward approximately 30 degrees. The striping manufacturers do not certify to meet the reflectivity requirements at compound angles exceeding 15 degrees down, combined with t he horizontal angles indicated in the rule. The general feeling among transporters and striping suppliers is that the rule is not definitive about the angular orientation of the striping, i.e. that there is no need to have the striping mounted on a surf ace that is perpendicular to the road. Please verify what the requirement is relative to orientation of the striping for conspicuity.