Interpretation ID: aiam5198
Inc. P.O. Box 879 Orange
NJ 07051;
"Dear Mr. Peepas: We have received your letter of July 9, 1993, t Taylor Vinson of this Office requesting interpretations of the trailer conspicuity requirements of Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment. Your questions are directed towards a 48-foot container chassis, but in a telephone conversation with Mr. Vinson you have explained that a 40-foot container chassis is also involved. For simplicity's sake we shall refer to trailers of both lengths collectively as the 'trailer'. The gooseneck on the trailer is 8 feet long. Paragraph S5.7.1.4.2(a) of Standard No. 108 specifies in pertinent part that the side horizontal strip of retroreflective sheeting 'need not be continuous as long as not less than half of the length of the trailer is covered.' You have asked whether the length of the gooseneck is included in the 50% computation. The answer is yes. The gooseneck is similar to a trailer tongue, and is included in determining the overall length of the trailer for purposes of compliance with Standard No. 108. From the photos you enclosed, we see that retroreflective sheeting has been applied to the gooseneck and the frame rail with approximately the same spacing between segments. If you determine that this configuration meets S5.7.1.4.2(a) without the container load in place, there would be no need to increase the amount of retroreflective sheeting on the trailer behind the gooseneck. The same paragraph also requires that retroreflective sheeting shall be located 'as close as practicable to 1.25 m. above the road surface.' You enclosed a photo of a Maersk loaded chassis and note that 'because of space limitations, the striping may not be 4 foot (sic) from the road surface.' You have asked whether there has been a change in height allowance to compensate for space adjustments. The agency has been petitioned for reconsideration of this specification, and to allow a mounting height as low as the 15 inches originally proposed. We have not reached a determination on this point, and the height remains at 4 feet. However, if the manufacturer of a new trailer determines that something less than 4 feet is 'as close as practicable to 1.25 m. above the road surface' with respect to a particular trailer design, it may certify conformance of the trailer with the mounting height requirement on that basis. Finally, paragraph S5.7.1.4.2(a) requires that the spaces between sheeting be 'distributed as evenly as practicable.' In a telephone call on July 16, you informed Mr. Vinson that in some instances equal spacing may not be possible because of trailer unit numbers and other identification, and structural characteristics. As we have advised in the preceding paragraph, the requirement is modified by what is practicable under the circumstances. Sincerely, John Womack Acting Chief Counsel";