Interpretation ID: nht93-7.30

DATE: October 20, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: James Z. Peepas -- Selecto-Flash, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 7/26/93 from James Womack from James Z. Peepas (A41; Std. 108) and letter dated 7/9/93 from James Z. Peepas to Taylor Vinson (OCC-8871)

TEXT:

In a recent letter of interpretation on the trailer conspicuity requirements of Standard No. 108, which are effective December 1, 1993, we informed you that "()f 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 word "without" is incorrect, and should be replaced with the word "with", in accordance with the requirement of S5.7.1.4.2(a) that conspicuity treatment not be obscured by trailer cargo. We are sorry for any inconvenience that this error may have caused you.

Our letter also informed you that we were considering a petition for reconsideration of the mounting height requirements for the conspicuity treatment. On October 6, 1993, the agency published its response to this petition, modifying the mounting height requirement to a range between 15 and 60 inches (375 to 1525 mm). I enclose a copy of the amendment for your information.