Interpretation ID: nht93-8.13

DATE: November 16, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Donald E. Schmitz -- Engineering Manager, Featherlite Mfg., Inc.

TITLE: None

ATTACHMT: Attached to letter dated 10/7/93 from Donald E. Schmitz to Howard M. Smolkin (OCC-9204)

TEXT:

This responds to your letter of October 7, 1993, to Acting Administrator Smolkin which "addresses the TTMA, September 8, 1993, Recommended Practice of Trailer Conspicuity Systems." You inform us that you "will begin applying the conspicuity tape to the trailer's bottom as shown" in the TTMA sketches, and "will assume our interpretation is correct . . . unless we receive a response from your office within ten days."

If you wish an interpretation of the TTMA drawings, you should consult that organization. This agency provides interpretations of Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment. With respect to paragraph S5.7, which establishes conspicuity system requirements for large trailers, effective December 1, 1993, the agency published an amendment on October 6, the day before your letter, which modified the mounting height requirements adopted in December 1992. The original requirement of "as close as practicable to 1.25 m above the road surface" has been changed to a range that is "as close as practicable to not less than 375 mm and not more than 1525 mm above the road surface...." I enclose a copy of the amendment for your information. See paragraph S5.7.1.4.2(a) for the change.