Interpretation ID: nht93-8.9

DATE: November 12, 1993

FROM: J. Z. Peepas -- Selecto-Flash, Inc.

TO: Taylor Vinson

TITLE: FAX#202-366-3820

ATTACHMT: Attached to letter dated 11/30/93 from John Womack to J. Z. Peepas (A41; Std. 108)

TEXT:

ATTACHED ARE 4 PRINTS, A-1, A-2, B-1, B-2 WHICH COVER THE FOLLING:

A-1 (40' CHASSIS) SHOWS 20' REFLECTIVE BEHIND THE GOOSE NECK FOR 40' CHASSIS WITH ONLY 6" PIECE WHITE REFLECTIVE MARKED ITEM 10, DELINEATING THE FRONT OF THE CHASSIS. THIS WILL LEAVE 8' CHASSIS UNMARKED AS DISCUSSED ON THE TELEPHONE.

A-2 (40' CHASSIS) WITH 20' REFLECTIVE FROM END OF GOOSE NECK BACK AND ADD ADDITIONAL REFLECTIVE FOR GOOSENECK.

B-1 (40/45' CHASSIS) SHOWS 50% OF THE REFLECTIVE FROM END OF GOOSE NECK TO END OF CHASSIS AND ONLY 6" PIECE WHITE REFLECTIVE AND DELINEATING FRONT OF CHASSIS.

B-2 (40/45' CHASSIS) WHICH ADDS ADDITIONAL REFLECTIVE ON GOOSE NECK EQUALLY SPACED.

WHEN I SPOKE ON THE TELEPHONE WITH YOU AND PAT BOYD, YOU INDICATED THAT AT LEAST 50% OF THE TOTAL LENGTH CHASSIS IN REFLECTIVE MATERIAL IS PLACED BEHIND THE GOOSE NECK. SINCE THE LOAD COVERS THE GOOSE NECK, YOU DID NOT SEE ANY NECESSITY IN PUTTING REFLECTIVE ON THE GOOSE NECK. HOWEVER, AT TIMES, A CHASSIS DOES MOVE WITHOUT A LOAD, AND THIS IN OUR OPINION, WILL CREATE A HAZARD, BECAUSE YOU WILL HAVE AN AREA OF 96" OR EVEN MORE DEPENDING ON DESIGN, WHICH WILL NOT HAVE ANY REFLECTIVE SHEETING ON IT.

IT WOULD BE OUR SUGGESTION THAT YOU RE-EVALUATE YOUR POSITION FOR NOT MAKING IT MANDATORY THAT REFLECTIVE SHOULD BE APPLIED ON THE GOOSE NECK.

I DISAGREE WITH THIS- 50% OF OVERALL LENGTH EVENLY SPACED FROM FRONT TO REAR (INCLUDING GOOSENECK) WITH A TOTAL OF 24'4" FOR A 48 FT. CHASSIS.

CHASSIS DO TRAVEL WITHOUT CONTAINERS AND WOULD THEN CREATE A SAFETY HAZARD WHEN:

1) ON THE HIGHWAY BY HAVING AN 8 TO 10 FOOT GOOSENECK NOT IDENTIFIED CREATING A SPACE THAT COULD BE CONFUSING TO A MOTORIST.

2) IN THE CONTAINER YARDS WHEN CHASSIS ARE OFF LOADED. SEVERAL INCIDENTS HAVE BEEN REPORTED WHERE A PANEL TRUCK WILL RIDE UNDER THE NOSE OF CHASSIS DRIVING IT THROUGH THE WINDSHIELD.

FINALLY WE UNDERSTAND THAT PAT BOYD HAS ADDRESSED THE ISSUE THAT NO MORE THAN FOUR FEET OF UNIDENTIFIED AREA SHALL BE ALLOWED ON A CHASSIS. OBVIOUSLY THE 8 to 10 FEET OF GOOSENECK WOULD BE IN VIOLATION OF THAT STATEMENT, FOR CHASSIS OFFLOADED ON A HIGHWAY.