Interpretation ID: nht94-1.42

TYPE: Interpretation-NHTSA

DATE: February 7, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Don Vierimaa -- Truck Trailer Manufacturers Association

TITLE: None

ATTACHMT: Attached to FAX dated 1/11/94 from Don Vierimaa to Pat Boyd (OCC-9595)

TEXT:

This responds to your FAX of January 11, 1994, to Pat Boyd of this agency requesting an interpretation of the trailer conspicuity requirements of Standard No. 108. In the future, please address your requests for interpretations to the Chief Counsel.

You have asked "may a manufacturer install a 4 inch (100 mm) wide retroreflective sheeting instead of 2 inch (50 mm) sheeting on the side of new trailers?"

Paragraph S5.7.1.3(d) of Standard No. 108 states that retroreflective sheeting shall have a width of 50 mm (Grade DOT-C2), 75 mm (Grade DOT-C3), or 100 mm (Grade DOT-C4). Paragraph S5.7.1.4.2(a), as amended on October 6, 1993 (58 FR 52021 at 52026), set s forth the requirements for application of retroreflective sheeting to the side of trailers. Without elaboration, it simply identifies it as "a strip of sheeting." This means that the manufacturer of the trailer is permitted his choice of Grade DOT-C2 , -C3, or -C4 material. Therefore, a manufacturer may install sheeting that has a width of 100 mm on the side of a trailer.