What trailer manufacturers must know about federal lighting requirements

TO clear up misconceptions regarding the revised FMVSS 108 rule that became effective December 1, 2012, Ed Patterson Sr took attendees through the changes and how they affect trailers.

A last-minute emergency prevented Patterson—manager of photometric testing for Intertek and a former member of the Society of Automotive Engineers (SAE) Lighting Committee—from delivering the presentation in person. A substitute, however, delivered his thoughts.  

The National Highway Traffic Safety Administration (NHTSA) had portions of SAE documents in FMVSS 108 for years, but had to take out most of references to them.   There were 14 changes identified from the previous standard to the rewritten standard, including nine changes that impact the manufacturing, testing, and validation practices.

Patterson listed required documentation for lighting components:

• Copy of the Lamp Suppliers Certification for each lamp type you purchase.

• Get a copy of the suppliers AMECA, “Certificate of Accreditation.”

• Obtain a copy of any other current quality certifications they have: A2LA, ISO.

• Demand a copy of the complete test report, with data, from the certifying testing laboratory. “Keep these documents in a permanent, secure, file,” he said. “Make sure there are multiple copies located in different places. This is your protection in case of a NHTSA audit.”

The following is a basic outline of the lighting requirement sets of trailers.

Required lamps on under-80” trailers:

• Turn signals. Two red or amber lamps. On the rear, at the same height, symmetrically about the vertical centerline, as far apart as possible. Not less than 15” nor more than 83” off ground. Must flash when the turn signal is actuated by the signal operating unit.

• Tail lamps. Two red lamps or one red lamp (on a trailer less than 30” wide). Mounted on the rear at the same height, symmetrical about the vertical centerline, and as far apart as possible.

• Stop lamps. Two red lamps or one red lamp (on a trailer less than 30” wide). Mounted on the rear at the same height, symmetrical about the vertical centerline, and as far apart as possible. When a single lamp is used, it must be mounted at or near the vertical centerline. Mounted not less than 15” nor more than 72” off ground. Steady burning—must be activated upon activation of the brakes. When optically combined with a turn signal, the stop lamp must override the turn flashing and be steady burning.

• Sidemarker lamps (front). Two amber. None required on trailers less than 1829mm (6 feet) in overall length, including the trailer tongue. Mounted on the front as far forward as possible, excluding the trailer tongue. Not less than 15 inches above the ground. Steady Burning, but may flash with turn signals.

• Sidemarker lamps (rear). Two red. Mounted on each side, as far to the rear as possible mounted not less than 15” nor more than 60” off ground.

• Reflex reflectors. Two amber: None required on trailers less than six feet in overall length, including the trailer tongue; mounted on the front as far forward as possible, excluding the trailer tongue; mounted not less than 15” nor more than 60” off ground. Two red, or one red lamp (on a trailer less than 30” wide): mounted on each side, as far to the rear as possible; mounted on the rear at the same height, symmetrical about the vertical centerline, and as far apart as possible; when a single lamp is used, it must be mounted at or near the vertical centerline.

• License plate lamp. One white. Additional lamps permitted to meet requirements. Mounted on rear to illuminate license plate from top or sides. Lamps must be steady burning.

Required lamps on under 80” trailers, but 30’ or over in length:

• Intermediate side marker lamps. Two amber. Mounted on each side, at or near the midpoint between the front and rear sidemarkers. Mounted not less than 15” from ground. Steady burning, but may flash with turn signals.

• Intermediate side reflex reflectors. Mounted on each side, at or near the midpoint between the front and rear sidemarkers. Mounted not less than 15” nor more than 60” from ground.

Required lamps on over-80” in overall width trailers:

• Clearance lamps. Two amber: mounted on the front to indicate the overall width of the vehicle, at the same height, symmetrically about the vertical centerline; may be located at a location other than the front if necessary to indicate the overall width of the vehicle, or for protection from damage during normal operation of the vehicle; mounted as near the top as possible; steady burning.

Two red: mounted on the rear to indicate the overall width of the vehicle, at the same height, symmetrically about the vertical centerline; may be located at a location other than the rear if necessary to indicate the overall width of the vehicle, or for protection from damage during normal operation of the vehicle; mounted as near the top as possible, except where the rear identification lamps are mounted at the extreme height of the vehicle. Practicability of locating lamps on the vehicle header is presumed when the header extends at least 25mm (1”) above the doors. ♦

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