The Transportation Safety Equipment Institute (TSEI) reports that its member companies are seeing an increase in requests from both trucking fleets and trailer OEMs to add innovative lighting devices that enhance visibility and improve communication with nearby drivers.
Some of these devices, which are supplemental to the required lighting and conspicuity devices installed on vehicles, have caused confusion among fleets, trailer OEMs and roadside inspectors as to their permissibility under applicable regulations. TSEI is actively working with regulators and the industry to ensure that all interested parties understand the scope of permissible use of such supplemental lighting.
More frequently, users are requesting additional high-mounted auxiliary turn and stop lamps on trailers, reports Brad Van Riper, Chairman of the Government Relations Committee at TSEI and Senior Vice President/Chief Technology Officer at Truck-Lite Co., Inc. of Falconer, NY.
TSEI, through its member companies, has been communicating its position to trailer OEMs and truck fleets. This configuration is applicable as long as it follows the minimum federal standards established by the Federal Motor Vehicle Safety Standard (FMVSS) No. 108 as well as the applicable Federal Motor Carrier Safety Regulations (FMCSRs) in Part 393, specifically including Subpart B, sections 393.9 - 393.30. TSEI has summarized the criteria applicable to high mounted auxiliary turn and stop lamps:
- Required lighting devices are installed per the requirements of the standard.
- The installed supplemental or auxiliary lighting adds to or supplements the required lighting devices.
- The supplemental lighting does not impair the effectiveness of the required devices
- The supplemental lighting is not to be installed in a manner that would cause confusion (e.g., no strobing, supplemental, red stop lamps in jurisdictions that do not allow them).
“It's critical that in meeting this request for better visibility during the stop function, we do not reduce the effectiveness of the primary function for the device at its particular location,” explained Kristen Goodson, TSEI President and Director of Product Management at Peterson Manufacturing Company of Grandview, MO. “TSEI members have been working to produce lighting solutions that provide the optimal balance between the primary function of the device and it's advanced warning capabilities.”
Although some have expressed concern about how new supplemental lighting configurations may be treated during roadside inspections, TSEI learned that roadside enforcement is well versed in the limitation set by FMCSR 393.9 and only required lamps must be operational. Roadside inspection officers consider three important guidelines when it comes to additional equipment, with respect to Part 393.3, whereby it may be used if:
1. It is not prohibited by regulation (such as amber tail/stop lamps).
2. It is not inconsistent with regulations (such as purple/green lights)
3. It does not decrease the safety of operation (as referenced in FMCSA’s 393.11 Interpretation)
TSEI believes that high mounted auxiliary turn or stop lamps are enhancements that can increase safety, providing that care is taken by fleets and OEMs who are implementing them to follow these guidelines and comply with the regulations. If so, their presence on vehicles should not negatively impact the good CSA scores of conscientious drivers and fleets. TSEI is committed to ensuring that assessment of these supplemental lighting enhancements is reliable and consistent across the roadside inspection program. TSEI’s goal is to achieve universal consensus regarding permissibility of use of these configurations under applicable regulations including FMVSS-108 requirements and Federal Motor Carrier Safety Regulations.
Significant technological advances are occurring in the truck and trailer lighting industry. Many of the proposed improvements will improve safety and reduce accidents. Being able to properly inspect and maintain the vehicle lighting and wiring system is one of the most important ways to ensure that vehicles operate safely.