A look at revised guidelines

THE NATIONAL ASSOCIATION OF TRAILER MANUFACTURERS (NATM), giving its interpretation of the FMVSS 108 re-write, has added a page to the 11th revision of its “Guidelines for Recommended Minimum Manufacturing Practices for Light and Medium Duty Trailers.”

During a convention session on the guidelines, NATM Technical Committee Chairman Michael Terry presented the “NATM Guide For Conducting Rear Lighting Compliance Audits for Stop, Turn, and Tail Lamps, and Rear Reflex Reflectors.”

“It's very simple to walk back and stand behind that trailer,” Terry said.

Added consulting engineer Dick Klein, “This is basically a how-to dealing with how far forward you can mount the rear stop, turn, and tail lights on a trailer so they can still be seen properly.”

They listed these steps:

  • Go rearward 10' (about three paces) from the right side tail light, along the extended centerline of the light. From light level (0 degrees), go up 20" and down 20" (+/-10 degrees), you must see all of the light-emitting surface in all three positions. Also, from light level (0 degrees), go up 10" and down 10" (+/-5 degrees), and you must see all of the light-emitting surface of the rear reflex reflector in all three positions.

  • Next, from this 10' position behind the light, step to the left 1.7' (10 degrees, about one-half pace) toward the center line of the trailer. From this inboard position at light level (0 degrees), go up 20" and down 20" (+/-10 degrees), and you must still be able to see all of the light emitting surface in all three positions. Also, at light level (0 degrees), you must still be able to see all of the light-emitting surface of the rear reflex reflector from this position.

  • Then, step to the left again (about another one-half pace) toward the center line of the trailer to a position 3.6' (20 degrees) left of the centerline of the light. From this position at light level (0 degrees), go up 10" and down 10" (+/-5 degrees), you must still be able to see all of the light-emitting surface in all three positions. Also, at light level (0 degrees), you must still be able to see all of the light-emitting surface of the rear reflex reflector from this position.

  • Now step further to the left (about another two paces) towards the center line of the trailer, to a position 10' (45 degrees) left of the centerline of the light. From this position at light level (0 degrees), you must be able to see at least about one-half of the light-emitting surface of the lamps projected illuminated lens area (a minimum of two square inches), not including the reflex reflector. No check is required here for the reflector portion.

  • Repeat steps 2, 3, and 4 while going to the outside (RIGHT) of the trailer's right rear tail light.

  • Repeat steps 1 through 5 for tail light and reflector on LEFT side of trailer, if there are any differences in the left and right rear sides of the trailer.

Talking about all of the changes they made in general to the guidelines, Terry said: “This is a beginning point for your company's manufacturing minimums. It is not fully comprehensive. We can't answer every question or detail on all the variations within an organization. The guidelines address the most common component parts. We can't take care of all of them.

“It's not only good business policy to follow the guidelines, but for safety, also. Safety is one of the main issues we face today. Even though we're competitors, we have common issues we need to resolve together.

“When we started, the purpose was for member services, but they've grown to be a whole lot more. Today, we're trying to provide information for end users and provide them with safe, dependable products that meet, and exceed, federal and state regulations. Hopefully, we'll build a safer product and our insurance rates will be reduced, and it'll be a better product for everybody.”

Terry said the guidelines do not: help legislate trailers; serve as “Trailer Building For Dummies”; help someone select proper tow vehicles or match the hitch to the coupler; or load trailers, receive cargo, or make a pre-tow checklist.

Tackling other issues

Other sections discussed:

  • Section A-3: They said that the National Highway Traffic Safety Administration (NHTSA) and Federal Motor Carrier Safety Administration (FMCSA) both have jurisdiction over trailer manufacturers — NHTSA primarily and FMCSA secondarily, if it's a commercial application.

  • Section B-2 (brakes): NATM added a surge-brake enforcement policy. “The law has not yet been changed, but there is a way in which FMCSA wants it enforced,” Terry said. “For years, it's been illegal to have surge brakes on commercial interstate vehicles. They are not allowed for certain weight ratios of tow vehicles and trailers.” All FMCSA enforcement personnel have been instructed to cease issuing citations for violations of 49 CFR 393.48 and 393.49 for instances in which an inertial surge-brake system is used on: a trailer with a GVWR of 12,000 lb or less, provided its GVWR does not exceed 1.75 times the GVWR of the towing vehicle; or a trailer with a GVWR greater than 12,000 lb, but less than 20,001 lb, provided the GVWR does not exceed 1.25 times the GVWR of the towing vehicle.

  • Section B-3 (couplers and safety devices): NATM added the Society of Automotive Engineers' (SAE) J2638, an informational report dealing with fifthwheel and gooseneck trailer attachment at or below 30,000 lb Gross Trailer Weight (GTW) and of components necessary to tow these trailers. It likely will become a recommended practice later this year, and regulatory authorities may use this standard to formulate regulations. (See full story in NATM coverage.)

  • Section C-1 (excise tax): Trailers under 26,000 lb are exempt from excise tax, so NATM includes guidelines for calculating the excise taxes. Featherlite's Norm Helmke said the Internal Revenue Service uses its own standards, irregardless of what NHTSA says. “We've had a lot of questions about how to calculate it,” Klein said. “Be very careful. Just because your axles are below 26,000 lb doesn't mean the Feds are going to allow that to happen, because they know the trailer GVW should be greater than 26,000 lb. For example, a lot of guys will say, ‘I want you to rate this trailer 25,999 GVWR,’ and you put two 12k axles on it, or three 8 ks. The IRS is not going to buy it. They know the real GVWR is higher than that. They have a way of calculating it based on the length of the trailer, load, and axle capacity — what it really should be.” Said Helmke, “If you use this methodology to set the GVWR, you should be OK.”

  • Section C-5 (safety recall): NATM has added two templates for US recalls: one for those caused by a vendor's component and one for those caused by something a company manufactured. They were developed from a Safety Recall Compendium issued by NHTSA. “Your responsibility is to notify the consumer, the dealer,” Helmke said. “My experience is that all you will get back in response is 50-55%. I've had one experience when I got less than that, and NHTSA came back after six quarterly reports were filed and said, ‘We want you to file four more.’ We had to send out a second notification. Typically, if you haven't gotten a big surge after six to eight months, send out a second notice. That should suffice. NHTSA hasn't been very onerous about getting on you about the results. If you're getting 50%, you should be all right.”

  • Section C-6 (Standard Industry Classification): “Any time you are reporting federal government statistical data, especially when you get the industrial surveys, please use the correct SIC code,” Terry said. “It gives us a lot more clout overall.”

  • Section E-3 (state agencies): NATM lists state requirements for business registration and management licenses. “If you've ever tried to start a new business in California and tried to reach the right person the first time, you needed a lot of luck,” Terry said. “It's not easy. This information in the book makes life a whole lot better for all of us.”

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