NHTSA Seeking Comments on Trailer Retroreflective Materials Conspicuity

March 27, 2015
The National Highway Traffic Safety Administration (NHTSA) is asking for public comment on a proposed collection of information on Title: 49 CFR Section 571.108, Compliance Labeling of Retroreflective Materials Heavy Trailer Conspicuity.

The National Highway Traffic Safety Administration (NHTSA) is asking for public comment on a proposed collection of information on Title: 49 CFR Section 571.108, Compliance Labeling of Retroreflective Materials Heavy Trailer Conspicuity.

Federal Motor Vehicle Safety Standard No. 108, ``Lamps, reflective devices, and associated equipment,'' specifies requirements for vehicle lighting for the purposes of reducing traffic accidents and their tragic results by providing adequate roadway illumination, improved vehicle conspicuity, appropriate information transmission through signal lamps, in both day, night, and other conditions of reduced visibility. For certifications and identification purposes, the Standard requires the permanent marking of the letters ``DOT-C2,'' DOT-C3'', or DOT-C4'' at least 3mm high at regular intervals on retroreflective sheeting material having adequate performance to provide effective trailer conspicuity.  The manufacturers of new tractors and trailers are required to certify that their products are equipped with retroreflective material complying with the requirements of the standard.

The Federal Motor Carriers Safety Administration (FMCSA) enforces this and other standards through roadside inspections of trucks. There is no practical field test for the performance requirements, and labeling is the only objective way of distinguishing trailer conspicuity grade material from lower performance material. NHTSA says that without labeling, FMCSA will not be able to enforce the performance requirements of the standard and the compliance testing of new tractors and trailers will be complicated.

NHTSA says labeling is also important to small trailer manufacturers because it may help them certify compliance. Because wider stripes or material of lower brightness also can provide the minimum safety performance, the marking system serves the additional role of identifying the minimum stripe width required for retroreflective conspicuity of the particular material.

Comments must be received on or before May 26, 2015.