Interpretation ID: nht93-8.1

DATE: November 8, 1993

FROM: Herman Myburgh -- Executive Vice-President, Allvan Corporation

TO: John Womack -- NHTSA

TITLE: Re: FMVSS Part 571.108 on conspicuity striping on truck

ATTACHMT: Attached to letter dated 11/22/93 from John Womack to Herman Myburgh (A41; Std. 108)

TEXT:

We are manufacturers of curtainsided trailers where the curtain material wraps around the side rails of the trailer. Currently there are no retroreflective tape manufacturer who makes a tape that can stick to or can be RF. welded to the curtain material itself.

Could we attach the conspicuity striping to the trailer frame rail itself in such a manner that it will still comply with the latest amendment of "anywhere from 375mm to 1525mm above the ground"? This will be in the same manner as it will probably be applied to container chassis. Your response to this at your earliest convenience will be appreciated.