Fleetline Products, Inc.
P.O. Box 298
Springfield, TN 37172
Dear Mr. Lavender:
This is in reply to your letter of March 28, 1997, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108.
You state that you have received "verbal" answers to certain questions from the Office of Safety Performance Standards and need a written confirmation of these answers from the Office of Chief Counsel. You wish to supply parts to "heavy duty truck manufacturers" that meet Standard No. 108, and are concerned with sheeting to be applied to the rear fenders, mud flaps or mud flap support brackets.
My initial comment is that we encourage manufacturers to seek written interpretations directly from the Office of Chief Counsel. Only the written interpretations of the Office of Chief Counsel are binding.
My second comment is to note that the conspicuity requirements of Standard No. 108 apply only to heavy trailers and to truck tractors that are 80 or more inches in overall width. Thus, a manufacturer wishing to add conspicuity sheeting to rear fenders, mud flaps or mud flap brackets of a straight truck need not follow Standard No. 108. Nevertheless, in the belief that standardization enhances safety, we encourage voluntary compliance with the conspicuity requirements for straight trucks as well.
The interpretations for which you seek confirmation are:
"The sheeting must be in a pattern of alternating red and white segments. The individual segments must be 300mm long plus or minus 150mm, i.e. from 150mm to 450mm long."
Yes. The specifications stated in paragraph S220.127.116.11(a) and (b) for the side and rear of trailers and truck tractors apply also to rear fenders, and mud flaps and their support brackets.
"There is no requirement for the color pattern to begin or end in either color. The inboard and outboard segments may be either red or white."
You are correct. The text of Standard No. 108 speaks of "alternating white and red color segments" (S18.104.22.168(a)) while Figure 30-1 through Figure 30-4 show red and white segments installed. However, there is no requirement that the color pattern begin or end with either color, or that inboard and outboard segments be red or white.
"There is no requirement for the tape to be completely free of discontinuities. On the brackets which have a 45 degree angle, the tape does not have to be cut in a miter joint."
Paragraph S22.214.171.124(a) specifies that sheeting "need not be applied to discontinuous surfaces" and provides several examples of these. We assume that this is what you mean by your statement. There is no requirement that tape be cut in a miter joint.
"Minor trimming of the tape to conform to the shape of a bracket is acceptable, provided the length measured on the center line of the tape is a minimum of 600mm. On the drawing included with this memorandum one corner of the tape is trimmed. This is acceptable."
Minor trimming of the tape is acceptable, as shown on your drawing. The length measured on the center line of the sheeting may be any length from 600mm to 900mm. (300mm +/- 150mm x 2).
"The drawing included with this memorandum illustrates a proposed bracket satisfying FMVSS 571.108."
The drawing shows an acceptable solution to mounting conspicuity material on a mud flap bracket.
If you have any further questions, you may refer them to Taylor Vinson of this Office (202-366-5263).
Acting Chief Counsel