1. FMCSA 2015 Raw Numbers 3,260,350 Total Inspections
2,206,515 Vehicle Inspections
20.89% Vehicle OOS Rate

3. FMCSA has no restriction on “signage” on trailers

4. A couple of thoughts on Trailer Lighting

6. Clearance lamps (mounted low on Van Trailers)
FMVSS No. 108: Table I-a Heading Additional Lamps Required  on All Multipurpose Passenger Vehicles (MPV) Trucks, and Buses, 2032 MM or More in Overall Width
Clearance lamps 2 RED
Mounting height: As near the top as practicable, except where the rear identification
lamps are mounted at the extreme height of the vehicle..  Practicability of locating lamps on the vehicle header is presumed when the header extends at least 25 mm above the rear doors.
Allowed via FMVSS Table 1-a
…..so…what is the safety impact of having clearance lamps mounted high, when clearance lamps are mounted low on flatbed trailers…??

7. Auxiliary Brake Lamps

8. Can the rear identification 3-lamp cluster be used as auxiliary brake lamps?
Yes, by NHTSA interpretation.
Alloy Custom Products, LLC inquired as to whether or not the rear 3-lamp identification cluster may be used as auxiliary brake lamps.
Based on NHTSA interpretation this is allowed:
In an interpretation to Terminal Service Co. (Ricky Bass) on September 24, 1990, NHTSA states “As the triple cluster will continue to be illuminated, though with a somewhat greater intensity in the stop lamp mode, we do not consider that the device would impair the effectiveness of the identification lamps.”
In an interpretation to Lincoln County Fleet Services (Michael Lafon) on October 26, 1999, NHTSA states that they have “permitted identification lamps mounted at or near the top of a wide vehicle to serve as auxiliary stop lamps on the theory that the public is now conditioned to seeing high-mounted stop lamp arrays on many narrower motor vehicles and would perceive an increase in intensity of identification lamps as indicating that the brakes had been applied.”

9. Auxiliary Turn Signal Lamps
Clearance Lamps?
Yes, they can function as turn signals as long as they continue to operate as clearance lamps.
Auxiliary Turn Signal Lamps

10. Auxiliary Light Spacing

11. How much space must separate auxiliary lamps from required lamps?
NHTSA believes that positioning auxiliary lamps at a distance that is at least twice the distance that separates each lamp in the required 3-lamp cluster provides sufficient separation not to impair the effectiveness of the 3-lamp cluster. [Provided in a July 28, 2005 interpretation to the Truck Manufacturers Association (Robert Clark)]
Required rear identification 3-lamp cluster
Clearance lamp
Clearance lamp
Based on a NHTSA interpretation.

12. STEMCO Petition for Exemption

13. STEMCO Petition Requests an exemption to allow:
STEMCO is requesting an exemption on behalf of motor carriers utilizing TrailerTails to allow trailer clearance and identification lamps to be moved to the lower rail.
This would allow the top TrailerTail panel to be installed flush with the roofline of the trailer, further improving aerodynamics.
Requests an exemption to allow:
Clearance and ID lamps to be moved to the lower rail
Top TrailerTail™ panel to be mounted flush with roofline

14. TrailerTail™ Technology
Current configuration SAE certified to deliver 5.54% fuel efficiency gains at 65 mph
New configuration will further increase fuel efficiency
Currently the top panel is mounted 1.5 – 3.5 inches below the roofline of the trailer to satisfy the visibility requirements of the rear identification clearance lamps. With this configuration there is a 5.54% fuel efficiency gain at 65 mph based on SAE Type II testing. STEMCO’s testing has shown that mounting the top panel flush with the trailer’s roofline will further increase annual diesel fuel savings by eliminating the unaerodynamic gap that disrupts the airflow transition.
This change in configuration will help motor carriers meet the proposed Greenhouse Gas Phase 2 Regulation as well as current requirements from the California Air Resources Board (CARB) Tractor-Trailer Greenhouse Gas regulations (in effect since 2010).

15. Rear Underride Repairs to damaged underride supports
What support do manufacturers provide to carriers?
Certification labelling – years later?
FMCSA regs point to NHTSA regs
Should be more of an inuse/maintain regulation

16. FMCSA Vehicle and Roadside Operations Division – Mike Huntley - Chief
Luke Loy, Sr. Engineer
Jose’ Cestero, Sr. Engineer
Amina Fisher, Sr. Engineer