Compliance Chuck Polley

Grote is pleased to introduce Chuck Polley as our new Manager of Standards and Regulatory Affairs.  We all wish Don Weidman the best of luck in his retirement!

Q: Are clear lenses on rear stop, turn, and tail signal lamps legal?

A: This issue has been asked of NHTSA on more than one occasion and their reply is that if the lamp being replaced contains a red reflex reflector and the replacement lamp either does not contain a reflector or the reflector is clear, then the lamp is non-compliant with FMVSS-108. This is because 108 requires a vehicle to have two red reflex reflectors on the rear of the vehicle (less than 80 inches wide).

NHTSA also stated that they are not aware of any red incandescent light bulbs that meet the color requirements of 108, therefore those lamps with clear lenses and red incandescent light bulbs would be non-compliant.

Red LED stop, tail, turn signal lamps however do meet the color requirements of 108 and therefore are compliant with 108 when a clear lens is used providing the replacement lamp does not remove (eliminate) any required equipment such as a reflex reflector.

Q: What do the letters on my light mean?

 A: Most of the lamps you purchase today will have lettering on them that doesn’t seem to make any sense.  This lettering is the "SAE" identification code.  The Society of Automotive Engineers has been committed to improving the effectiveness and safety of your vehicles lighting.  They have developed a uniform identification code that is being used by all reputable manufacturers.  The code can be found in SAE J759 JUN2001 – Lighting Identification Code.

 Here is an example of a code you may see on a light. 

SAE = Indicates lamp has been designed to SAE specifications as indicated by the following letter codes.

A = Reflex Reflector, I = Turn signal, S = Stop Lamp, T = Tail lamp.   75 = the year lamp was certified.

DOT Indicates lamp has been tested and conforms to DOT Required Specifications, but does not indicate that the Department of Transportation or NHTSA has approved the lamp.

 Please remember that this is a voluntary code and NHTSA only requires codes on headlamps.  For a consolidated listing of the codes see the Grote Technical Catalog or contact SAE @ 877-606-7323 or CustomerService@sae.org

Q: Is it required for the driver to see the bottom rear side marker lamp or commonly called the tracking lamp?

A: Although most drivers will argue this fact, it is not required for the driver to be able to see the Red Tracking Lamp at the bottom rear side of the trailer.  It is a good idea for safety to use lamps that allow drivers to see how the trailer is tracking.  Especially when they are backing into  the dock or backing in general.  It makes it easier to (track) the rear of the trailer, thus the name Tracking Lamp.  Grote offers a number of lamps for this purpose.  One of the most popular styles is the "Beehive" Lamp.  (Looks like a beehive) and is easily replaceable.

When using LED lamps you might prefer to use a SAE "PC" rated lamp.  This will have a Red diode that can be aimed towards the front of the vehicle so the driver can easily see the lamp in his mirror.  Grote offers a variety of popular styles of this lamp.

Q: What is a "PC" clearance and marker lamp anyway and where should I use it?

A: A "PC" lamp is a rating by SAE designated to specific Clearance and Marker lamps. It is a lamp that can easily be seen from both the side as well as from the front. This lamp should always be used on trailers that use only one Clearance and Marker lamp in the front corner. That one lamp is mounted on a 45-degree angle so it can be seen from the front and side. Not all clearance and Marker lamps have a "PC" rating and if you use one that does not have this rating your driver can be ticketed.

Q: Can I remove the reflectors on my Trailer?

A: Yes, only if your trailer is properly equipped with D.O.T approved Conspicuity Treatment.  The Conspicuity Treatment must be installed at locations where the reflex reflector’s are normally required (reference FMVSS-108 paragraph S5.1.1.29).

Conspicuity Tape was required on all new trailers manufactured after December 1, 1993.

Then on March 26, 1999 The Federal Highway Administration (FHWA) issued a final rule, which requires older trailers to be retrofitted with a conspicuity treatment.  Any trailer manufactured before December 1, 1993 that are 80 inches or more wide and with GVWR of 10,001 or more pounds.  The effective date of the final rule was June 1, 1999.  Motor carriers are required to comply with the final rule by adding the RED & WHITE conspicuity treatment no later than two (2) years after the effective date of the final rule JUNE 1, 2001.

Motor Carriers that presently have trailers in operation with conspicuity treatment of a color different than RED & WHITE will have until JUNE 1, 2009 to comply.

Alternation RED/WHITE tape on the side and rear of each trailer.

·        12" WHITE Strips in the upper rear corners.

·        1 ½" wide strip of RED/WHITE tape on the horizontal bar of the rear I.C.C bumper.

·        50% of the length of the trailer shall be treated with 2" wide or two (2) 1" stripes applied no further than 1" apart.

Q: Can I add extra lights on my Truck, Tractor, Trailer or Body, over and beyond the legal requirements in FMVSS108?

A: Yes, however any additional lamps, must first meet all legal requirements for the intended location and function.  But more importantly they can’t detract from the intended lamps that are legally required.