Reflective Tape

[jjoerger]

We are in the process of replacing all the reflective tape on the rear of our straight truck. Peeled all the old stuff off, sanded the rear bumper and repainted. Getting ready to apply the new tape.
The location for this tape is covered under FMCSA 393.11.
There is a nice drawing of a straight truck in Figure 2. However, since our truck is more than 80 inches wide our rear tape must meet the same requirements as a semi trailer. See figure 8. The horizontal top (near the box floor) and bottom (near the ground) portions of the bumper have to be covered. Also the upper outside corners of the rear doors must have the L shaped reflector that you see on the back of all semi trailers. I very rarely see this on a straight truck, but a nice SC DOT officer explained it to me as a courtesy one night and showed me where to find it in the regs.
Here's a link: Part 393.11: Lamps and reflective devices. - Federal Motor Carrier Safety Administration

 

[greg334]

DO NOT buy cheap tape.
​

A lot of the tape they sell at truck stops are not up to DOT standards.

Buy it from a trailer repair center (not T/A) if you can.

 

[jjoerger]

We bought a 100' roll from a trailer supply company. It is marked DOT approved on the tape. Got it on ebay for $64.95.

 

[TeamCaffee]

I am reading through the regulations on 393.11 and 393.13 and there is nothing about straight trucks and Retroreflective Sheeting and Reflex Reflectors. All of the regs that I am reading is on trailers and semi trailers.

The pictures of the straight trucks when I read the footnotes it says nothing about the sheeting or the tape.

What am I missing?

I am reading in the FMCSA handbook

 

[greg334]

That's a good price but even if it is marked DOT approved, it may not be.

See the way the DOT works is the manufacture does not have to submit a product for their approval but can mark it approved. It is a self-approved system and works pretty well for most products. It is only when there are complaints - I think there is a formula that they use to trigger an investigation - is when they actually get one and test it.

A good example is HID conversion kits, NOT one of them meets the DOT standards as a conversion kit to replace the headlamp bulbs but a lot of them are marked DOT approved. The problem with the kits is not with the kits themselves but with the headlamps, they are not designed for the HID bulb itself, hence the light is scattered and for some blinding. (Personally I like HID systems because it doesn't blind me in my mirrors or head on.) SO the DOT decided to ban the kits to make it easier for them to police the problem.

So back to the reflective tape. The problem I ran into is not with the reflective quality but rather with the lack of adhesive that bonds the tape together. I had some Chinese made crap and some junk made in India that both within a year separated and fell apart.

I try to use 3M products.

BUT nevertheless, it is a great thing you bringing this subject up with the CSA 2010 thing happening.

 

[davekc]

Don't see anything either about having reflective tape on the mud flaps of a straight truck.

 

[TeamCaffee]

I am not talking mud flaps I am talking the whole back of the truck. I not see anything on the back of the truck.

 

[davekc]

My reference to mud flaps was related to another post that stated someone was cited for failure to have mudflaps taped.
Didn't see it in the provided example. Only mudflap hangers on tractors is what I thought.

 

[greg334]

Dave,
The mudflap issue I am talking about are the weights on the bottom of the flaps, we here are told that a reflective or stainless steel weight is not allowed.

Linda,
Try 393.26, maybe?

393.13 are specific to trailers made before 1983 and 393.11 has to do with lighting, which is referenced by 393.26

States also have some different requirements.

 

[davekc]

We are good there. We don't have any weights on the mud flaps.

 

[jjoerger]

Linda,
I failed a Speedco DOT Annual Inspection because I did not have the L reflectors at the top of the doors.
After leaving the Speedco I had the tape applied and was reinspected and passed.
A few days later I talked with a SC DOT inspector and asked about the requirements for a straight truck. He told me that since our boxes are about the same height and width (over 80 inches wide) we are supposed to use the same diagram as a semi trailer. According to the inspector that I talked with the straight truck in the diagram is a box van or something like a small uhaul.

 

[ATeam]

Sadly, not every scale cop gets it right. Nor does every mechanic that does DOT inspections.

Looking at the illustrations here, rear upper body marking (Figure 8, item 9) is clearly required for semi trailers. No such marking is shown on the illustrations for straight trucks (Figures 2-6). I would make the argument to the scale cop that the difference clearly shown means that no rear upper body marking is required on a straight truck body.

That may not be enough to keep him from writing the citation anyway, in which case I would appeal to a supervisor if one was available and eventually a judge if it came to that. If it went to court and I won, I would next make a big stink about the incompetent scale cop that wrote an undeserved citation.

Posts like this give us good practice and a renewed familiarity with the rules. At an actual scale stop, it makes it easier for us to quickly present familiar illustrations and make our case.

 

[TeamCaffee]

Greg 393.26 refers back to 393.11 which is for trailers.

Jim, Speedco would have to show me where in the FMCSA book the regulation is located.

We have the conspicuity tape on the back of our box because it is not worth the hassle of arguing the point with a DOT officer.

 

[ATeam]

We have the conspicuity tape on the back of our box because it is not worth the hassle of arguing the point with a DOT officer.

A valid point. There are the rules and then there are situations that can be avoided by making certain accomodations.

 

[jjoerger]

I've been informed by a reliable source and qualified DOT inspector that the Speedco and SC DOT were both wrong in there interpretation of this reg.

There is a federal regulation that discusses the tape so arranged on a trailer and that is in part 393.13. Nowhere does it mention anything other than a trailer.

However, since I already have it on and it looks good I am going to leave it. It will make our truck more visable at night and in adverse weather conditions. I think it will also keep an overzealous LEO from giving me a citation that I will have to challenge.

 

[greg334]

Just like the mud flap issue, states do not have to follow everything in that green book and may require trucks in their state to have that.

What gets me is the idea that less is good, I would think that having those reflective material would actually be a good thing and the concern with any hassle from any the DOT officer would be the least of a concern to put them on.

 

[cheri1122]

My reference to mud flaps was related to another post that stated someone was cited for failure to have mudflaps taped.
Didn't see it in the provided example. Only mudflap hangers on tractors is what I thought.

Only on tractors is right - it's meant to improve visibility of bobtails, and should not apply to straight trucks. A violation was issued when one LEO decided a tractor is a tractor, whether with or without the capability to bobtail, and must therefore have the reflective tape on the mudflap hangers.
It is easier to put the tape on than argue with a LEO - or would be, if I could figure out how to attach it securely to the flaps. Any suggestions?

 

[Brisco]

I am reading through the regulations on 393.11 and 393.13 and there is nothing about straight trucks and Retroreflective Sheeting and Reflex Reflectors. All of the regs that I am reading is on trailers and semi trailers.

The pictures of the straight trucks when I read the footnotes it says nothing about the sheeting or the tape.

What am I missing?

I am reading in the FMCSA handbook

Look at the link JJ posted again:

Part 393.11: Lamps and reflective devices. - Federal Motor Carrier Safety Administration

Right below that chart is a "Legend."

Legend: Types of commercial motor vehicles shown in the last column of Table 1.

Now look at item "B" in that "Legend."

B. Buses and trucks 2,032 mm (80 inches) or more in overall width

Now go back to the chart and look at the last column all the way down that chart.

Vehicles for which the devices are required

"B" does not specify "trailer" only, as is worded here above that chart:

(b) Conspicuity Systems. Each trailer of 2,032 mm (80 inches) or more overall width

That's probably what's throwing everyone off. In that chart, it clearly shows that if your "Truck" is 80 inches or more in overall width, then Yes, your "Truck" needs to have the same markings as a "Trailer" has to have.

Heck, if you notice, "B" is listed in every one of those requirements except the last one, "Parking Lamps".



Hope this Helps!

 

[Yesteryear]

This is the part I am not understanding. When I was pulled over in Georgia for a level one DOT Inspection that was the violation given. Said reflection tape has to be at both the top and bottom of the bumper. Now here is the clincher, he gave me a passing DOT sticker for the truck even though he put on the DOT inspection a violation for not having the tape on the bottom of the bumper. So I think I failed the inspection however I was given a passing sticker.

Was stopped again in Texas by another DOT officer who was going to give me a citation for not having white reflective tape at the top of the box. I told my husband (my husband was awake this time), he told me to ask for the statue the officer was going by. All previous stops he was asleep. I asked the officer what statue he was using and he went back to his car for about 15 minutes then came back and told me that he was letting it go since I have marker lights at the top of the box the white reflective tape was not required. He is the same one that gave the violation because one of the straps on the fire extinguisher was almost (not quite) broken, even though it was still securely held in place by a clamp and a second strap. lol Think it made him mad about the statue. Hubby wanted me to ask for his supervisor but I did not want to make waves so just took the violation.

 

[highway star]

You still got the sticker because it wasn't considered a critical violation. My back-up lights weren't working during a level 1 but I still got a sticker. I was told to take care of it when ever I had the time. I would think that silly holder strap deal would be the same.