A quick glance around any truckstop parking lot will soon reveal the absence, inadequacy or inappropriate placement of the white or red and white reflective tape. These are known as “conspicuity treatments” that the FMCSA regulations require on trailers and the rear of truck tractors.  It is the responsibility of each driver to ensure proper markings are on their trucks and trailers. The absence, inadequacy, or inappropriate placement of reflective tape can attract attention that could lead to a level I inspection.  At the present time, a roadside inspection that reveals a failure to comply with conspicuity sheeting regulations could subject a driver to three CSA severity weight points and have an impact on their carrier’s safety rating.

Everything a driver needs to know is contained in Title 49 of the Code of Federal Regulations, §393.11(b) and in its cross reference of the Federal Motor Vehicle Safety Standard No. 108 which is also in 49 CFR 571.108.  These references are not particularly reader friendly, so I will summarize here so you can use the information to ensure you are compliant. 
 

These regulations cover trailers manufactured on or after 12/01/1993 and the necessity to retrofit trailers built before that date, and truck tractors built on or after 07/01/1997.  The regulations also discuss dimensions in millimeters, so I’ve converted them to nearest inch for ease of understanding.

The conspicuity treatments discussed here are either “retroreflective sheeting” (white strips of vinyl tape or red and white strips of vinyl tape) or similarly colored “reflex reflectors” (plastic reflectors, commonly with adhesive backing).  Each strip of sheeting must be not less than 2 inches wide.  The letters DOT-C2 (2”), DOT-C3 (3”), or DOT-C4 (4”), as appropriate, must appear at least once on the exposed surface of each white or red segment of retroreflective sheeting, and at least once every 12 inches on retroreflective sheeting that is white only.  Conspicuity sheeting is sold in truck stops and service centers and is often referred to as “Conspicuity Tape”, “Conspicuity Reflective Tape”, “Truck Reflective Tape” or “Reflexite Conspicuity tape”

Simply speaking, tractors require alternating red and white tape on the mudflap brackets and white reflective tape on the upper rear corners of the cab.  Trailers must be reflectorized with alternating red and white reflective tape on the sides, bottom of doors and the ICC bar; also, two pieces of white tape must be on each upper rear corner.  The specific requirements are as follows:

TRACTOR TREATMENT

Two strips of red and white sheeting, each not less than 2 feet in length, must be fastened as close as practicable to the rear and the outer edges of the tractor.  This means a two foot strip on each mudflap support bracket, on plates attached to the support brackets or on the mudflaps.  If your truck has no mudflaps or brackets, the strips of tape must be fastened to the fenders, and if there are no fenders or mudflap brackets, the strips must be fastened to the rear of the cab.  In the later case, no more than 25% may be obscured by other vehicle equipment.

Also on rear of the tractor, four strips of white sheeting, each at least one foot in length.  Two strips mounted horizontally as far as practicable to the uppermost outer right and left edges of the cab and two strips mounted vertically as far as practicable to the top outermost right and left edges of the cab.

TRAILER TREATMENT - sides

Trailers affected by these regulations are those that are at least 80 inches or more in width and have a GVWR over 10,000 pounds.

The alternating red and white sheeting must be applied horizontally on each side of the trailer.  It must be no closer to the road surface than 15 inches or higher than 60 inches above the road.  The sheeting must start as far forward as practicable and continue to as far to the rear of the trailer as practicable but it doesn’t have to be continuous.  The sheeting may be evenly spaced and must cover at least half the distance of the length of the trailer.  So, a 53 foot trailer must have a minimum of 26 ½ feet of the red and white sheeting on each side.  When applying the sheeting, make sure that the white section does not come within 3 inches of a red or amber light and the red section within 3 inches of an amber lamp.

TRAILER TREATMENT - rear

Retroreflective sheeting must be applied to the rear of each trailer as follows, except that Element 2 is not required for container chassis or for platform trailers without bulkheads, and Element 3 is not required for trailers without underride protection devices (ICC Bar):
  • Element 1: A strip of sheeting, as horizontal as practicable, in alternating colors across the full width of the trailer, as close to the extreme edges as practicable, and as close as practicable to not less than 15 inches and not more than 60 inches above the road surface at the stripe centerline with the trailer at curb weight.
  • Element 2: On rear of the trailer, four strips of white sheeting, each at least one foot in length.  Two strips mounted horizontally as far as practicable to the uppermost outer right and left edges of the cab and two strips mounted vertically as far as practicable to the top outermost right and left edges of the trailer.
  • Element 3: A strip of sheeting in alternating colors across the full width of the horizontal member of the rear underride protection device (ICC Bar).
STRAIGHT TRUCK TREATMENT                           

From the rear, straight trucks often have the same appearance as a dry van or reefer trailer; however, Federal regulations do not require conspicuity sheeting on straight trucks.  I believe the safety conscious among us will continue to apply the red and white retroreflective sheeting to the sides and rear of their straight trucks in the same manner as required for trailers.

DRIVER RESPONSIBILITY AND CSA

Trucking Safety, and the FMCSA program known as CSA, are constantly on the minds of carriers, drivers and law enforcement officials.  The Compliance, Safety and Accountability (CSA) program is a fluid project that is evolving and changing due to challenge by proactive carriers and public and private associations.  Therefore, it is important to remain current and aware of any defect that will contribute to an unsafe situation or alert a law enforcement officer of a potential defect.

Truck and trailer manufacturers, outfitters and repair facilities do not always apply the conspicuity sheeting as specifically required by the FMCSA.  It is the responsibility of each driver to ensure proper markings are on their trucks and trailers, so it’s important to not attract any attention that could lead to a level I inspection.  Make sure you are compliant with the reflective tape requirements to avoid getting CSA points and have an impact on your carrier’s safety rating.
 
 
 
 

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Comment ()


Shirl: If you were displaying the two foot long red/white tape on each mudflap bracket and the four 1 foot long white tapes on the rear of your cab as indicated in my comment concerning the tractor regulation, then you would be in compliance with 393.11. If so, you would be well served by submitting a DataQ request and have the 3 CSA points removed from your CSA score. From the tone of your comment, I suspect you believe that if a trailer is attached to the tractor, the reflective tape and perhaps the mudflaps are not required. I have found no distinction in the regulations that would support that common belief

September 04, 2013 19:19:10 PM

Terry,
We were cited for violation of 393.11 as it applies to a Tractor. We were in fact pulling a trailer at the time during daylight hours. The trailer was in compliance and as a combination the Tractor reflective tape can not be seen from the rear. Just thought I would add to the conversation........ Thanks

September 04, 2013 13:51:32 PM

Ray:
The regulations at 393.11 direct us to have our retroreflective material meet the requirements in the Federal Motor Vehicle Safety Standards (FMVSS) number 108. This reference further states that the retroreflective tape must be in conformance with the American Standard for Testing and Materials (ASTM). These references discuss the photometric requirements. Who among us carry a light meter to check the lumenosity of our reflective material.

Our government does not provide the lay person very good guidance concerning your question. So, it all boils down to common sense. If you are missing significant pieces of tape, and the tape no longer reflects much light; if the tape on your flatbed rub rail is excessively scuffed; if the ICC bar tape is worn from dock lock abrasion and you think it is no longer effective, a DOT officer might feel the same as you and use the defective reflectors as an excuse to pull you over

December 04, 2012 7:12:15 AM

I see a lot of trailers where the red/white tape is so old and eaten up that they seem useless. Do the regs say anything about when you should have to replace them. I know it should be common sense, but anytime I have mentioned to my company about them needing replaced it seems to fall on deaf ears and is never done.

December 02, 2012 8:18:54 AM

Great info!

November 29, 2012 8:26:27 AM

Great info and very helpful. I am leaseed to a carrier and am constantly connecting to different trailers. This will help in making sure that these trailers are compliant.

I'm sure Terry will correct me if I am in error but I don't believe that there are any regulations on the Federal side (DOT/FMCSA/CSA) regarding mudflaps. If you are to be cited for a mudflap violation it will be for violating a states' rules.

November 12, 2012 13:32:10 PM

Shalom: The regulations state that Element 2 is not required for container chassis or for platform trailers without bulkheads. It doesn't specifically mention or exempt soft sides, however the sheeting must be applied to a rigid part of the vehicle, so one could argue if no rigid area to apply, it would not be required.

November 04, 2012 10:32:46 AM

great info. Terry, Thanks.
i have to wonder, howcome NO curtinSide trailer have any of the Element2 strips ?
same goes to 'side load' steel trailers.

November 03, 2012 13:05:43 PM

Very informative.

November 02, 2012 10:01:42 AM

Yeah I have to keep up with the tape. Sometimes it gets torn or scarped

November 01, 2012 9:00:49 AM

Terry - The comments on the mud flaps keeps running around in my mind as I am under the impression all trucks have to have mud flaps or some kind of protection around their drive tires of the tractor. That led me to my next thought about the fenders I am seeing and I do not know the name for then but they completely cover the drive tires and come down behind the last tire almost to the ground. The fenders are usually painted to match the truck and I do not remember seeing any reflective tape on these. From what I am reading that would be they are opening themselves up for possible CSA points and a violation?

November 01, 2012 7:07:42 AM

Awesome information Terry, thanks for the insight!

October 31, 2012 15:03:56 PM

An important topic covered well -- thanks terry!

October 31, 2012 9:03:35 AM

Terry, This is a interesting subject and after reading this I am amazed how many trucks and trailer do not have the proper conspicuity markings.

October 31, 2012 8:18:23 AM

Thanks Mike.. My intent was to introduce an oft misunderstood requirement that stands out when markings are incorrect and easy and inexpensive to permanently fix; no batteries nor wires required

October 29, 2012 18:22:13 PM

Terry very interesting and thanks for breaking it down! We are in a straight truck and like you mentioned even though not required we have the correct red and white retroreflective sheeting to the sides and rear of our box. I have had fun as I am driving down the road looking at trucks and trailers as they pass me to see all of the very odd configurations I see of the conspicuity sheeting.

October 29, 2012 17:04:29 PM

Thanks Terry. This is a question I get asked about from time to time. I am going to print off your article and share it.

October 29, 2012 16:50:28 PM

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About Terry OConnell

After a 30 year U.S. Coast Guard career, Terry and his wife René, obtained their CDLs and began a 19 year adventure in expediting. In 2008, he entered his third career working for the Safety Department of an interstate carrier.

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