SURGE BRAKE UPDATE On October 7, 2005 the Federal Motor Carrier Safety Administration issued Docket No. FMCSA -2005-21323, requesting comments on Proposed Rulemaking which will “officially” make hydraulic surge brakes legal for use in commercial operations. Previous to this, on September 14, 2004, the Agency (FMCSA) published an Enforcement Policy Concerning Trailers Equipped With Surge Brakes. This Policy, sent to all Field Administrators, Division Administrators and State Directors, and National Law Enforcement Teams, allowed the use of surge brake trailers operated in interstate commerce, provided certain conditions were satisfied. These conditions were simply: • For trailers 12,000 lbs. and less the GVWR of the trailer cannot exceed 1.75 times the GVWR of the tow vehicle. • For trailer with a GVWR greater than 12,000 lb. up to 20,000 lbs., the GVWR of the trailer cannot exceed 1.25 times the GVWR of the tow vehicle. In other words, if you are pulling a 20,000 lb. GVWR trailer with surge brakes you must be using a towing vehicle with a GVWR of at least 16,000 lbs., e.g., a Ford F-450 or the like. In the lighter case if you tow a 12,000 GVWR surge brake trailer, the tow vehicle must have a GVWR of at least 6900 lbs. Although the comment period closed on December 6, 2005, no decisions have been forthcoming from the FMCSA. GUIDE FOR CHECKING THE REAR LIGHTS, AND REFLECTORS ON BOAT TRAILERS The placement of the stop, turn, and tail lamps, and reflex reflectors on the rear of boat trailers needs to provide adequate photometry and visibility, per Federal Regulations. Based on SAE standards referred to in the Federal Motor Vehicle Safety Standards for Lighting (FMVSS 108) the rear lamps, and reflectors, must be viewable from 45 degrees either side of the extended centerline of each lamp. Use the following steps when evaluating the placement of your rear lamps and reflectors: 1. Go rearward 10’ (about 3 paces) from the right side light, and then go 3.6’ (about 1 pace) to the left (toward center of trailer). At light level (0 degrees), and up to +/- 10” up and down, you must be able to see ALL of the light emitting surface. At light level you must also be able to see the whole light emitting surface of the rear reflex reflector. 2. Go further to the left another 6.7’ (another 2 paces-making a total of 10’ off light center). At light level you must be able to see about ½ of the lamps projected illuminated lens area (minimum 2 sq. in.), not including the reflex reflector. No check is required here for the reflector portion. 3. From this inboard position, go back to the right 8.3’ (1.7’ left of light centerline), and then go up and down 20” from light level. At all 3 positions you must still see ALL of the light emitting surface. At light level you must still be able to see the entire light emitting surface of the reflex reflector. 4. Go back to the extended centerline of the light. Go up and down 20” from light level. At all 3 positions you must see ALL of the light surface. Going up and down 10” you must see the entire light emitting surface of the reflex reflector. 5. Repeat steps 1-3 when going to the outside (right) of the trailer’s right rear light. 6. Repeat Steps 1-5 for light and reflector on left rear side of trailer if there are any differences in the left and right rear sides of the trailer. Dick Klein is a registered Professional Engineer. Mr. Klein has a BS in Mechanical Engineering from Syracuse University and a MS in Aerospace Engineering from the University of Toronto. His expertise is primarily in the area of combination vehicle dynamics, stability and control, handling qualities, and driver behavior. Mr. Klein also has experience in trailer design and components, and as such he provides technical services to many trailer manufacturers. Furthermore, Mr. Klein conducts combination vehicle accident /vehicle investigations throughout the U.S. for numerous insurance companies, associations, and law firms.