1. Lighting / Conspicuity Tape 2. Tires 3. Safety Chains 4. Couplers 5. Fenders / Mud Flaps 6. Structures 7. Surge Brakes 8. VIN / Cert labels 9. GVWR 10. Exporting 11. Dimensions FREQUENTLY ASKED QUESTIONS From Trailer Manufacturers Lighting / Conspicuity Tape QUESTION: Is conspicuity tape that is marked DOT C-2 legal with our company logo imprinted on it? ANSWER: According to a NHTSA interpretation dated 10/06/2000, yes, an excerpt from this interpretation is as follows: Your next question is whether conspicuity markings that incorporate a logo would "qualify as conspicuity markings under FMVSS 108." S5.7 prescribes dimensions for the width of the sheeting and the length of the individual segments. As noted above, a logo could be inserted in otherwise conforming sheeting if the sheeting meets the photometric, color, and all other requirements with the logo in place. You have also asked whether "conspicuity markings that incorporate a logo [are] taken into account when assessing conformance to FMVSS standard 108." The coefficients for retroreflection of each segment of red and white sheeting must be not less than the minimum values specified in Fig. 29 of Standard No. 108. In determining conformance with S5.7, if a logo prevented a segment of sheeting from complying with the photometric or any other requirement, we would consider that the segment failed to comply with Standard No. 108. Thus, the answer to this question is yes. To read the entire interpretation, please visit our site. Tires QUESTION: What can you tell us about keeping records of the serial numbers of tires purchased, then issued to trailers? Many of the tires we get have no serial numbers on the tires. Should we be refusing them from the suppliers? ANSWER: All tires are required by law to have a DOT number stamped on them. If you EVER receive a tire without a DOT number, reject it!!!! You should record these DOT numbers and attach to the “build sheet” (manufacturer’s record) for that trailer. This is in the event there is ever a recall. The key item on the DOT # is the last 4 digits, which specifies the “month and year” of manufacture, e.g. 0903 = 9th month of 2003. The rest are manufacturers’ codes. QUESTION: We have heard that there are new Tire Labeling Requirements for trailers issued by the Federal Government. Is this true? ANSWER: Yes. A new label is required to be on all new trailers as of September 1, 2005. QUESTION: Do all trailers need to have the Tire Label applied? ANSWER: The new Tire Label that is required on trailers manufactured after September 1, 2005 is only required on trailers that have a GVWR of 10,000 lbs. or less. However, I recommend including information for determining correct load limit for all trailer weights, as well as the tow vehicle. QUESTION: What size (dimensions) does the new Tire Safety Label have to be? ANSWER: There are no specific dimensions given for this new label, except the tire on the label must be 13mm x 14mm. But remember, it must be in color; specifically is must be yellow text on black background or black text on yellow background and have a red box. QUESTION: My competitors are providing “used” tires (as an option) on their trailers. Is this allowable? ANSWER: According to Section 571.120 (Federal Motor Vehicle Safety Standards), “Tire Selection and Rims for Motor Vehicles Other than Passenger Cars,” each vehicle equipped with pneumatic tires for highway service must be equipped with pneumatic tires that meet the requirements of 571.119, “New Pneumatic Tires for Vehicles Other than Passenger Cars.” There is one exception. Paragraph S5.1.3 of §571.120 states that “In place of tires that meet the requirements of Standard No. 119, a …trailer may at the request of the purchaser be equipped at the place of manufacture of the vehicle with retreaded or used tires owned or leased by the purchaser, if the sum of the maximum load ratings meets the requirements of S5.1.2.” So, if your customer brings his “used” tires to your plant AND the tires are of an acceptable maximum load rating for the Gross Axle Weight Rating (GAWR) AND were originally manufactured in compliance with Standard No. 119, you may install them on his new trailer. To cover yourself you should have the customer sign a statement, or release, that he has provided his own tires and the manufacturer is not responsible for them. QUESTION: Are passenger rated tires allowed on trailers? We get only “ST” tires, but I still see many “P” rated tires on trailers. ANSWER: Passenger tires are allowed on trailers; however the individual maximum load capacity of the tire must be reduced 10%. The total adjusted tire capacities on any axle must then be equal to or greater than the GAWR specified on the Certification/VIN label for that axle. QUESTION: How do I know I have the sized proper tires on my trailer? ANSWER: Look at the VIN / Certification label on the front left side of the trailer. This will have the proper tire size, and inflation pressure, printed on it. You can check this by looking at the Maximum Load Rating stamped on the sidewall of the tire. This load rating (when multiplied by 2 - for the 2 tires on the axle) must be equal to, or greater than, the Gross Axle Weight Rating (GAWR) printed on the VIN / Certification label. Safety Chains QUESTION: Is there an exception to the Safety Chain Requirement on the Gooseneck style trailer if the trailer is equipped with a King Pin on the Adjustable tube instead of the standard Ball coupler? I have been told that the RV (camper style King Pin units) are not required to have safety chains. ANSWER: Safety chain usage is controlled by each state. The Government Affairs Division did a safety chain survey a year or two ago and found that many states exempt 5th-wheel king pin assemblies. We do not know how that relates to goose neck trailers using a ball attachment. The only way to know is to seek guidance from the involved state and see how their rules of the road read. Not all states address safety chains and not all states exempt the 5th wheel hitch. QUESTION: I am looking for information regarding safety chains and the requirement to use clips/clasps attached to the hook end of the safety chain. We understand the requirement for each safety chain's strength to exceed the total GVWR of the trailer. We also use weldable joining links that attach the safety chains to the trailer. Please explain the required use of hooks, and where they are required. ANSWER: The safety chain requirements are controlled by each state, except for the overall strength and details specified in SAE J684, which is available from the SAE. Therefore, you would have to check each state to determine if they have a special requirement for the "S" hook, or clip/clasp. For example, California and Canada do require “positive locking” clasps on the safety chains. Couplers QUESTION: I need to know if there is a law stating that 10,000 GVW trailers cannot use a 2” ball coupler. ANSWER: There is nothing preventing the use of a 2" coupler on a 10,000 lb. GVWR trailer. However, the 2" coupler must meet the coupling requirements of a Class 4 trailer classification. The coupler must obviously be rated at 10,000 lbs. or greater. QUESTION: Is there a law stating that 10,000 lb. GVWR trailers cannot use a 2” ball coupler? ANSWER: There is no “law” preventing the use of a 2” coupler on a 10,000 lb. GVWR trailer. However, according to SAE Standard J684 (Trailer couplings, hitches, and safety chains), the 2” coupling would have to meet Class 4 strength requirements, and be rated (stamped on the coupler) for 10,000 lb. trailer capacity. Since there are no SAE recognized classifications higher than Class 4, any couplers rated higher than 10,000 lbs. would have to be certified by the coupling manufacturer, including the appropriate hitch ball size. Fenders / Mud Flaps QUESTION: Are there any requirements about fenders coming down a certain length over the wheels ? ANSWER: There are no requirements for fender coverage. There is an SAE "mud flap" standard but this is specified on a state by state basis. QUESTION: Are there any Federal Requirements regarding mud flaps on trailers? ANSWER: There are no federal requirements (e.g. in 49 CFR 393); however, there is an SAE Recommended Practice, J682 "Rear Wheel Splash and Stone Throw Protection" from October 1984 that several states reference in this area. Basically J682 says that "mud flaps" are required if the ratio of the bottom of the trailer bed to the length from the bottom of the wheel to the end of the trailer is > 1:3. In other words, if the bottom of the frame, at the end of the trailer is, say, 25", then the center of the rear wheels must be more than 75" from the back of the trailer. If it is less than 75," then you need flaps of a length to restrict the ratio to the 1:3 number. Structures QUESTION: Are there any structural design regulations, specifications, standards, etc. that we could use in the structural design of our trailers? ANSWER: No. The design of the trailer structural components is totally left to the manufacturer. There are stress analysis (Finite Element Analysis) computer programs available, and they may be of use for assessing localized stress points, but the selection of structural components, e.g., frame rails, cross-members, etc. is your decision. Checking your final selection against what is used by other reputable manufacturers is also a solution. Surge Brakes QUESTION: Are surge brakes now legal? ANSWER: Yes. As of September 14, 2004, the Federal Motor Carrier Safety Administration (FMCSA) sent a letter to all Field Administrators, National Enforcement Teams, and Division Administrators and State Directors to the effect that they should no longer ticket trailers with surge brakes. Of course this only applies to interstate commerce, but in general all the states go by these rules (for intrastate commerce) or they have adopted their own surge brake rules. QUESTION: We are a small boat trailer manufacturer currently making trailers under 10,000 pounds GVWR. However, we are considering making larger trailers and we are not sure about the laws requiring surge brakes. We see some of our competitors offering electric over hydraulic saying it is required by law, while others do not offer it saying it only applies to commercial vehicles. I am concerned that if we are selling to one of our dealers who in turn sells it to a retail customer to haul his boat it would be legal, but since we are a company I would assume we would be considered a commercial entity and be breaking the law if we tried to deliver. ANSWER: Currently, there is a Petition, before the FMCSA to legalize surge brakes for commercial applications. In the meantime, the FMCSA has temporarily approved the use of surge brakes, via an Enforcement Bulletin (issued Sept 14, 2004), as long as a specific tow vehicle to trailer weight ratio is maintained. The ratio is as follows: For trailers having a GVWR> 12,000 lbs. the trailer GVWR cannot exceed 1.25 times the tow vehicle GVWR. For example, a 16,000 lb. GVWR trailer must be towed with a tow vehicle having a GVWR of at least 12,800 lbs. For trailers below 12,000 lbs,. the weight ratio is reduced to 1.75. For example, a 10,000 lb. GVWR trailer must be towed with a tow vehicle having a GVWR of at least 5,714 lbs. Remember, all this has to do with COMMERCIAL operations. For personal use of surge brake trailers there are NO Federal laws. These are controlled only by specific state statutes. For example, Maryland recently passed a law that allows surge brakes on trailers up to 10,000 lbs. GVWR. VIN / Cert labels QUESTION: Are there any laws requiring VINs or S/Ns to be stamped on the trailer frame? ANSWER: The only state that I am currently aware of that has this type of legislation is Tennessee. SECTION 1. Tennessee Code Annotated, Section 55-5-106, is amended by adding the following language as a new, appropriately designated subsection: (f) (1) After December 31, 2004, any new trailer manufactured in this state and intended for sale to the general public within this state shall be required to have stamped upon such vehicle's metal tongue or metal frame a vehicle identification number. The required vehicle identification number shall not be the same as the vehicle identification number of any other trailer manufactured by the same manufacturer. (2) After December 31, 2004, no new trailer shall be sold to the general public in this state unless such trailer shall bear a vehicle identification number stamped upon such vehicle's metal tongue or metal frame which shall not be the same as the vehicle identification number of any other trailer made by the same manufacturer. (3) As used in this subsection, "trailer" means every vehicle with or without motive power, designed for carrying persons or property and for being drawn by a motor vehicle and so constructed that no part of its weight rests upon the towing vehicle. QUESTION: Is the information on the (VIN) label required to be in a certain order? ANSWER: 49 CFR Section 567.4 (g) that states that the label shall contain the following statements, in the English language, lettered in block capitals and numerals not less than three thirty-seconds of an inch high, in the order shown: 1. Name of manufacturer 2. Month and year of manufacture 3. “Gross Vehicle Weight Rating” or “GVWR” 4. “Gross Axle Weight Rating” or “GAWR” 5. The statement: “This vehicle conforms to all applicable Federal Motor Vehicle Safety Standards in effect on the date of manufacture shown above.” 6. Vehicle identification number 7. The type of classification of the vehicle (e.g., truck, MPV, bus, trailer). The tire, rim, and cold inflation information can be provided either on the certification label or on a separate label applied in the same area on the trailer. GVWR QUESTION: I was wondering if you could provide a definition of GVW & GVWR. What is the difference, and, if any, the impact the two have on axles. ANSWER: GVW is the “Gross Vehicle Weight”, which is the actual weight of the vehicle. GVWR is the “Gross Vehicle Weight Rating”, and is the maximum allowable weight for the vehicle, which includes the weight of the trailer and the weight of the anticipated cargo. The axles must be able to support the GVWR, less the amount of weight carried by the tow vehicle (the “tongue weight” or the “hitch load”). This means that the GAWR (Gross Axle Weight Rating) may be less than the GVWR. It is generally accepted that this difference may be as high as 15% of the GVWR for bumper pull trailers, and 25% for gooseneck and 5th wheel trailers, although a more conservative approach would have them equal (since you don’t know how the consumer will load the trailer). Exporting QUESTION: What requirements to I have as a trailer manufacturer to export trailers to Europe? ANSWER: (The following answer was provided by Serge Redding, Division Manager for TUV Rheinland of North America, Inc. TUV Rheinland, headquartered in Newtown, Connecticut, is a subsidiary of TÜV Rheinland Group and is a global leader in compliance engineering, testing and certification for domestic and worldwide markets.) Unlike the U.S. self-certification scheme, the EU-system is based on third-party certification. In order to sell vehicles that can be registered for use on public roads, they have to be certified by an independent and accredited technical service as meeting a series of requirements. Currently, there is no way to get European-wide vehicle approval for trailers. They have to be approved on a country-by-country basis. However, manufacturers can obtain sub-system approvals for items ranging from brakes to license plate installation. These sub-system certifications are very useful when applying for the national vehicle approvals, as each country has to accept them! So, if a trailer has an EU brake certification, no Member State can reject a registration of that trailer type because of brakes. For trailers sold in very limited series, it is not necessarily financially attractive for the manufacturer to pursue EU-wide system certifications. A better choice for these cases would be pursuing National “Single-Vehicle” registrations in the country of destination. The requirements are, in general, based on the European standards, but the process is less complicated, involves less paperwork, and is noticeably cheaper. Other EU-Member States may accept “Single-Vehicle” registrations issued by one country, especially if the test reports are issued by a reputable technical service. QUESTION: What are the differences in requirements for trailers shipped to Canada, as opposed to those manufactured solely for use in the U.S.? ANSWER: Transport Canada requires that U.S. Trailer manufacturers register in advance to obtain pre-clearance into Canada. Canadian manufacturers are required to register with NHTSA or to go through an RI process on each individual vehicle. The big difference between the registration processes is that Transport Canada demands specific documentation and proof of testing for Air Brake Trailers. I suggest that you visit the following Web site www.ctea.on.ca and go to the 'Quick links' button and scroll down until you find the section ‘Importing Vehicles into Canada’ and open the Links there. Specifically, Transport Canada also requires detailed drawings of lighting specifications and a layout that meets the regulations under CMVSS/FMVSS 108 or color photos of a typical export trailer unit showing all sides. They also need to see proof of an Air Brake Timing test for a typical trailer configuration that meets FMVSS/CMVSS 121 for Timing. In addition, evidence of a dynamic air brake test of the trailer configuration to meet '121' for Parking OR that the company is a CTEA member and investor in the CTEA Generic Parking Brake Testing Program and therefore able to supply a hard copy of test data from the CTEA database. Transport Canada also requires proof that the U.S. Company is registered as a manufacturer with NHTSA. Dimensions QUESTION: On a trailer do we measure from the top of the tire or the bottom to determine the 102 inch width requirements? ANSWER: To determine the width of the trailer, you must measure to the extreme width of the trailer, which may or may not be the tires, but with certain limited exceptions for non-load carrying devices. If it is the tires, then you measure to the top side of the tire so that tire bulge is not included, i.e. may be ignored. See 23 CFR§ 658.15 and .16. Questions are answered by Dick Klein, 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.