TSEI expresses its support for NTTC’s exemption request in comments

The Transportation Safety Equipment Institute (TSEI) recently filed comments in support of the request made by the National Tank Truck Carriers (NTTC) to allow the use of amber pulsating brake lamps on the back of all tank trailers.

NTTC last year petitioned the Federal Motor Carrier Safety Administration (FMCSA) to allow the installation of a pulsating, brake-activated light. Current regulations require all exterior lamps to be “steady-burning.” FMCSA earlier granted a similar exemption to Groendyke, allowing it to install pulsating amber lights on the rear end of tankers in its fleet, in addition to the steady-burning brake lights.

The request also is similar to exceptions made for other classes of commercial vehicles, TSEI said, such as buses, tow trucks, vehicles transporting oversized loads, and certain state and local emergency and service vehicles.

While voicing its support for NTTC’s exemption request, TSEI also provided FMCSA with a number of recommendations, which it asked the agency to consider in tailoring the terms of the request exemption, or in considering possible amendments to the Federal Motor Carrier Safety Regulations (FMCSR) to accommodate wider use of pulsating lamps on commercial vehicles. Those recommendations include:

1. The lamp should be located and mounted as consistently as possible across all vehicles.
2. The lamp color and initial brightness should be consistent across all vehicles.
3. The lamp color should be amber and be consistent with other uses of flashing amber lamp exemptions/exceptions.
4. The lamp’s pulsating frequency should be consistent for all trailers that have the lamp installed.
5. Consideration should be taken of past research on lamps for attracting operator attention such as that detailed in the section entitled, “Overview of Human Factors Research on Attracting an Operator’s Attention” in the NHTSA report, Enhanced Rear Lighting and Signaling Systems, which outlines methods of coding of lamps (color, position, size, flash, apparent motion, intensity, alphanumeric, pictorial and shape).
6. FMCSA should work with or support standards organizations, including SAE and the Technology & Maintenance Council (TMC), in the development of a Recommended Practice (RP) for the design, installation, and maintenance of Enhanced Rear Signaling (ERS) lamps.
7. FMCSA should coordinate and align the NTTC exemption request with the exemption granted to Groendyke to facilitate uniformity among tank trailer lighting, and a consistent, joint exemption renewal process for all motor carriers operating tank trailers equipped with ERS if NTTC’s exemption is granted.
8. Consideration should be taken of Section 6.23 of UN Regulation 48.4 This regulation provides for flashing emergency stop signals during high levels of retardation.
9. FMCSA should work with NTTC to monitor the safety improvement during the five-year exemption period to more fully evaluate effectiveness.
10. FMCSA should work during the initial exemption period to modify the FMCSRs to allow such lamps for tank trailers at a minimum, but also consider straight trucks hauling hazardous cargo and all other trucks and trailers.
11. FMCSA should work with NHTSA to permit installation of such lamps on new trucks and trailers, which will reduce cost and increase usage.
12. FMCSA should consider other actions in progress as detailed in the Fall 2019 Unified Agenda of regulatory and deregulatory actions.