Explaining Conspicuity Tape Requirements for Straight Trucks (Single Unit Trucks)
This article addresses questions regarding the necessity of reflective conspicuity treatment on straight box trucks, also known as box trucks.
Question: Is retroreflective DOT C2 Conspicuity Tape required on straight box trucks? I understand that it is required on large semi-tractor-trailer rigs, but I have not seen where it is required on smaller straight trucks. Also, is DOT C2 tape allowed on smaller trucks?
Answer: To the best of my knowledge, reflective red and white DOT C2 tape or reflectors, known as conspicuity treatment, are not mandatory for single-unit box trucks. FMVSS 108 is a regulation for Tractor Trailer Rigs. Single-unit trucks or box trucks are not covered by this regulation. An effort began within the NHTSA in 2015 to add single-unit trucks (straight trucks) to the regulation via an update to FMVSS 108; however, it appears as though this effort was closed due to the inability of the NHTSA to show sufficient effectiveness to warrant the cost. (See PDF letter at the bottom of this page).
This article is intended to bring clarity to the often-confusing requirements for conspicuity tape on straight trucks (box trucks), particularly in the context of the requirement on semi-tractors and trailers, which are similar vehicles.
FMVSS 108 as it Pertains to Tractor-Trailer Rigs
The Federal Motor Vehicle Safety Standard (FMVSS) 108: Lamps, Reflective Devices, and Associated Equipment outlines the requirements for conspicuity treatments, specifically for manufacturers of new truck-tractors, trailers, and semi-trailers. These requirements apply solely to trailers exceeding 80 inches in overall length with a gross vehicle weight rating greater than 10,000 pounds, manufactured on or after Dec. 1, 1993, and truck-tractors manufactured on or after July 1, 1997.
For location requirements of conspicuity treatment on truck-tractors and trailers, refer to Section 5.7, Conspicuity Systems in FMVSS 108, part of Title 49 (Transportation) Code of Federal Regulations (CFR) Part 571.
FMVSSs are minimum performance standards that all motor vehicles for public highway use must adhere to, issued and maintained by the National Highway Traffic Safety Administration (NHTSA), a DOT entity.
The Federal Motor Carrier Safety Administration (FMCSA), another DOT entity, oversees the development, revision, and enforcement of Federal Motor Carrier Safety Regulations (FMCSRs). These regulations apply to commercial motor vehicle operators in interstate commerce, covering aspects such as commercial driver’s licenses and equipment requirements found in 49 CFR Part 393 – Parts and Accessories Necessary for Safe Operation.
In essence, motor vehicle manufacturers are responsible for complying with NHTSA standards and regulations, while motor carriers (end users) are accountable for meeting FMCSRs.
Similar Voluntary Treatment for Single-Unit Trucks
Installation of a conspicuity treatment on a single-unit truck is permissible as long as it doesn’t interfere with the required lighting in FMVSS 108, Section 5.1.3, which states, “No additional lamp, reflective device, or other motor vehicle equipment shall be installed that impairs the effectiveness of lighting equipment required by this standard.” Also, avoid large amounts of white reflective in the rear of a truck and large amounts of red in the front, as this can confuse oncoming drivers.
If you choose to add conspicuity to your single-unit truck, it would be our recommendation that you follow the conspicuity guidelines for larger semi-trucks. This will give you context as to how much and where to apply the retroreflective tape. We also recommend using only a branded certified DOT C2 from a reputable seller. Consult FMVSS 108, Section 5.7, for location and reflective material requirements. NHTSA emphasizes the importance of a vehicle’s visibility, and compliance with Section 5.7 ensures adherence to Section 5.1.3. As an optional item, not mandated by FMVSS 108.
In closing, to the best of our knowledge, the DOT C2 treatment required on larger tractor-trailer rigs is not mandatory on single-unit trucks; however, adding this treatment to a truck shows due diligence and will be helpful in preventing collisions. And in the case of an accident, it shows due diligence.
Steven Cole (Economics, MBA – University of West Florida , Business & Innovation – Stanford University) 25 years of experience in the reflective safety business. Specializing in vehicle accident and rear end collision reduction through increased visibility.