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Guide to DOT Federal Safety Regulations for Trailer Manufacturers

Federal Requirements

The Motor Carrier Safety Improvement Act of 1999 went into effect on January 1, 2000, after being introduced in the House just 60 days prior. The bill signified a measurable shift in the way the federal government handled and processed its commercial vehicle safety and compliance standards. This date also marked the birth of the Federal Motor Carrier Safety Administration (FMCSA), an organization working under the umbrella of the Department of Transportation. The introduction of the FMCSA helped the agency to better handle the affairs of commercial vehicles, including its licensing and data and analysis, as well as its regulatory compliance and enforcement procedures.

Ever since the change, commercial vehicles have faced an unprecedented level of scrutiny, particularly in terms of safety. This is especially true for the manufacturing processes and sales of commercial trailers, because guidelines stipulated by the FMCSA under the guidance of the Department of Transportation must be followed by all applicable parties, not just their operating entities.

Because these guidelines may vary depending on the state in which the trailer is sold and/or used, the cross-departmental nature can make for confusion. To remedy this, we’ve compiled a guide featuring the most important DOT federal safety regulations as they relate to truck trailer manufacturers. Below, you’ll find an outline of the illustrated key points:

For an in-depth look at the various federal safety regulations and compliance programs for truck trailer manufacturers, read on.

Federal Requirements for Trailer Manufacturers

Federal Requirements

We have already made mention of how the DOT and FMCSA are associated, but there is yet another federal agency that oversees the manufacturing practices of truck trailers – the National Highway Traffic Safety Administration (NHTSA). In its guide, Requirements for Manufacturers of Trailers Produced for Distribution Within the U.S. Market, the agency details the initial rules that trailer manufacturers are made to follow.

In the guide, manufacturers are taken through the various processes put into place to ensure their compliance, all of which must be made available prior to, during, and after the manufacturing of the applicable trailers. The key safety points are as follows:

  • Any manufacturer who violates the safety regulations outlined in the guide will be “subject to a civil penalty not to exceed $6,000 for each violation, or $16,375,000 for any related series of violations.”
  • All foreign manufacturers must be in full compliance with the safety regulations formed by the DOT.
  • Each trailer must include a VIN that follows the format, content and physical requirements.
  • All certification labels must be properly affixed.
  • Manufacturers must provide customers with a one-page purchaser statement.
  • Manufacturers must provide customers with proof of certification (more on this later).

The above information only scratches the surface, as safety compliance also covers the trailer manufacturers’ responsibility in terms of tire selection, weight, visibility, and more. To determine, whether or not you, as a trailer manufacturer, are subject to the regulations, first get to know how the DOT defines a heavy-duty or commercial trailer. A commercial trailer is:

  • A vehicle with a GCWR or GVWR of more than 10,000 lbs. (this denotes the combined weight of the trailer and truck)
  • Vehicles exceeding 26,000 lbs. which require the driver to hold a CDL
  • Vehicles hauling hazardous materials, as defined by the DOT

For more information and forms on the vehicles that constitute certification and/or importation documents, visit the NHTSA website.

How to Obtain a World Manufacturing Identifier (WMI)

As mentioned, it is compulsory for each and every truck trailer manufacturer to obtain a Vehicle Identification Number (VIN) before the sale of the piece of equipment. This is not a process that can be self-reported – each VIN contains a coded description that includes the trailer’s manufacturer name, year of production, place of production, and other specialized characteristics. How to Obtain a World Manufacturing Identifier (WMI) 

To help make the VIN distribution process more streamlined, the NHTSA contracts with a company called SAE International. It is the job of this private firm to provide manufacturers with a selected portion of the VIN, called the World Manufacturing Identifier (WMI). Without the WMI, a trailer’s VIN is considered incomplete.

In order to obtain a WMI, you must first begin an application with SAE International, using its online application form. Manufacturers based outside of the United States who plan on doing business with U.S. fleets must obtain and submit a Non-US WMI Application. Take note: an additional one-time fee of $525 USD must be made payable to SAE International in order to successfully obtain a Non-US WMI.

NHTSA Registration and Data Plates

Now that the WMI has been obtained, the trailer manufacturer is ready to register its trailer’s VIN with the NHTSA. According to the Electronic Code of Federal Regulations Office, the General Requirements (§565.13) are as follows:

  • Every vehicle manufactured in one stage must have a VIN assigned by the manufacturer.
  • Vehicles manufactured in multiple stages must have a VIN assigned by the incomplete vehicle manufacturer.
  • Any entities altering vehicles (specified in 49 CFR 567.7) should use the VIN assigned by the original vehicle manufacturer.
  • VINs consist of 17 characters, including a check digit which appears in position 9 of the VIN. It must be present on the vehicle as well as any transfer documents.
  • VINs must be unique: No two vehicles subject to the federal motor vehicle safety standards, manufactured within a 60-year period beginning with the 1980 model year, will share an identical VIN.
  • Every vehicle’s VIN should appear clearly on a part of the vehicle (other than the glazing) that is not designed to be removed (other than for repair purposes), or on a separate plate or label permanently affixed to a part of the vehicle meeting the same requirements.
  • For passenger cars, multipurpose passenger vehicles, low-speed vehicles, and trucks with a GVWR of 4536 kg or less, the VIN should be located inside the passenger compartment. The VIN must be “readable, without moving any part of the vehicle, through the vehicle glazing under daylight lighting conditions by an observer having 20/20 vision (Snellen) whose eye-point is located outside the vehicle adjacent to the left windshield pillar.” Each character in the VIN must be at least 4 mm in height.
  • Each character in every VIN must be one of the letters in the set: [ABCDEFGHJKLMNPRSTUVWXYZ] or a number in the set: [0123456789]. These must be assigned using the method outlined in §565.15. All spaces in the VIN must be accompanied by one of these characters.
  • Capital, san-serif typeface must be used for the VIN.

Once a VIN that includes a WMI provided by SAE International is affixed to the vehicle, the trailer manufacturer must register the VIN with the NHTSA at least 60 days prior to the first sale of the trailer. There is currently no online portal available for this task. Instead, manufacturers must send the above information, along with any other applicable forms, to:

Administrator, National Highway Traffic Safety Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
Attention: VIN Coordinator

In terms of data plate material, it is recommended that manufacturers select one that is built tough enough to withstand abrasion, UV exposure, and harsh weather elements. Metalphoto® photosensitive anodized aluminum is the top choice for identification and asset tracking purposes as its heavy-duty enough to display the information, even with frequent exposure.

Third-Party Safety Verification Programs

Ostensibly, the aforementioned guidelines might seem complex to new trailer manufacturers, considering manufacturers must abide by all regulations with a number of different agencies before the trailer even hits the road. Because of this, some trailer manufacturers decide to consult third-party firms to ensure that they are in full compliance throughout the building, sales, and maintenance processes.

One such firm is the National Association of Trailer Manufacturers (NATM) Compliance Verification Program. NATM requires all of its member manufacturers undergo the program. In it, the members are provided a compendium entitled, Guidelines for Minimum Recommended Manufacturing Practices (Guidelines), a guide which is meant to provide easy access of the current federal regulations. In addition to this, members are also awarded technical support, as well as a biennial consultation that focuses, specifically, on the compliance of FMCSA safety standards.

According to NATM, each consultation comes with an up-to-date checklist featuring important trailer safety considerations, such as:

  • VIN labels
  • NHTSA registration
  • Record keeping guidelines
  • Safety cable/chain standards
  • Breakaway system standards
  • Lighting safety
  • Conspicuity tape standards
  • Personalized recommendations for easy compliance

Conspicuity Requirements for Trailers

Conspicuity Requirements for Trailers

In the FMCSA’s Conspicuity Requirements for Commercial Vehicles, the agency provides a long list of lighting safety guidelines for trailers manufactured on or after December 1, 1993. This forces all trailer manufacturers to install red and white retroreflective sheeting and/or reflex reflectors to specific areas of the vehicle.

When purchasing this specialized sheeting, the trailer-maker must also ensure that it is manufactured by a firm that is FMVSS-certified (Federal Motor Vehicle Safety Standard-certified). This will be made evident by an “FMVSS No. 108” marked on the product. Any and all conspicuity materials that are in compliance with FMCSA will be labeled as such:

  • DOT-C (Rectangular reflectors)
  • DOT-C2 (50mm wide reflective material)
  • DOT-C3 (75mm wide reflective material)
  • DOT-C4 (100mm wide reflective material)

Trailers manufactured after December 1, 1993 must adhere to a strict range of conspicuity treatments on the sides of the trailer, the lower rear area of the trailer, and the upper rear area of the trailer. All rules concerning specific placement are stipulated in the Conspicuity Requirements for Commercial Vehicles guide. Manufacturers must carefully consult this information and conform to it depending upon the unique dimensions of the trailer.

Additionally, if the trailer exceeds 10,000 lbs., it may need further conspicuity treatments in the form of clearance lights, identification lights, brake lights, marker lights, and even license plate lights depending upon the state in which the trailer is operating. Manufacturers must reference all corresponding conspicuity treatment information as part of its safety compliance process.

Rules for Truck and Trailer Pairings

Rules for Truck and Trailer Pairings

In FMCSA’s Section § 393.201: Frames, trailer manufacturers must pay close attention to §393.43 Breakaway and emergency braking. This section provides important information on the required braking systems for trucks towing trailers equipped with brakes:

(a) Towing vehicle protection system. Every motor vehicle, if used to tow a trailer equipped with brakes, shall be equipped with a means for providing that in the case of a breakaway of the trailer, the service brakes on the towing vehicle will be capable of stopping the towing vehicle. For air braked towing units, the tractor protection valve or similar device shall operate automatically when the air pressure on the towing vehicle is between 138 kPa and 310 kPa (20 psi and 45 psi).

(b) Emergency brake requirements, air brakes. Every truck or truck tractor equipped with air brakes, when used for towing other vehicles equipped with air brakes, shall be equipped with two means of activating the emergency features of the trailer brakes. One of these means shall operate automatically in the event of reduction of the towing vehicle air supply to a fixed pressure which shall not be lower than 20 pounds per square inch nor higher than 45 pounds per square inch. The other means shall be a manually controlled device readily operable by a person seated in the driving seat. Its emergency position or method of operation shall be clearly indicated. In no instance may the manual means be so arranged as to permit its use to prevent operation of the automatic means. The automatic and manual means required by this section may be, but are not required to be, separate.

(c) Emergency brake requirements, vacuum brakes. Every truck tractor and truck when used for towing other vehicles equipped with vacuum brakes, shall have, in addition to the single control required by §393.49 to operate all brakes of the combination, a second manual control device which can be used to operate the brakes on the towed vehicles in emergencies. Such second control shall be independent of brake air, hydraulic, and other pressure, and independent of other controls, unless the braking system be so arranged that failure of the pressure on which the second control depends will cause the towed vehicle brakes to be applied automatically. The second control is not required by this rule to provide modulated or graduated braking.

(d) Breakaway braking requirements for trailers. Every trailer required to be equipped with brakes shall have brakes which apply automatically and immediately upon breakaway from the towing vehicle. With the exception of trailers having three or more axles, all brakes with which the trailer is required to be equipped must be applied upon breakaway from the towing vehicle. The brakes must remain in the applied position for at least 15 minutes.

(e) Emergency valves. Air brake systems installed on towed vehicles shall be so designed, by the use of “no-bleed-back” relay emergency valves or equivalent devices, that the supply reservoir used to provide air for brakes shall be safeguarded against backflow of air to the towing vehicle upon reduction of the towing vehicle air pressure.

(f) Exception. The requirements of paragraphs (b), (c) and (d) of this section shall not be applicable to commercial motor vehicles being transported in driveaway-towaway operations.

Though the above rules might not always be an applicable compliance issue for all truck trailer manufacturers, they illustrate the responsibility of the trailer-maker; all should make inquiries about their customers’ vehicles so that dangerous pairings are not established.

Additional Resources on DOT Regulations for Truck Trailer Manufacturers

For more information on how to stay on the right side of trailer manufacturing and safety compliance laws, visit the following resources:

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