The Dangers of Counterfeit Retro Reflective DOT C2 Truck Tape

The Hidden Hazard: The Dangers of Counterfeit DOT C2 Reflective Tape

Introduction:

Retro Reflective DOT tape is a critical component of road safety, enhancing visibility and reducing the risk of accidents, especially during low-light conditions. In the case of large semi trucks, the Department of Transportation (DOT) mandates specific standards for reflective tape to ensure its effectiveness in alerting motorists and preventing collisions. Unfortunately, the rise of poorly constructed counterfeit DOT tapes poses a significant threat to road safety, as these imitation products often fail to meet the required standards. In this article, we will explore the dangers associated with counterfeit DOT tape and why it’s essential to prioritize authenticity.

Reduced Visibility:

Counterfeit reflective tape typically cuts corners on the high-quality materials and engineering necessary to provide optimal visibility in low light conditions. Authentic DOT reflective tape is designed to reflect light effectively, making it visible from a considerable distance. In contrast, counterfeit DOT products may have subpar reflective capabilities, compromising a driver’s ability to identify and respond to the presence of a large truck in low-light conditions.

Shortened Lifespan:

Genuine DOT reflective tape is engineered to endure challenging weather conditions such as rain, snow, and UV exposure. In contrast, counterfeit alternatives frequently utilize subpar materials, resulting in rapid deterioration and a shortened lifespan. As the tape loses its reflective properties and adhesive strength, its ability to effectively fulfill its primary function, making large trucks conspicuous, diminishes. This decline in effectiveness increases the risk of potential collisions on the road.

Adhesive Failure:

Effective adhesion is essential for the optimal performance of DOT tapes. Films that start to lift from a surface experience accelerated deterioration compared to tape securely sealed to a surface. Counterfeit products may use substandard adhesives that fail to adhere securely to the surface, leading to peeling or complete failure. This adhesive failure compromises the tape’s functionality and poses a risk to other vehicles.

Non-compliance with Regulatory Standards:

Authentic DOT reflective tape is manufactured in accordance with strict regulatory standards to ensure consistent quality and performance. The Federal Motor Carriers Safety Administration (FMCSA) has strict requirements that these tapes must meet in order to bear the DOT C2 logo. Counterfeit products often do not meet these standards, putting users at risk of legal consequences and compromising road safety. Not only do sub par products put other drivers at risk, they also place tremendous liability on the truck owner in the event of an accident. The small cost savings is definitely not worth the risk.

Inferior Retroreflective Technology:

Authentic DOT reflective tape employs advanced retroreflective technology, ensuring optimal light reflection back to its source, such as a vehicle’s headlights. Micro-prismatic films are able to alert drivers to a trucks presence from thousands of feet away in some cases. Counterfeit products may use outdated technology or substandard retroreflective materials. Consider, for example, the various counterfeit tapes that employ Type 3 High Intensity films as their base. They feature red printed block stripes, accompanied by the DOT-C2 logo, so the tape looks real. The issue stems from the fact that Type 3 tapes deviate from FMCSA specifications, offering visibility from only a fraction of the distance that prismatic DOT tapes can achieve. This has the potential to lead to precarious situations where motorists might struggle to promptly recognize a large vehicle or hazard, making it challenging to maneuver to safety or come to a full stop in time.

Conclusion:

The dangers associated with counterfeit DOT C2 tape are far-reaching, encompassing reduced visibility, shortened lifespan, adhesive failure, non-compliance with regulatory standards, and inferior retroreflective technology. Prioritizing the use of authentic, regulation-compliant reflective tape is crucial to maintaining road safety and preventing accidents. Tapes such as Oralite, 3m Diamond Grade, Avery, Nikkalite, and Grote are generally recognized as good quality compliant brand name DOT tapes. It is advisable to thoroughly research non-branded tapes available on marketplaces to ensure they are not counterfeit. Buying counterfeit DOT reflective tape might seem cost-effective, but if it falls short of standards, it cannot ensure the protection of drivers. This situation can potentially place a truck driver or their company in a position of significant liability.

Reflective DOT C2 Tape Application Errors That Can Lead to Truck Accidents

Mistakes in the Application of Retro-Reflective DOT C2 Tapes That Can Lead to Avoidable Accidents

In an effort to mitigate accidents involving large commercial trucks and other vehicles, federal law mandated the application of DOT C2 red and white (silver) reflective tape to trucks in 1992. The purpose was to avoid accidents, injuries, and fatalities caused by collisions between big trucks and smaller vehicles. While the red and white tape is visible during the day, its primary function is to enhance safety and visibility at night by reflecting back the headlights of oncoming cars, providing smaller vehicles more reaction time and helping avoid potential accidents.

Tractor trailers pose specific dangers to smaller cars due to their large and relatively immovable nature, resulting in severe impacts. Additionally, the height of these trucks increases the risk of smaller vehicles going under them, making it crucial for drivers to see and stop in time. Because of this, it is imperative that large semi trucks and trailers be marked properly and maintained. Trucks that are below par in visibility pose a constant risk to other drivers and substantial liability to the trucks owners.

The chart below, sourced from the MUTCD, illustrates the importance of visibility in reducing accidents by demonstrating the relationship between sight distance and stopping distance. This chart is intended to show how important it is that retroreflective tapes on trucks be in good condition and placed in all the required locations. Neglect in this area places an oncoming driver closer to the truck when they become aware of its presence.

distance-stop-vehicle — Distance Needed to Stop a Vehicle

Effectiveness of Properly Applied and Maintained DOT C2 Tape

Before discussing mistakes in applying and maintaining DOT C2 tape, we must recognize its effectiveness when properly applied and still in a new condition. An NHTSA study in 2001, eight years after the law’s implementation, found that DOT tape significantly reduced side and rear impacts into trailers, particularly in dark conditions, by up to 29%. Moreover, it proved especially effective in reducing injury crashes in low-light conditions, resulting in a 44% reduction in fatalities or injuries to drivers.

Conspicuity and Purpose of Reflective Tape

To understand these issues, it’s vital to understand that trucks are marked with bright, alternating-colored reflective tape for “conspicuity purposes,” which is defined as the property of being clearly discernible. Conspicuity goes beyond simply being visible, ensuring that an object stands out from its surroundings. Reflective tape, especially in contrasting colors, enhances conspicuity at night when it reflects light back to its source.

This article aims to highlight circumstances hindering DOT C2 reflective truck tape from fulfilling its intended purpose. Mistakes in application and maintenance of DOT tape made by trucking companies or drivers can lead to avoidable accidents, injuries, or fatalities. These errors range from tape placement to the tape’s age, condition, or type.

1. Old, Dirty, or Delaminated Tape

Tape that is delaminated or aged reflects less light than new tape. As tape ages, its reflectivity diminishes, even more so when dirt and grime accumulate on its surface. Delamination, especially in air-backed prismatic tapes, further reduces performance, allowing water, dirt, and grime to compromise the tape’s reflective properties.

2. Tape Placed Too High on a Truck

Since automobile headlights are designed to shine low to avoid blinding other drivers, DOT tape must be placed as low as possible. Proper placement ensures maximum reflectivity and visibility. Tape applied too high, especially on the side of a tanker, might go unnoticed by approaching drivers, potentially leading to collisions. The DOT requirement is from 15 – 60 inches above the road. Note that the truck in the picture below is not in violation.

3. Tape Placed at an Angle Versus a Proper Vertical Application

DOT C2 tape reflects best when perpendicular to a light source. Placing the tape at an angle reduces its efficiency, resulting in lower reflectivity percentages. For instance, a tape at a 30-degree angle may lose up to 40% reflectivity for the white portion, affecting its visibility and effectiveness in preventing accidents. This means that with a lower return of light, oncoming vehicles need to be closer to the truck to see the reflective tape.

4. Counterfeit DOT Tape

The market offers cheaper DOT tapes made in other countries, but many of these are counterfeit and not compliant with NHTSA/FMCSA requirements. Non-compliant tape may not meet photometric requirements, compromising its ability to reflect enough light for proper conspicuity. This can lead to late detection by approaching drivers, increasing the risk of accidents.

5. Skipped Area of a Truck

Skipping certain areas of a truck during tape application, believing enough tape has been applied, leaves those areas vulnerable to accidents. All areas required by law should be marked to ensure comprehensive visibility. Failure to do so creates unnecessary hazards, especially in critical areas like the under-ride bar. Remember, at night, the reflective tape is often all an approaching driver sees.

Going Above and Beyond Minimum Requirements

While many trucking companies adhere to minimum requirements for reflective safety, going beyond these can enhance visibility, improve safety, and show due diligence in the event there is an accident. Options include using wider certified tapes, placing tape in lower areas or under the truck box, incorporating reflective graphics, or outlining the truck silhouette with reflective tape.

In conclusion, addressing these oversights in the application of retro-reflective DOT C2 tapes is crucial for maximizing their effectiveness in preventing accidents and ensuring the safety of all drivers on the road. Understanding the impact of tape placement, condition, and compliance with regulations is key to maintaining optimal conspicuity and reducing the risk of collisions.

Definitions – Glossary of Retro Reflective Terms

Glossary (Definitions) of Terms Related to Retro-Reflectivity and Photo-Metrics

In order to assist our customers in understanding all aspects of visibility, photo-metrics, and retro-reflectivity, we have put together a glossary of relevant terms. Words that you will see in specification sheets, regulations, and accident analysis reports. This list will hopefully help you with clarity as you read through these documents.

Adhesive (for retro reflective sheeting) – A sticky substance that is used to join two things together. This is normally permanent, but can also be temporary (removable). For retro reflective tape there are 5 classes of adhesive backings. Each is for a specific purpose. Class 1 is the most common and is the backing found on most reflective tapes.

ASTM D4956 Type 1 through 11 – This specification includes flexible, non-exposed glass-bead lens and microprismatic, retroreflective sheeting for traffic control signs, delineators, road barrels, and devices. ASTM 4956 does not address inks, overlays, or other printing methods that may be applied to retroreflective sheeting material to create traffic signs or other devices.

ASTM E810 – A standardized method for measuring retro reflectivity. Measurements made by this test method are related to visual observations of retroreflective sheeting as seen by the human eye when illuminated by tungsten-filament light sources such as a motor vehicle headlamp.

Brightness – Attribute of a visual perception according to which an area appears to emit more or less light. The quality or state of giving out or reflecting light. The opposite of darkness. One object being substantially brighter than another, creates contrast and conspicuity.

Candelas / Lux / Square Meter – A unit of luminous intensity expressed as one candela in one second of light emittance per square meter of area. This is the unit of measurement used to measure the intensity of brightness of retroreflective sheeting and other lighting. This measurement is also used to set minimum standards for reflectivity.

Chromaticity – Chromaticity is an objective specification of the quality of a color regardless of its luminance. Chromaticity consists of two independent parameters, often specified as hue (h) and colorfulness. It is the quantification of color.

Chromaticity Coordinates – A numeric description of color. Or color quantified with numeric coordinates. The chromaticity coordinates can be expressed on a 2D chromaticity diagram. These coordinates assure that a retro reflective tape is the proper color.

Chromaticity Diagram – This diagram shows all the hues perceivable by the standard observer for various (x,y) pairs and also indicates the spectral wavelengths of the dominant single frequency colors. It is an image that displays all colors and their corresponding xy coordinate.

Coefficient of Retro-Reflection – The ratio of the coefficient of luminous intensity of a plane retroreflecting surface to its area expressed in candelas per square meter.

Color – The aspect of any object that may be described in terms of hue, lightness, and saturation. Expressed by chromaticity coordinates according to the CIE (Commission Internationale de l’Eclairage 1931 ) standard colorimetric system.

Competitive Lighting – Lighting that overshadows or drowns out other lights or retro reflective surfaces to where they become less conspicuous or invisible. An example would be a trucks headlights shining at 15,000 candelas, near retro reflective tape shining at 500 candelas.

Cone of Retro Reflectivity – light returning from a sheet of reflective tape expands as it moves towards the light source. As it expands, it forms a cone of reflectivity shaped like a megaphone. As the light expands, it becomes dimmer.

Conspicuity – the characteristics of an object that determine the likelihood that it will come to the attention of an observer. This is achieved through color, contrast, patterns, and brightness.

Department of Transportation (US-DOT) – The federal agency in charge of all transportation related affairs in the US. This agency is over the FMCSA (Federal Motor Carrier Safety Association), NHTSA (National Highway Traffic Safety Association), FHWA (Federal Highway Association), and many other transportation agencies. (FAA, FTA, FRA, MARAD, PHMSA, etc.)

Diffused or Scattered Reflectivity – light is scattered or diffused in multiple directions. Almost all objects are seen in this way. If you look at your car in daylight, you are seeing it because of diffused or specular reflectivity.

Dimensional Stability – in terms of retro reflective tape or any other adhesive film, this is the ability of a film to hold its original size. The more dimensionally stable a film is, the longer it lasts on a surface, given good adhesion.

Entrance angle – angle between the illumination axis and the retroreflector axis. This is the angle that light enters a retro reflective film. At a perpendicular 0 degree angle, reflectivity is at its highest. Specification sheets measure maximum reflectivity at 4 degrees entrance angle. At a 15 degree entrance angle, retro reflectivity is reduced by approximately 20%. At 30 degrees, reflectivity drops by approximately 50%. At 45 degrees, reflectivity drops by approximately 85%. And at a 60 degree entrance angle, retro reflectivity is reduced by 86 – 99% depending on the tape type and brand.

Federal Motor Carrier Safety Administration (FMCAS) – established within the Department of Transportation on January 1, 2000, pursuant to the Motor Carrier Safety Improvement Act of 1999 [Public Law No. 106-159, 113 Stat. 1748 (December 9, 1999)]. Formerly a part of the Federal Highway Administration, the Federal Motor Carrier Safety Administration’s primary mission is to prevent commercial motor vehicle-related fatalities and injuries. (this agency is under the US DOT)

Flexibility – the ability of an object or film to stretch, conform, or bend. The quality of bending easily without breaking.

Glass Bead Reflective Sheeting (tape) – retro reflective films that use perfectly round glass sphere for reflectivity. Light enters the bead, is bent, bounced and returned to the light source. There are two kinds of beads, standard and metallized. Glass bead reflective tape is not as bright as prismatic films.

Impact Resistance – the ability of a material to resist permanent deformation caused by high force or shock applied to it over an extremely short period of time.

Light Dispersion – the width of the returning beam of light from a standard or reflective surface. Certain tapes reflect in a tight beam and can be seen at great distances. Others reflect in a wider beam and can be seen closer in but at wider angles.

Luminance Factor – the ratio of the luminance of the body considered to the luminance of a perfect diffuser under identical conditions of illumination and observation.

Micro-Prismatic Reflective Sheeting (tape) – retro reflective tape that achieves reflectivity via man made micro prisms. A prism array is embossed on the back of a film and either metalized like a mirror, or backed with a white film. Prismatic retro reflective tape is brighter than glass bead films.

National Highway Traffic Safety Administration (NHTSA) – responsible for reducing deaths, injuries and economic losses resulting from motor vehicle crashes. NHTSA sets and enforces safety performance standards for motor vehicles and equipment, and through grants to state and local governments enables them to conduct effective local highway safety programs. NHTSA investigates safety defects in motor vehicles, sets and enforces fuel economy standards, helps states and local communities reduce the threat of drunk drivers, promotes the use of safety belts, child safety seats and air bags, investigates odometer fraud, establishes and enforces vehicle anti-theft regulations and provides consumer information on motor vehicle safety topics. (this agency is under the US DOT)

Observation angle – angle between the axes of the incident beam and the observed (reflected ) beam. In retroreflection the angle between the illumination axis and the observation axis.

Photometer – an instrument for measuring light. Often used in photography. These devices do not necessarily measure retro reflectivity, just basic light returning from a surface in daylight.

Photometrics – The study of light. The measurement of the intensity, brightness, chromaticity, or other properties of light.

Retro Reflectivity – the ability of a surface to return light back to the light source. This differs from scattered or diffused reflectivity which is when a surface returns light in all directions, and specular reflectivity which is like a mirror. (AKA – Retro Reflection – reflection in which the reflected rays are preferentially returned in directions close to the opposite of the direction of the incident rays, this property being maintained over wide variations of the direction of the incident rays.)

Refraction – change in the direction of the propagation of radiation determined by change in the velocity of the propagation in passing from one medium to another.

Retro-Reflective Element – A single optical unit which by refraction or reflection, or both, produces the phenomenon of retroreflection.

Retro-Reflective Material – A material that has a thin continuous layer of small retroreflective elements on or very near its exposed surface ( for example, retroreflective sheeting, beaded paint, highway sign surfaces or pavement striping).

Retro-Reflective sheeting – A retro-reflective material preassembled as a thin film ready for use.

Retroreflectometer – In the most simple of terms a retroreflectometer is an instrument that assesses the nighttime visibility of a retro reflective surface. Reflective surfaces such as sign faces, DOT C2 tape, and pavement markings, can be tested. The readings from these devices are in candelas, which is a measure of light. The devices are first calibrated using a known reading from a sample swatch of retro reflective material, and then used to test the subject film.

Retro-Reflector – A surface or device that reflects light back along the incident path, irrespective of the angle of incidence. This simply means that it returns light back to the source. These devices can normally accomplish this at angles of up to 60 degrees, with reflectivity declining as the angle increases.

Rotation Angles – An angle of rotation is the measure of the amount that a figure is rotated about a fixed point called a point of rotation. Reflective tape brightness is measured at different rotation angles.

Shrinkage – the reduction in size of a film compared to its original size. In terms of tape, it is how much the film pulls back over time. This process can affect the longevity of a film. A lack of shrinkage is called dimensional stability.

Sight Distance – Sight Distance is a length of road surface which a particular driver can see with an acceptable level of clarity.

Solvent Resistance – the ability of a surface to resist corrosion or degradation from solvents such as alcohol, mineral spirits, etc.. The more solvent resistant a surface is, the longer it lasts in a harsh environment. Generally speaking.

Specular Gloss – the measure of light reflecting off of the surface of an object or film. A polished surface has more gloss than a matte surface.

Specular Reflectivity – Mirror like reflectivity. Light return depends on the angle of the surface.

Source – An object that produces light or other radiant flux, such as a vehicles headlights.

Stopping Sight Distance – Stopping Sight Distance (SSD) is the viewable distance required for a driver to see so that he or she can make a complete stop in the event of an unforeseen hazard.

Viewing angle – The angle between the retroreflector axis and the observation axis. The angle in which we view an object.

Visibility – The properties and behavior of light waves and objects interacting in the visual environment to produce light signals capable of evoking visual sensation.

How We Review Retro Reflectivity as it Relates to a Truck or Vehicle Accident

As it pertains to retro reflective tape, there are several factors that we consider when reviewing an accident between a large semi-truck and another vehicle. Our goal in assessing these elements is to estimate what an approaching vehicle most likely saw as they neared the truck in question. This can be compared and contrasted with a properly marked truck.

These elements are as follows –

Properly Applied Certified Retro Reflective DOT C2 Tape – It important that certified reflective DOT tape with the DOT-C2 logo be affixed to a semi truck and the trailer it tows, in the right amounts, and in the proper places. Failure to do this violates Federal Regulation and places the lives of other drivers in danger. In dark conditions, the retro reflective tape on a truck may be the only thing that alerts a driver to a trucks presence. With this being said, the Federal Motor Carriers Safety Administration (FMCSA) and the National Highway Traffic Safety Administration (NHTSA) mandate that trucks over 80 inches wide and over 10,000 pounds be marked with DOT-C2 C3 or C4 retro reflective tape. (the C2 C3 C4 are the widths of the tape) Specific requirements are in our FMCSA article here.

To be certified, DOT tapes must meet certain requirements. These are color (chromaticity), surface appearance, width, pattern spacing, DOT-C2 logo, and retro reflective performance. Generally speaking, the regulation requires DOT tape to meet ASTM D4956 Type 5 specifications for all aspects of the film except for photo metrics. For photo-metrics, which in this case is brightness, the FMCSA provides a chart, however, it is roughly the equivalent of ASTM D4956 Type 3 requirements.

The amount of tape to be applied and where it must be applied are also specifically outlined in the Federal regulation. These areas are the sides of the trailer, the back lower areas, the back upper areas, and the truck itself (cab). All areas specified must be marked with DOT approved retro reflective tape that is a minimum of 2 inches wide, up to 4 inches. Damaged tape that no longer meets DOT specs may cause a truck to fail inspection.

retro reflective dot c2 conspicuity chart diagram — DOT Retro Reflective Tape Placement Requirements

Condition of the DOT C2 Retro Reflective Tape – Damaged or missing retro reflective DOT C2 tape can affect the ability of other drivers to see a large truck at night. Tape age, weathering, dirt, and grime also contribute to a less effective reflective tape performance. Missing tape is often caught by DOT inspectors, but weathered, aged, or dirty tape are seldom used as grounds for an inspection failure since inspectors do not normally run retro reflectivity tests on the tape. But just because a truck did not fail an inspection, does not mean that the retro reflective tape on that truck is performing to minimum specifications.

In reference to age, DOT tape manufacturers warranty their tapes meet minimum FMCSA and NHTSA standards for 5 , 7 , or 10 years depending on the brand and model. And this warranty applies only if the tape is properly applied and cared for. After the warranty period expires, manufacturers no longer guarantee that the tape will meet minimum reflectivity requirements, which is the most important characteristic of the tape when it comes to sight distance. This means that it is possible that older tapes that are beyond their warranty no longer meet minimum reflectivity standards, and as such, no longer provide the necessary protection from collisions.

The issue with degraded tape is that as reflectivity decreases, the distance at which the tape can be seen decreases as well. So at some point, by the time a driver sees the tape, it is too late to stop, and a collision occurs.

Old damaged dot c2 retro reflective conspicuity tape — Example of Old DOT C2 tape with Diminished Reflectivity

Ambient Lighting at the Time of the Accident – Since light creates what our eyes see, it is very important to know how much light was present at the scene of an accident, at the exact time that it occurred. Was it day or night? Was the moon full? Were there street lights nearby? Or was it completely dark? This analysis is important because the less ambient light there is lighting up a truck, the more approaching drivers must depend on other conspicuity that is affixed to the truck itself. At night, with very little or no ambient lighting, approaching drivers depend solely on the large truck and trailers lights, and the retro reflective conspicuity tape attached to the truck itself. At night, without these two elements, or if they are substantially diminished, trucks can easily be invisible to an approaching driver.

Weather Conditions at the Time of the Accident – Rain, Snow, Fog, or Smoke in the area of an accident can affect visibility. Any one of these elements can greatly affect what an approaching driver sees as he nears a large semi truck. Darkness, and the addition of one or more of these elements can make perceiving objects in the distance difficult for a driver. In situations like this, effective truck lights, and bright retro reflective tape in very good condition would be necessary to cut through these elements and alert an approaching driver of the presence of a semi truck. In inclement conditions, even a moderately degraded film may not be enough to provide conspicuity, and as such, it is entirely possible that a large truck may appear invisible to an approaching driver.

Angle of the Retro Reflective Tape in Relation to the Oncoming Driver (Entrance Angle of Light) – Retro Reflective Tapes perform at their maximum when they are perpendicular to a cars headlights. As that angle increases, and light from a cars headlights strike the tape at more and more of an angle, reflectivity decreases. At some point above the 45 degree mark, the tape no longer returns sufficient light to be seen from a distance. This angle can be created from a truck sitting at an angle across a roadway, or from the tape being applied at an angle on the truck. More often the issue is the overall angle of the truck. So if a truck is parked across a roadway at a 60 degree angle, an approaching vehicle may not see the retro reflective tape at all, even when close in. So if at night, a truck driver places his trailer at a sharp angle to approaching traffic, the chances of a collision are high since that sharp of an entrance angle renders reflective tape almost invisible.

entrance angle retro reflectivity example — The Highest Level of Retro Reflectivity is at 0 Degree Entrance Angle.

Height of the Installed Retro Reflective Tape in Comparison to the Approaching Vehicles Headlights – The height DOT C2 retro reflective tape is applied is important. As stated in Federal Regulation, DOT C2 tape applied to the side of a truck should fall between 15 and 60 inches from the road surface. The main issue is height. Tape placed too high on a truck can result in car headlights (low beams) hitting below the tape. This is especially true with newer cars with a tight beam pattern. If a cars headlights hit below the conspicuity tape, very little light is returned to the driver, rendering the truck difficult for the driver to see. Generally, the lower that a tape can be installed on the sides of a truck, the better for visibility.

Competitive Lighting at the Accident Scene – At night, light coming from headlights, running lights, street lights, and other sources, compete with retro reflective tape for the attention of drivers. For example, if a section of Retro Reflective DOT tape, that reflects at 700 candelas, is near headlights that emit 15,000 to 20,000 candelas, it is easily drowned out. And if attention is drawn to the headlights of a truck, and its trailer is in the path of the oncoming vehicle, an accident can easily occur.

Observation Angle of Oncoming Driver To Returning Light – The distance that a drivers eyes are from their own headlights constitutes what is known as the observation angle. Light from headlights is directed at retro reflective tape and is bounced back to the source of the light which is the headlights. In a standard vehicle, the eyes of the driver are only slightly above the returning light. In a truck however, the eyes of the driver are higher. The typical observation angle for the driver of a car is .20 degrees, and the observation angle for a truck driver is .50 degrees. This difference in observation angles reduces the return of light to a drivers eyes by a surprising 77%.

Distance Away and Speed of Approaching Driver – If an accident occurred due to a large truck pulling into or across traffic, it is important to know how many feet away the approaching vehicle was from the impact point and how fast the driver was traveling at that point in time. This information, along with an analysis of the retro reflective tape on the truck allows an assessment to be made as to how much time the driver had to identify the truck and take evasive action, and how many feet they had to do so. Combining this data with information about the condition of the retro reflective tape affixed to the truck allows us to make assumptions about what the driver saw, when they saw it, and how much time they had to react.

DOT C2 C3 C4 Retro Reflective Conspicuity Tape – Standards to be Certified

What standards must a retro reflective tape must meet to be certified?

The standards and specifications for DOT tape to be certified are required by Federal Regulation § 393.11, through its cross reference to FMVSS No. 108. I have included some definitions below which include agencies involved in the regulation of over the road trucks. There are quite a few and what each does can be a bit confusing. Also add to this that each state has its own Department of Transportation with rules and regulation.

The information and regulations below cover the color and pattern of the films that can be used as DOT tape, as well as the required photometrics. Also covered in the text below is the required placement of the DOT tape on the truck and trailer. For placement, this article is more clear and concise.

Definitions –

FMVSS – Federal Motor Vehicle Safety Standards

NHTSA – National Highway Traffic Safety Administration

FMCSA – Federal Motor Carrier Safety Administration

DOT – US Department of Transportation

Retro Reflectivity – the ability of an object to reflect light back to its source.

Conspicuity – something being highly visible or conspicuous. The process of making something more visible.

Photometry (photometrics) – science that deals with the measurement and intensity of light.

Certification – the process of assuring something meets certain standards.

Retro-reflector – a device used to indicate the presence of a vehicle by the reflection of light emanating from a light source not connected to the vehicle (similar to retro reflective sheeting)

§ 393.11 Lamps and reflective devices.

(1) Lamps and reflex reflectors. Table 1 specifies the requirements for lamps, reflective devices and associated equipment by the type of commercial motor vehicle. The diagrams in this section illustrate the position of the lamps, reflective devices and associated equipment specified in Table 1. All commercial motor vehicles manufactured on or after December 25, 1968, must, at a minimum, meet the applicable requirements of 49 CFR 571.108 (FMVSS No. 108) in effect at the time of manufacture of the vehicle. Commercial motor vehicles manufactured before December 25, 1968, must, at a minimum, meet the requirements of subpart B of part 393 in effect at the time of manufacture.

(2) Exceptions: Pole trailers and trailer converter dollies must meet the part 393 requirements for lamps, reflective devices and electrical equipment in effect at the time of manufacture. Trailers which are equipped with conspicuity material which meets the requirements of § 393.11(b) are not required to be equipped with the reflex reflectors listed in Table 1 if—

(i) The conspicuity material is placed at the locations where reflex reflectors are required by Table 1; and

(ii) The conspicuity material when installed on the motor vehicle meets the visibility requirements for the reflex reflectors.

(b) Conspicuity Systems. Each trailer of 2,032 mm (80 inches) or more overall width, and with a GVWR over 4,536 kg (10,000 pounds), manufactured on or after December 1, 1993, except pole trailers and trailers designed exclusively for living or office use, shall be equipped with either retroreflective sheeting that meets the requirements of FMVSS No. 108 (S5.7.1), reflex reflectors that meet the requirements FMVSS No. 108 (S5.7.2), or a combination of retroreflective sheeting and reflex reflectors that meet the requirements of FMVSS No. 108 (S5.7.3). The conspicuity system shall be installed and located as specified in FMVSS No. 108 [S5.7.1.4 (for retroreflective sheeting), S5.7.2.2 (for reflex reflectors), S5.7.3 (for a combination of sheeting and reflectors)] and have certification and markings as required by S5.7.1.5 (for retroreflective tape) and S5.7.2.3 (for reflex reflectors).

Federal Motor Vehicle Safety Standards (FMVSS) – Title 49 / Sub Title B / Chapter 5 / Part 571 / Sub Part B / 571.108 – Conspicuity Systems

(§ 571.108 Standard No. 108; Lamps, reflective devices, and associated equipment.)

S8.2 Conspicuity systems. The requirement for conspicuity systems may be met with retroreflective sheeting, conspicuity reflex reflectors, or a combination of retroreflective sheeting and conspicuity reflex reflectors.

S8.2.1 Retroreflective sheeting.

S8.2.1.1 Retroreflective sheeting must consist of a smooth, flat, transparent exterior film with retroreflective elements embedded or suspended beneath the film so as to form a non-exposed retroreflective optical system.

S8.2.1.2 Retroreflective sheeting material. Retroreflective sheeting must meet the requirements, except photometry, of ASTM D 4956–90 (incorporated by reference, see § 571.5) for Type V Sheeting. Sheeting of Grade DOT–C2 of no less than 50 mm wide, Grade DOT–C3 of no less than 75 mm wide, or Grade DOT–C4 of no less than 100 mm wide may be used.

S8.2.1.3 Certification marking. The letters DOT–C2, DOT–C3, or DOT–C4, as appropriate, constituting a certification that the retroreflective sheeting conforms to the requirements of this standard, must appear at least once on the exposed surface of each white or red segment of retroreflective sheeting, and at least once every 300 mm on retroreflective sheeting that is white only. The characters must be not less than 3 mm high, and must be permanently stamped, etched, molded, or printed in indelible ink.

S8.2.1.4 Application pattern.

S8.2.1.4.1 Alternating red and white materials.

S8.2.1.4.1.1 As shown in Figures 12–1 and 12–2, where alternating material is installed, except for a segment that is trimmed to clear obstructions, or lengthened to provide red sheeting near red lamps, alternating material must be installed with each white and red segment having a length of 300 ±150 mm.

S8.2.1.4.1.2 Neither white nor red sheeting must represent more than two thirds the aggregate of any continuous strip marking the width of a trailer, or any continuous or broken strip marking its length.

S8.2.1.5 Application location. Conspicuity systems need not be installed, as illustrated in Figure 12–2, on discontinuous surfaces such as outside ribs, stake post pickets on platform trailers, and external protruding beams, or to items of equipment such as door hinges and lamp bodies on trailers and body joints, stiffening beads, drip rails, and rolled surfaces on truck tractors.

S8.2.1.6 Application spacing. As illustrated in Figure 12–2, the edge of any white sheeting must not be located closer than 75 mm to the edge of the luminous lens area of any red or amber lamp that is required by this standard. The edge of any red sheeting must not be located closer than 75 mm to the edge of the luminous lens area of any amber lamp that is required by this standard.

S8.2.1.7 Photometry. Each retroreflective sheeting must be designed to conform to the photometry requirements of Table XVI–c when tested according to the procedure of S14.2.3 for the color and grade as specified by this section.

S8.2.2 Conspicuity reflex reflectors.

S8.2.2.1 Certification marking. The exposed surface of each conspicuity reflex reflector must be marked with the letters DOT–C which constitutes a certification that the reflector conforms to the conspicuity reflex reflector requirements of this standard. The certification must be not less than 3 mm high, and must be permanently stamped, etched, molded, or printed in indelible ink.

S8.2.2.2 Application pattern.

S8.2.2.2.1 Alternating red and white materials. Conspicuity reflex reflectors must be installed in a repetitive pattern of two or three white reflectors alternating with two or three red reflectors, with the center of each reflector not more than 100 mm from the center of each adjacent reflector.

S8.2.2.2.2 White material. White conspicuity reflex reflectors must be installed with the center of each reflector not more than 100 mm from the center of each adjacent reflector.

S8.2.2.3 Photometry. – see also chart at bottom of this page for photometrics

dot c2 c3 c3 fmvss photometry requirements

S8.2.2.3.1 Each red conspicuity reflex reflector must be designed to conform to the photometry requirements of Table XVI–a for a red reflex reflector and Table XVI–b for a red conspicuity reflex reflector when tested according to the procedure of S14.2.3 as specified by this section.

S8.2.2.3.2 Each white conspicuity reflex reflector installed in only a horizontal orientation must be designed to conform to the photometry requirements of Table XVI–a for a white reflex reflector and Table XVI–b for a white horizontal conspicuity reflex reflector when tested according to the procedure of S14.2.3 as specified by this section.

S8.2.2.3.3 Each white conspicuity reflex reflector installed in a vertical orientation must be designed to conform to the photometry requirements of Table XVI–a for a white reflex reflector, and Table XVI–b for a white horizontal conspicuity reflex reflector and a white vertical conspicuity reflex reflector when tested according to the procedure of S14.2.3 as specified by this section.

S8.2.3 Conspicuity system installation on trailers.

S8.2.3.1 Trailer rear.

S8.2.3.1.1 Element 1—alternating red and white materials. As shown in Figure 11, a strip of sheeting or conspicuity reflex reflectors, as horizontal as practicable, must be applied across the full width of the trailer, as close to the extreme edges as practicable, and as close as practicable to not less than 375 mm and not more than 1525 mm above the road surface at the strip centerline with the trailer at curb weight.

S8.2.3.1.2 Element 2—white. (not required for container chassis or for platform trailers without bulkheads).

S8.2.3.1.2.1 As shown in Figure 11, two pairs of strips of sheeting or conspicuity reflex reflectors, each pair consisting of strips 300 mm long of Grade DOT–C2, DOT–C3, or DOT–C4, must be applied horizontally and vertically to the right and left upper contours of the body, as viewed from the rear, as close to the top of the trailer and as far apart as practicable.

S8.2.3.1.2.2 If the perimeter of the body, as viewed from the rear, is other than rectangular, the strips may be applied along the perimeter, as close as practicable to the uppermost and outermost areas of the rear of the body on the left and right sides.

S8.2.3.1.3 Element 3—alternating red and white materials. (not required for trailers without underride protection devices).

S8.2.3.1.3.1 As shown in Figure 11, a strip of Grade DOT–C2 sheeting no less than 38 mm wide or reflectors must be applied across the full width of the horizontal member of the rear underride protection device.

S8.2.3.2 Trailer side—alternating red and white materials.

S8.2.3.2.1 As shown in Figure 11, a strip of sheeting or conspicuity reflex reflectors must be applied to each side, as horizontal as practicable, originating and terminating as close to the front and rear as practicable, as close as practicable to not less than 375 mm and not more than 1525 mm above the road surface at the strip centerline at curb weight, except that at the location chosen the strip must not be obscured in whole or in part by other motor vehicle equipment or trailer cargo.

S8.2.3.2.2 The strip need not be continuous as long as not less than half the length of the trailer is covered and the spaces are distributed as evenly as practicable.

S8.2.3.2.3 If necessary to clear rivet heads or other similar obstructions, Grade DOT–C2 sheeting may be separated into two 25 mm wide strips of the same length and color, separated by a space of not more than 25 mm and used in place of the retroreflective sheeting that would otherwise be applied.

S8.2.4 Conspicuity system installation on truck tractors.

S8.2.4.1 Element 1—alternating red and white materials. As shown in Figure 13, two strips of sheeting or conspicuity reflex reflectors, each not less than 600 mm long, located as close as practicable to the edges of the rear fenders, mudflaps, or the mudflap support brackets, must be applied to mark the width of the truck tractor.

S8.2.4.1.1 The strips must be mounted as horizontal as practicable, in a vertical plane facing the rear, on the rear fenders, on the mudflap support brackets, on plates attached to the mudflap support brackets, or on the mudflaps.

S8.2.4.1.2 Strips on mudflaps must be mounted not lower than 300 mm below the upper horizontal edge of the mudflap. If the vehicle is certified with temporary mudflap support brackets, the strips must be mounted on the mudflaps or on plates transferable to permanent mudflap support brackets.

S8.2.4.1.3 For a truck tractor without mudflaps, the strips may be mounted outboard of the frame on brackets behind the rear axle or on brackets ahead of the rear axle and above the top of the rear tires at unladen vehicle height, or they may be mounted directly or indirectly to the back of the cab as close to the outer edges as practicable, above the top of the tires, and not more than 1525 mm above the road surface at unladen vehicle height.

S8.2.4.1.4 If the strips are mounted on the back of the cab, no more than 25% of their cumulative area may be obscured by vehicle equipment as determined in a rear orthogonal view.

S8.2.4.2 Element 2—white. As shown in Figure 13, two pairs of strips of sheeting or conspicuity reflex reflectors, each pair consisting of strips 300 mm long, must be applied horizontally and vertically as practicable to the right and left upper contours of the cab, as close to the top of the cab and as far apart as practicable.

S8.2.4.2.1 No more than 25% of their cumulative area may be obscured by vehicle equipment as determined in a rear orthogonal view.

S8.2.4.2.2 If one pair must be relocated to avoid obscuration by vehicle equipment, the other pair may be relocated in order to be mounted symmetrically.

S8.2.4.2.3 If the rear window is so large as to occupy all the practicable space, the material may be attached to the edge of the window itself.

S14.2.3 Reflex reflector and retroreflective sheeting photometry.

S14.2.3.8.2 Retroreflective sheeting. The required measurement for retroreflective sheeting reflectors at each test point as shown in Table XVI is candela per lux per square meter of area.

S14.2.3.7 Procedure. Photometric measurements of reflex reflectors and retroreflective sheeting must be made at various observation and entrance angles as shown in Table XVI.

FRA Part 224 – Reflectorization of Rail Freight Rolling Stock – More Detail

PART 224—REFLECTORIZATION OF RAIL FREIGHT ROLLING STOCK

Authority:49 U.S.C. 20103, 20107, 20148 and 21301; 28 U.S.C. 2461 note; and 49 CFR 1.89.

Source:70 FR 62176, Oct. 28, 2005, unless otherwise noted.

Subpart A—General

§ 224.1 Purpose and scope.

(a) The purpose of this part is to reduce highway-rail grade crossing accidents and deaths, injuries, and property damage resulting from those accidents, by enhancing the conspicuity of rail freight rolling stock so as to increase its detectability by motor vehicle operators at night and under conditions of poor visibility.

(b) In order to achieve cost-effective mitigation of collision risk at highway-rail grade crossings, this part establishes the duties of freight rolling stock owners (including those who manage maintenance of freight rolling stock, supply freight rolling stock for transportation, or offer freight rolling stock in transportation) and railroads to progressively apply retroreflective material to freight rolling stock, and to periodically inspect and maintain that material. Freight rolling stock owners, however, are under no duty to install, clean or otherwise maintain, or repair reflective material except as specified in this part.

(c) This part establishes a schedule for the application of retroreflective material to rail freight rolling stock and prescribes standards for the application, inspection, and maintenance of retroreflective material to rail freight rolling stock for the purpose of enhancing its detectability at highway-rail grade crossings. This part does not restrict a freight rolling stock owner or railroad from applying retroreflective material to freight rolling stock for other purposes if not inconsistent with the recognizable pattern required by this part.

§ 224.3 Applicability.

This part applies to all railroad freight cars and locomotives that operate over a public or private highway-rail grade crossing and are used for revenue or work train service, except:

(a) Freight rolling stock that operates only on track inside an installation that is not part of the general railroad system of transportation;

(b) Rapid transit operations in an urban area that are not connected to the general railroad system of transportation;

(d) Freight rolling stock that is subject to a reflectorization requirement promulgated by another Federal agency.

§ 224.5 Definitions.

Administrator means the Administrator of the Federal Railroad Administration or the Administrator’s delegate.

Associate Administrator means the Associate Administrator for Safety, Federal Railroad Administration, or the Associate Administrator’s delegate.

Damaged means scratched, broken, chipped, peeled, or delaminated.

Flat car means a car having a flat floor or deck on the underframe with no sides, ends or roof (including spine cars, articulated and mult-unit intermodal cars).

Freight rolling stock means:

(1) Any locomotive subject to part 229 of this chapter used to haul or switch freight cars (whether in revenue or work train service); and

(2) Any railroad freight car (whether used in revenue or work train service).

Freight rolling stock owner means any person who owns freight rolling stock, is a lessee of freight rolling stock, manages the maintenance or use of freight rolling stock on behalf of an owner or one or more lessors or lessees, or otherwise controls the maintenance or use of freight rolling stock.

Locomotive has the meaning assigned by § 229.5 of this chapter, but for purposes of this part applies only to a locomotive used in the transportation of freight or the operation of a work train.

Obscured means concealed or hidden (i.e., covered up, as where a layer of paint or dense chemical residue blocks all incoming light); this term does not refer to ordinary accumulations of dirt, grime, or ice resulting from the normal railroad operating environment.

Person means an entity of any type covered under 1 U.S.C. 1, including but not limited to the following: A railroad; a manager, supervisor, official, or other employee or agent of a railroad; any owner, manufacturer, lessor, or lessee of railroad equipment, track or facilities; any independent contractor providing goods or services to a railroad; and any employee of such an owner, manufacturer, lessor, lessee, or independent contractor.

Railroad means all forms of non-highway ground transportation that run on rails or electromagnetic guideways, including high speed ground transportation systems that connect metropolitan areas, without regard to whether they use new technologies not associated with traditional railroads.

Railroad freight car has the meaning assigned by § 215.5 of this chapter.

Tank car means a rail car, the body of which consists of a tank for transporting liquids.

Universal Machine Language Equipment Register means the database containing information on rail equipment maintained by the Association of American Railroads.

Unqualified Retroreflective Sheeting means engineering grade sheeting, super engineering grade sheeting (enclosed lens) or high-intensity type sheeting (ASTM Type I, II, III, or IV Sheeting) as described in ASTM International Standard D–4956–04, “Standard Specification for Retroreflective Sheeting for Traffic Control.”

Work train means a non-revenue service train used for the maintenance and upkeep service of the railroad.

§ 224.7 Waivers.

(a) Any person subject to a requirement of this part may petition the Administrator for a waiver of compliance with such requirement. The filing of such a petition does not affect that person’s responsibility for compliance with that requirement while the petition is being considered.

(b) Each petition for waiver under this section shall be filed in the manner and contain the information required by part 211 of this chapter.

(c) If the Administrator finds that a waiver of compliance is in the public interest and is consistent with railroad safety, the Administrator may grant the waiver subject to any conditions that the Administrator deems necessary.

§ 224.9 Responsibility for compliance.

(a) Freight rolling stock owners, railroads, and (with respect to certification of material) manufacturers of retroreflective material, are primarily responsible for compliance with this part. However, any person that performs any function or task required by this part (including any employee, agent, or contractor of the aforementioned), must perform that function in accordance with this part.

(b) Any person performing any function or task required by this part shall be deemed to have consented to FRA inspection of the person’s facilities and records to the extent necessary to determine whether the function or task is being performed in accordance with the requirements of this part.

§ 224.11 Penalties.

(a) Any person (including but not limited to a railroad; any manager, supervisor, official, or other employee or agent of a railroad; any owner, manufacturer, lessor, or lessee of railroad equipment, track, or facilities; any employee of such owner, manufacturer, lessor, lessee, or independent contractor) who violates any requirement of this part or causes the violation of any such requirement is subject to a civil penalty of at least $1,052, but not more than $34,401 per violation, except that: Penalties may be assessed against individuals only for willful violations, and, where a grossly negligent violation or a pattern of repeated violations has created an imminent hazard of death or injury to persons, or has caused death or injury, a penalty not to exceed $137,603 per violation may be assessed. Each day a violation continues shall constitute a separate offense. FRA’s website at www.fra.dot.gov contains a schedule of civil penalty amounts used in connection with this part.

(b) Any person who knowingly and willfully falsifies a record or report required by this part is subject to criminal penalties under 49 U.S.C. 21311.

[70 FR 62176, Oct. 28, 2005, as amended at 72 FR 51197, Sept. 6, 2007; 73 FR 79702, Dec. 30, 2008; 77 FR 24420, Apr. 24, 2012; 81 FR 43110, July 1, 2016; 82 FR 16133, Apr. 3, 2017; 83 FR 60747, Nov. 27, 2018; 84 FR 23735, May 23, 2019; 84 FR 37073, July 31, 2019; 86 FR 1758, Jan. 11, 2021; 86 FR 23254, May 3, 2021; 87 FR 15868, Mar. 21, 2022; 88 FR 1127, Jan. 6, 2023]

§ 224.13 Preemptive effect.

Under 49 U.S.C. 20106, issuance of this part preempts any State law, rule, regulation, or order covering the same subject matter, except an additional or more stringent law, rule, regulation, or order that is necessary to eliminate or reduce an essentially local safety hazard; that is not incompatible with a law, rule, regulation, or order of the United States Government; and that does not unreasonably burden interstate commerce.

§ 224.15 Special approval procedures.

(a) General. The following procedures govern consideration and action upon requests for special approval of alternative standards under § 224.103(e).

(b) Petitions.

(1) Each petition for special approval of an alternative standard shall contain—

(i) The name, title, address, and telephone number of the primary person to be contacted with regard to the petition;

(ii) The alternative proposed, in detail, to be substituted for the particular requirements of this part; and

(iii) Appropriate data and analysis establishing that the alternative will provide at least an equivalent level of safety and meet the requirements of § 224.103(e).

(2) Each petition for special approval of an alternative standard shall be submitted to the Docket Clerk, Office of Chief Counsel, Federal Railroad Administration, RCC–10, Mail Stop 10, 1200 New Jersey Avenue, SE., Washington, DC 20590.

(c) Notice. FRA will publish a notice in the Federal Register concerning each petition under paragraph (b) of this section.

(d) Public comment. FRA will provide a period of not less than 30 days from the date of publication of the notice in the Federal Register during which any person may comment on the petition.

(1) Each comment shall set forth specifically the basis upon which it is made, and contain a concise statement of the interest of the commenter in the proceeding.

(2) Each comment shall be submitted to the U.S. Department of Transportation, Docket Operations (M–30), West Building Ground Floor, Room W12–140, 1200 New Jersey Avenue, SE., Washington, DC 20590, and shall contain the assigned docket number which appears in the Federal Register for that proceeding. The form of such submission may be in written or electronic form consistent with the standards and requirements established by the Federal Docket Management System and posted on its Web site at http://www.regulations.gov.

(3) In the event FRA determines that it requires additional information to appropriately consider the petition, FRA will conduct a hearing on the petition in accordance with the procedures provided in § 211.25 of this chapter.

(e) Disposition of petitions.

(1) If FRA finds that the petition complies with the requirements of this section and that the proposed alternative standard is acceptable or changes are justified, or both, the petition will be granted, normally within 90 days of its receipt. The Associate Administrator may determine the applicability of other technical requirements of this part when rendering a decision on the petition. If the petition is neither granted nor denied within 90 days, the petition remains pending for decision. FRA may attach special conditions to the approval of the petition. Following the approval of a petition, FRA may reopen consideration of the petition for cause stated.

(2) If FRA finds that the petition does not comply with the requirements of this section, or that the proposed alternative standard is not acceptable or that the proposed changes are not justified, or both, the petition will be denied, normally within 90 days of its receipt.

(3) When FRA grants or denies a petition, or reopens consideration of a petition, written notice is sent to the petitioner and other interested parties and a copy of the notice is placed in the electronic docket of the proceeding.

[70 FR 62176, Oct. 28, 2005, as amended at 74 FR 25173, May 27, 2009]

Subpart B—Application, Inspection, and Maintenance of Retroreflective Material

§ 224.101 General requirements.

All rail freight rolling stock subject to this part shall be equipped with retroreflective sheeting that conforms to the requirements of this part. Notwithstanding any other provision of this chapter, the application, inspection, and maintenance of that sheeting shall be conducted in accordance with this subpart or in accordance with an alternative standard providing at least an equivalent level of safety after special approval of FRA under § 224.15.

§ 224.103 Characteristics of retroreflective sheeting.

(a) Construction. Retroreflective sheeting applied pursuant to this part shall consist of a smooth, flat, transparent exterior film with microprismatic retroreflective elements embedded in or suspended beneath the film so as to form a non-exposed retroreflective optical system.

(b) Color. Retroreflective sheeting applied pursuant to this part shall be yellow, fluorescent yellow, or white as specified by the chromaticity coordinates of ASTM International’s Standard D 4956–04, “Standard Specification for Retroreflective Sheeting for Traffic Control.” The Director of the Federal Register approves the incorporation by reference of this standard in this section in accordance with 5 U.S.C. 552(a) and 1 CFR part 51. You may obtain a copy of the incorporated standard from ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428–2959 or at http://www.astm.org. You may inspect a copy of the incorporated standard at the Federal Railroad Administration, Docket Clerk, 1200 New Jersey Avenue, SE., Washington, DC 20590 or at the National Archives and Records Administration (NARA). For information on the availability of this material at NARA, call 202–741–6030, or go to http://www.archives.gov/federal_register/code_of_federal_regulations/ibr_locations.html.

(c) Performance. Retroreflective sheeting applied pursuant to this part shall meet the requirements of ASTM D 4956–04, for Type V Sheeting if metalized or Type VII Sheeting if non-metalized, except for the initial minimum values of the coefficient of retroreflection, and shall, as initially applied, meet the minimum values for the coefficient of retroreflection specified in Table 1 of this subpart.

[70 FR 62176, Oct. 28, 2005, as amended at 74 FR 25173, May 27, 2009]

Table 1 to Subpart B of Part 224—Minimum Coefficient of Retroreflection (R_A) (in Candela/Lux/Meter²) Requirement for Retroreflective Sheeting (Minimum Photometric Performance Requirements)

Entrance angle	Observation angle
	0.2 Degree		0.5 Degree
	Yellow or fluorescent yellow	White	Yellow or fluorescent yellow	White
−4°	400	600	100	160
30°	220	350	45	75

(d) Certification. The characters “FRA–224”, constituting the manufacturer’s certification that the retroreflective sheeting conforms to the requirements of paragraphs (a) through (c) of this section, shall appear at least once on the exposed surface of each piece of sheeting in the final application. The characters shall be a minimum of three millimeters high, and shall be permanently stamped, etched, molded, or printed within the product and each certification shall be spaced no more than four inches apart.

(e) Alternative standards. Upon petition by a freight rolling stock owner or railroad under § 224.15, the Associate Administrator may approve an alternative technology as providing equivalent safety. Any such petition shall provide data and analysis sufficient to establish that the technology will result in conspicuity and durability at least equal to sheeting described in paragraphs (a) through (c) applied in accordance with this part and will present a recognizable visual target that is suitably consistent with freight rolling stock equipped with retroreflective sheeting meeting the technical requirements of this part to provide the intended warning to motorists.

§ 224.105 Sheeting dimensions and quantity.

Retroreflective sheeting shall be applied along the length of each railroad freight car and locomotive side as described in § 224.106. Unless otherwise specified, retroreflective sheeting applied under this part shall be applied in strips 4 inches wide and 18 or 36 inches long, as practicable. The amount of retroreflective sheeting to be applied to each car or locomotive subject to this part is dependent on the length of the car or locomotive and the color of the sheeting. For purposes of this part, the length of a railroad freight car or locomotive is measured from endsill to endsill, exclusive of the coupler and draft gear. Each side of a railroad freight car subject to this part, including each unit of multi-unit cars, and each side of a locomotive subject to this part must be equipped with at least the minimum amount of retroreflective sheeting specified in Table 2 of this subpart.

Table 2 to Subpart B of Part 224—Minimum Quantity Requirement for Retroreflective Sheeting on Freight Rolling Stock

Freight car or locomotive length	Minimum area of retroreflective sheeting required (per car/locomotive side)—yellow sheeting (ft²)	Minimum area of retroreflective sheeting required (per car/locomotive side)—white sheeting (ft²)
Less than 50 ft.	3.5	4.0
Over 50 ft. to 60 ft.	4.0	5.0
Over 60 ft. to 70 ft.	4.5	5.5
Over 70 ft. to 80 ft.	5.0	6.0
Over 80 ft. to 90 ft.	5.5	7.0
Over 90 ft. to 100 ft.¹	6.0	7.5

§ 224.106 Location of retroreflective sheeting.

(a) Railroad freight cars. The retroreflective sheeting shall be applied along the length of each railroad freight car side in the manner provided by a uniform industry standard accepted by the Associate Administrator that provides for distribution of material along the length of each car and as close as practicable to 42 inches above the top of rail. In the event such a standard is not proffered by industry or accepted by the Associate Administrator, the criteria set forth in this subpart shall apply. Retroreflective sheeting applied under this part must be located clear of appurtenances and devices such as ladders and other safety appliances, pipes, or other attachments that may obscure its visibility. Retroreflective sheeting need not be applied to discontinuous surfaces such as bolts, rivets, door hinges, or other irregularly shaped areas that may prevent the sheeting from adhering to the car sides. In addition, retroreflective sheeting need not be applied over existing or required car stencils and markings. If necessary to avoid appurtenances, discontinuous surfaces, or existing or required car markings or stencils, 4×18 and 4×36 inch strips of retroreflective material may be divided into 4×9 inch strips and applied on either side of the appurtenance, discontinuous surface, or car markings or stencils, as practicable. Unless otherwise specified, retroreflective sheeting shall be applied along the sides of freight rolling stock at intervals not to exceed every 12 feet, as practicable. If it is not practicable to apply retroreflective sheeting every 12 feet because of existing stencils, appurtenances, or discontinuous surfaces, the sheeting shall be applied at the next smallest interval practicable.

(1) General rule. On railroad freight cars other than flat cars and tank cars, retroreflective sheeting shall be applied in either a vertical or horizontal pattern along the length of the car sides, with the bottom edge of the sheeting as close as practicable to 42 inches above the top of rail. Retroreflective sheeting shall not be applied below the side sill.

(i) Vertical application. If retroreflective sheeting is applied in a vertical pattern, at least one 4×36 inch strip or two 4×18 inch strips, one above the other, shall be applied as close to each end of the car as practicable. Between these two vertical end strips, a minimum of one 4×18 inch strip shall be applied at least every 12 feet, as practicable. SeeFigures 1, 2 and 3.

(ii) Horizontal application. If retroreflective sheeting is applied in a horizontal pattern, at least one 4×36 inch strip, or two 4×18 inch strips, one above or next to the other, shall be applied as close to each end of the car as practicable. Between these end strips, a minimum of one 4×18 inch strip shall be applied at least every 12 feet, as practicable. See Figures 4, 5, and 6.

(2) Tank cars. On tank cars, retroreflective sheeting shall be applied vertically to each car side and centered on the horizontal centerline of the tank, or as near as practicable. If it is not practicable to safely apply the sheeting centered vertically about the horizontal centerline of the tank, the sheeting may be applied vertically with its top edge no lower than the horizontal centerline of the tank. A minimum of either one 4×36 inch strip or two 4×18 inch strips, one above the other, shall be applied as close to each end of the car as practicable. Between these two end strips, a minimum of one 4×18 inch strip shall be applied at least every 12 feet, as practicable. Retroreflective sheeting applied under this part shall not be located in the spillage area directly beneath the manway used to load and unload the tank. See Figures 7 and 8.

(3) Flat cars. On flat cars, retroreflective sheeting shall be applied in a horizontal pattern along the length of the side sill with the bottom edge of the sheeting no lower than the bottom of the side sill and the top edge of the sheeting no higher than the top of the car deck or floor. At least two 4×18 inch strips, one above the other, shall be applied as close to each end of the car as practicable. If the side sill is less than 8 inches wide, one 4×36 inch strip, or two 4×18 inch strips may be applied one next to the other, dividing the strips into nine inch segments as necessary in accordance with paragraph (a) of this section. Between the two end strips, a minimum of one 4×18 inch strip shall be applied at least every 12 feet, as practicable. See Figure 9. If a car has a separate rack structure, retroreflective sheeting may be applied to the flat car portion only in accordance with the requirements of this section. For cars without continuous side sills, retroreflective sheeting may be applied to other surfaces inboard of the sides, such as the center sill, provided that the sheeting is not obscured by other components.

(4) Cars of special construction. This paragraph applies to any car the design of which is not compatible with the patterns of application otherwise provided in this section. Retroreflective sheeting shall conform as closely as practicable to the requirements of paragraphs (a)(1) through (a)(3) of this section and shall have the minimum amount of sheeting described in § 224.105 distributed along the length of each car side.

(b) Locomotives. Locomotives subject to this part shall be equipped with at least the minimum amounts of retroreflective sheeting required by § 224.105 either in strips four inches wide and 18 or 36 inches long and spaced as uniformly as practicable along the length of the locomotive sides, or in one continuous strip, at least four inches wide, along the length of the locomotive. Retroreflective sheeting applied to locomotive sides shall be applied as close as practicable to 42 inches from the top of the rail.

§ 224.107 Implementation schedule.

(a) Railroad freight cars. All railroad freight cars subject to this part must be equipped with retroreflective sheeting conforming to this part by November 28, 2015. If a car already has reflective material applied that does not meet the standards of this part, it is not necessary to remove the material unless its placement interferes with the placement of the sheeting required by this part.

(1) New cars. Retroreflective sheeting conforming to this part must be applied to all cars constructed after January 26, 2006, before the cars are placed in service.

(2) Existing cars without retroreflective sheeting.

(i) If, as of October 28, 2005, a car subject to this part is not equipped on each side with at least one square foot of retroreflective sheeting as specified in paragraph (a)(3) of this section, retroreflective sheeting conforming to this part must be applied to the car at the earliest of the following two occasions occurring after November 28, 2005 or in accordance with paragraph (a)(2)(ii) of this section:

(A) When the car is repainted or rebuilt; or

(B) Within nine months (270 calendar days) after the car first undergoes a single car air brake test as prescribed by 49 CFR 232.305.

(ii) A freight rolling stock owner may elect not to follow the schedule in paragraph (a)(2)(i) of this section if, not later than January 26, 2006 the freight rolling stock owner submits to FRA a completed Reflectorization Implementation Compliance Report certifying that the cars in the owner’s fleet subject to this part will be equipped with retroreflective sheeting as required by this part in accordance with the schedule specified in Table 3 of this section. See Appendix B of this part for Reflectorization Implementation Compliance Report form.

Table 3 to Subpart B of Part 224—Alternative Schedule for Application of Retroreflective Material to Freight Cars per § 224.107(a)(2)(ii)

(A)¹	(B) (percent)
November 28, 2007	20
November 28, 2008	30
November 28, 2009	40
November 28, 2010	50
November 28, 2011	60
November 28, 2012	70
November 28, 2013	80
November 28, 2014	90
November 28, 2015	100

Thereafter,

(A) The designated fleet shall be equipped with retroreflective sheeting according to the schedule specified in Table 3 of this section;

(B) No later than January 28, 2008, the freight rolling stock owner shall submit to FRA an updated Reflectorization Implementation Compliance Report showing which cars of the fleet subject to this part were equipped with retroreflective sheeting as required by this part during the initial 24-month implementation period. Thereafter, updated Reflectorization Implementation Compliance Reports shall be submitted annually, no later than December 31 of each year for the duration of the 10-year implementation period. See Appendix B of this part.

(C) If, following the conclusion of the initial 24-month period or any 12-month period thereafter, the percentage requirements of this section have not been met—

(1) The freight rolling stock owner shall be considered in violation of this part;

(2) The freight rolling stock owner shall, within 60 days after the close of the period, report the failure to the Associate Administrator;

(3) The requirements of paragraph (a)(2)(i) shall apply to all railroad freight cars subject to this part in the freight rolling stock owner’s fleet; and

(4) The fleet owner shall take such additional action as may be necessary to achieve future compliance.

(D) Cars to be retired shall be included in the fleet total until they are retired.

(3) Existing cars with retroreflective sheeting. If as of October 28, 2005, a car is equipped on each side with at least one square foot of retroreflective sheeting, uniformly distributed over the length of each side, that car shall be considered in compliance with this part through November 28, 2015, provided the sheeting is not unqualified retroreflective sheeting, and provided the freight rolling stock owner files a completed Reflectorization Implementation Compliance Report with FRA no later than January 26, 2006 identifying the cars already so equipped. See Appendix B of this part for Reflectorization Implementation Compliance form.

(b) Locomotives. Except as provided in paragraph (b)(4) of this section, all locomotives subject to this part must be equipped with conforming retroreflective sheeting by November 28, 2010. If a locomotive already has reflective material applied that does not meet the standards of this part, it is not necessary to remove the material unless its placement interferes with the placement of the sheeting required by this part.

(1) New locomotives. Retroreflective sheeting conforming to this part must be applied to all locomotives constructed after January 26, 2006, before they are placed in service.

(2) Existing locomotives without retroreflective sheeting.

(i) If as of October 28, 2005 a locomotive subject to this part is not equipped with the minimum amount of retroreflective sheeting specified in paragraph (b)(3) of this section, retroreflective sheeting conforming to this part must be applied to the locomotive not later than nine months after the first biennial inspection performed pursuant to 49 CFR 229.29 occurring after November 28, 2005.

(ii) A freight rolling stock owner may elect not to follow the schedule in paragraph (b)(2)(i) of this section, if not later than January 26, 2006, the freight rolling stock owner submits to FRA a Reflectorization Implementation Compliance Report certifying that the locomotives in the owner’s fleet subject to this part will be equipped with retroreflective sheeting as required by this part in accordance with the schedule specified in Table 4 of this section. See Appendix B of this part.

Table 4 to Subpart B of Part 224—Alternative Schedule for Application of Retroreflective Material to Locomotives per § 224.107(b)(2)(ii)

(A)¹	(B) (percent)
November 28, 2007	40
November 28, 2008	60
November 28, 2009	80
November 28, 2010	100

Thereafter,

(A) The designated locomotive fleet shall be equipped with retroreflective sheeting according to the requirements of this paragraph (b)(2)(ii);

(B) No later than January 28, 2008, the freight rolling stock owner shall submit to FRA an updated Reflectorization Implementation Compliance Report showing which locomotives of the fleet subject to this part were equipped with retroreflective sheeting as required by this part during the initial 24 month implementation period. Updated Reflectorization Implementation Compliance Reports shall be submitted annually, no later than December 31 of each year, for the duration of the 5-year implementation period. See Appendix B of this part.

(C) If, following the conclusion of the initial 24-month period or any 12-month period thereafter, the percentage requirements of this section have not been met—

(1) The freight rolling stock owner shall be considered in violation of this part;

(2) The freight rolling stock owner shall, within 60 days after the close of the period, report the failure to the Associate Administrator;

(3) The requirements of paragraph (b)(2)(i) shall apply to all locomotives subject to this part in the freight rolling stock owner’s fleet; and

(4) The fleet owner shall take such additional action as may be necessary to achieve future compliance.

(D) Locomotives to be retired shall be included in the fleet total until they are retired.

(3) Existing locomotives with retroreflective sheeting. If as of October 28, 2005, a locomotive is equipped on each side with at least one square foot of retroreflective sheeting, that locomotive shall be considered in compliance with this part for through November 28, 2015, provided the existing material is not unqualified retroreflective sheeting, and provided the freight rolling stock owner files a Reflectorization Implementation Compliance Report with FRA no later than January 26, 2006, identifying the cars already so equipped. See appendix B of this part. If, as of October 28, 2005, a locomotive is equipped with unqualified retroreflective sheeting, the locomotive will be considered in compliance with this part through November 28, 2015, provided the locomotive is equipped with a minimum of 3 square feet of retroreflective material on each side and provided the freight rolling stock owner files a Reflectorization Implementation Compliance Report with FRA no later than January 26, 2006, identifying the locomotives already so equipped. See appendix B of this part.

(4) Each railroad that has fewer than 400,000 annual employee work hours as of the end of calendar year 2004, and does not share locomotive power with another railroad with 400,000 or more annual employee work hours, may bring its locomotive fleet into compliance according to the following schedule: fifty percent of the railroad’s locomotives must be retrofitted pursuant to § 224.106(b) by October 28, 2010, and one hundred percent must be retrofitted pursuant to § 224.106(b) by October 28, 2015. If a railroad with fewer than 400,000 annual employee work hours shares locomotive power with a railroad with 400,000 or more annual employee work hours, the smaller railroad must comply with the requirements of paragraphs (b)(2) and (3) of this section.

§ 224.109 Inspection, repair, and replacement.

(a) Railroad freight cars. Retroreflective sheeting on railroad freight cars subject to this part must be visually inspected for presence and condition whenever a car undergoes a single car air brake test required under 49 CFR 232.305. If at the time of inspection less than 80 percent of the amount of sheeting required under § 224.105 (§ 224.107 in the case of freight cars subject to § 224.107(a)(3)) on either side of a car is present, not damaged, and not obscured, the inspecting railroad or contractor shall promptly notify the person responsible for the reporting mark, as indicated in the Universal Machine Language Equipment Register, of the damaged, obscured, or missing sheeting (unless the inspecting railroad or contractor is the person responsible for the reporting mark). The inspecting railroad or contractor shall retain a written or electronic copy of each such notification made for at least two years from the date of the notice and shall make these records available for inspection and copying by the FRA upon request. Any person notified of a defect under this section shall have nine months (270 calendar days) from the date of notification to repair or replace the damaged, obscured, or missing sheeting. Where the inspecting railroad or contractor is the person responsible for the reporting mark, the person shall have nine months (270 calendar days) from the date of the inspection to repair or replace the damaged, obscured, or missing sheeting.

(b) Locomotives. Retroreflective sheeting must be visually inspected for presence and condition when the locomotive receives the annual inspection required under 49 CFR 229.27. If at the time of inspection less than 80 percent of the amount of sheeting required under § 224.105 (§ 224.107 in the case of locomotives subject to § 224.107(b)(3)) on either side of a locomotive is present, not damaged, and not obscured, the damaged, obscured, or missing sheeting must be repaired or replaced within nine months (270 calendar days) from the date of inspection, provided a record of the defect is maintained in the locomotive cab or in a secure and accessible electronic database to which FRA is provided access on request.

§ 224.111 Renewal.

Regardless of condition, retroreflective sheeting required under this part must be replaced with new sheeting no later than ten years after the date of initial installation. At the time of replacement, it is not necessary to remove the old sheeting unless it interferes with the placement of the new sheeting, but the old sheeting shall not be considered in calculating the amount of retroreflective material required under this part. For purposes of this section, November 28, 2005, shall be considered the initial date of installation for freight cars and locomotives covered by § 224.107(a)(3) or 224.107(b)(3).

NHTSA Report on the Effectiveness of DOT C2 Retro Reflective Tape on Tractor Trailers

In 2001, after all trucks had either been manufactured with retro reflective DOT C2 tape that met NHTSA specifications, or had been retro-fitted, the agency conducted a study of the reflective tapes effectiveness in preventing accidents.

It was found that by treating a truck and trailer with DOT C2 with the minimum required retro reflective DOT C2 (2″ wide), in accordance with the regulation, accidents at night were reduced by 44%. (up to 5000 injuries and 350 fatalities prevented) The report, quoted below, covers a variety of important subjects and discusses the difficulty of night time visibility when it comes to the large on the road trucks and trailers.

Keep in mind that 2″ wide DOT C2 tape is the minimum standard. But C3 and C4 (3″ and 4″ wide) tapes are also available and would provide even more night time conspicuity, hence decreasing accidents. (see DOT C2 FMCSA regulation)

The full study performed by the NHTSA is below.

FRA 224 Train Retro Reflective Marking Requirements (Regulation)

Trains and freight cars pose a great danger to passenger vehicles, should the two ever come in contact with each other. Tractor trailer rigs are large, heavy and immovable, but freight cars are more so. To reduce the incidences of train and passenger car collisions, the Federal Rail Association passed FRA 224, a regulation that requires all rail stock be clearly marked with retro reflective strips at specific intervals. The regulation is posted below.

FMCSA’s Conspicuity Requirements for Commercial Motor Vehicles

You will find below the FMCSA (Federal Motor Carrier Safety Administration) regulation for marking DOT regulated trucks and trailers. This regulation was passed by the NHTSA (National Highway Traffic Safety Association) in December of 1992 and is applicable to all trucks with a gross vehicle weight of 10,000 pounds and an overall width of 80 inches. The purpose of this regulation is reduce the number of collisions between large trucks and passenger vehicles. In 2001, the effectiveness of this regulation was analyzed and a report was prepared by the NHTSA showing a decrease in accidents of 44% for trucks and trailers properly treated with retro reflective tape.

Retro Reflectivity and DOT Regulated Trucks – Summary

Tractor-trailer rigs, among the largest vehicles on American highways, pose significant risks to smaller vehicles. Annually, collisions involving these large trucks lead to around 120,000 injuries and over 5,000 deaths in the United States. Due to their massive and solid structure, tractor-trailers are particularly unforgiving in accidents with smaller vehicles, often resulting in severe outcomes.

Contrary to what one might expect, the substantial size of these trucks doesn’t always aid in visibility. In many driving scenarios, their large trailers can blend into the surroundings, becoming virtually invisible to approaching drivers. This effect is similar to how the outer edges of an IMAX screen can vanish from a viewer’s peripheral vision. The situation is further complicated by competing lights from the truck and other vehicles, especially problematic at night when the trailer towed by a truck often remains unseen until its headlight pass by.

History of the Application of Reflective Tape to Trucks
Nighttime visibility has always been a key component in accidents involving large trucks. The core problem is that drivers often fail to notice these large trucks in time to prevent a collision, especially in low-light conditions. In modern times, the most significant visibility issues arise from the use of either insufficient or poorly maintained reflective tape on trucks.

However, prior to 1992, the situation was more critical as there was no mandate for trucks to use retroreflective tape. Without this tape, trucks were even harder to spot at night, increasing the risk of accidents. The absence of mandatory retroreflective tape meant that many trucks blended into the dark surroundings, making them virtually invisible to other road users until it was too late to avoid a collision. The introduction of regulations requiring reflective tape on trucks was a significant step towards improving nighttime visibility and reducing accidents.

To address this, the NHTSA implemented a regulation in December 1992, mandating the use of retroreflective tape in specific locations on DOT-regulated trucks. By June 2001, all trucks were required to have this tape, and by June 2009, uniformity in truck markings was achieved. The minimum standard is DOT C2 tape, which is 2 inches wide, but wider options like DOT C3 and C4 tapes are also permitted and offer increased visibility.

A 2001 NHTSA study confirmed the effectiveness of this regulation, finding a 44% reduction in nighttime accidents involving trucks with the required retroreflective tape. This measure is estimated to prevent up to 5,000 injuries and 350 fatalities each year, demonstrating its efficacy.

However, issues persist with trucks that either lack sufficient markings as per DOT standards or use old, UV-damaged, and weathered tape, which compromises visibility and heightens accident risks. It’s vital to maintain proper markings with fresh, certified high-quality branded tape to enhance visibility and allow other drivers adequate time to spot and avoid trucks.

Interestingly, FMCSA regulations specify that trucks can use DOT retroreflective tape ranging from 2 inches (C2) to 4 inches (C4) in width. While all three sizes are available, 4-inch tape offers double the reflectivity and visibility. Despite this, 99% of trucks on the road use the minimum C2 tape.