FMCSR 393.11 Footnote 5 - Lights on Converter Dollies
| Entry Date | December 13, 2012 |
|---|---|
| Issue Number | 12-037-VEH |
| Name | Ted Scott |
| Agency | American Trucking Associations |
| Address | 950 N. Glebe RoadArlington, VA, 22203United StatesMap It (opens in a new tab) |
| Phone | 703-838-1908 |
| [email protected] | |
| Committee | Vehicle Committee |
| Status | Closed |
| Summary of Issue | FMCSR 393.11 lamps, tail lamps is written to allow converter dollies when being used in full trailer configuration to not need working stop and tail lamps on the rear of the dolly. Most dollies when in full trailer mode operate in this manner. When being towed singly the tail and stop lamps are operational. In two cases in the last year and a half in Georgia and Virginia, violations have been written for non-operational converter dolly lamps when in full trailer mode. The language used in FMCSR 393.11 footnote 5, can be considered confusing and should be adjusted to eliminate any confusion as to when converter dolly lamps should work. |
| Justification or Need | In both cases mentioned above the eventual DataQ submission after considerable education has removed the CSA violation. However, there are thousands of converter dollies operating through out North America with the ability to not have the lamps operational when in full trailer mode. |
| Request for Action | Change 393.11 footnote 5 to clearly state that stop and tail lamps do not need to be operational when the converter dolly is in full trailer mode. |