Operational Policy 15 - Guidance for 390.21T(b)

There should be guidance or operational policy on when to cite 390.21T. On June 13, 2024 we had two vehicles/drivers stopped for Level 1 DOT Inspections by the same officer with the California Highway Patrol within hours of each other. During the inspections the only violation that was listed for each Truck was for 390.21T(b) Carrier number displayed on vehicle is not clearly legible from at least 50 feet. Attached images show the measurements for our DOT Markings that are the standard on our 24,000 plus truck fleet. We subsequently filed a DataQ for each inspection and the violations were then removed by the officer citing ", due to insufficient documentation of the violation". We do not believe this an Agency issue but rather an officers interpretation/variation of eye sight.

390.21T(c) states that the marking must (1) Appear on both sides of the self-propelled CMV; (2) Be in letters that contrast sharply in color with the background on which the letters are placed; (3) Be readily legible, during daylight hours, from a distance of 50 feet (15.24 meters) while the CMV is stationary; and (4) Be kept and maintained in a manner that retains the legibility required by paragraph (c)(3) of this section. The regulation does not state a measurement that the numbers or letters must be, or state what color decals cannot be used on certain colors of vehicles. Instead it is broad enough to allow for vastly different interpretations/eye sight by agencies or officers.

Create guidance for officers on when to cite 390.21 violations, or make an addition to Operational Policy 15.