Reverse Lamps - 393.11 Table - Location Clarification

FMCSA 393.11 Light Table required Semi Tractor (Truck tractor Legend C) Backup Lamp. Footnote 14; Backup lamp required to operate when truck tractor is in reverse. The Light Table, for the reverse lamp, clearly documents Location as Rear, Position as Rear, and Height above road surface as No Requirement. Figure 1 Truck diagram illustration for 393.11(a)(1) shows # 9-Backup Lamp can be positioned anywhere within the perforated outline at the rear of the tractor. This is also clarified in FMCSA Regulation 393.11(a)(1) – The diagrams in this section illustrate the position of the lamps specified in Table 1. All commercial motor vehicles manufactured on or after Dec 25, 1968, must, at a minimum, meet the applicable requirements of 49 CFR 571.108 (FMVSS No. 108). When you review this the Mounting location documents “On the rear” and S7.6.4.Mounting height documents No Requirements. This has posed an issue on Roadsides if the backup lamp(s) are located (installed) at the rear of the sleeper berth (where the lamp(s) can now be free of damages when originally located at the rear of the last drive axle. There should be NO violation if there is one or two white lamps, illuminates when the tractor is placed in reverse, and the lamp(s) are located at the REAR of the tractor with no height requirement.

A DataQ was submitted only to be denied because the backup lamps were located on each side at the rear of the sleeper berth. However, the backup lamps were in the required area of the perforated outline (rear of tractor) as illustrated in Regulation 393.11(a)(1) Figure 1 Truck Diagram. Both illuminated when the tractor was placed in reverse, brighter lamps (required white) for backup vison, better positioning, and free of any road damages that could occur if located at the end of the rear axle. The Officer’s superior stated the Regulation requires the backup lamp, as manufactured, must be installed at the most rear lower portion of the rear drive axle, in the license plate area, and cannot be moved anywhere at the rear of the tractor.

Need clarification to prevent these violation issues at roadside via an updated Footnote in the Light Table. As example when the License Plate Footnote was updated to clarify the FMCSA Regulation.