OOSC, Part II, Item 9. Lighting Devices (4) - Electrical System - Towed Vehicle

There has been some discontenting views on the parallels, or lack there of, of documenting 393.17 and 393.23, specific to documenting lighting violations in drive-away and converter dolly.

It is this inspectors interpretation 393.23 is specific to trailers to document the failure of the power supply line from truck to trailer, by way of either the driver failing to connect or other means of disconnecting. This is supported by OPS 14, where the inspector re-establishes the connection and then documents lighting violations, if "none" they only document the 393.23PT violation. Conversely, when documenting the 393.17 violation on a tow truck hauling a vehicle on the bed and a vehicle on the converter dolly, the inspector would site each individual lamp violation separately without documenting the power supply may have disconnected OR battery of the wifi lamps didn't have adequate power supply to operate the lamps on the rear unit.

In this case, on inspections where the 393.23PT violation is documented you have 1 violation resulting in CSA scores being affected, where as with 393.17 violations it is possible to have 5 violations being listed resulting in additional CSA score increases, when in fact the two violations are similar. I'd request a subpart be added to 393.23 to specifically address power supply to converter dolly's when the power supply is amiss. This could be accomplished by subpart A - 393.23PS, Power supply to rear most unit lighting assembly disconnected/failure (OOS violation). This would simply parallel the two regulatory sections to a consistent documentation and CVSA applicability in assessing appropriate safety scores.