Guide to DOT Federal Safety Regulations for Trailer ...

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The Motor Carrier Safety Improvement Act of  went into effect on January 1, , after being introduced in the House just 60 days prior. The bill signified a measurable shift in the way the federal government handled and processed its commercial vehicle safety and compliance standards. This date also marked the birth of the Federal Motor Carrier Safety Administration (FMCSA), an organization working under the umbrella of the Department of Transportation. The introduction of the FMCSA helped the agency to better handle the affairs of commercial vehicles, including its licensing and data and analysis, as well as its regulatory compliance and enforcement procedures.

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Ever since the change, commercial vehicles have faced an unprecedented level of scrutiny, particularly in terms of safety. This is especially true for the manufacturing processes and sales of commercial trailers, because guidelines stipulated by the FMCSA under the guidance of the Department of Transportation must be followed by all applicable parties, not just their operating entities.

Because these guidelines may vary depending on the state in which the trailer is sold and/or used, the cross-departmental nature can make for confusion. To remedy this, we&#;ve compiled a guide featuring the most important DOT federal safety regulations as they relate to truck trailer manufacturers. Below, you&#;ll find an outline of the illustrated key points:

For an in-depth look at the various federal safety regulations and compliance programs for truck trailer manufacturers, read on.

Federal Requirements for Trailer Manufacturers

We have already made mention of how the DOT and FMCSA are associated, but there is yet another federal agency that oversees the manufacturing practices of truck trailers &#; the National Highway Traffic Safety Administration (NHTSA). In its guide, Requirements for Manufacturers of Trailers Produced for Distribution Within the U.S. Market, the agency details the initial rules that trailer manufacturers are made to follow.

In the guide, manufacturers are taken through the various processes put into place to ensure their compliance, all of which must be made available prior to, during, and after the manufacturing of the applicable trailers. The key safety points are as follows:

• Any manufacturer who violates the safety regulations outlined in the guide will be &#;subject to a civil penalty not to exceed $6,000 for each violation, or $16,375,000 for any related series of violations.&#;
• All foreign manufacturers must be in full compliance with the safety regulations formed by the DOT.
• Each trailer must include a VIN that follows the format, content and physical requirements.
• All certification labels must be properly affixed.
• Manufacturers must provide customers with a one-page purchaser statement.
• Manufacturers must provide customers with proof of certification (more on this later).

The above information only scratches the surface, as safety compliance also covers the trailer manufacturers&#; responsibility in terms of tire selection, weight, visibility, and more. To determine, whether or not you, as a trailer manufacturer, are subject to the regulations, first get to know how the DOT defines a heavy-duty or commercial trailer. A commercial trailer is:

• A vehicle with a GCWR or GVWR of more than 10,000 lbs. (this denotes the combined weight of the trailer and truck)
• Vehicles exceeding 26,000 lbs. which require the driver to hold a CDL
• Vehicles hauling hazardous materials, as defined by the DOT

For more information and forms on the vehicles that constitute certification and/or importation documents, visit the NHTSA website.

How to Obtain a World Manufacturing Identifier (WMI)

As mentioned, it is compulsory for each and every truck trailer manufacturer to obtain a Vehicle Identification Number (VIN) before the sale of the piece of equipment. This is not a process that can be self-reported &#; each VIN contains a coded description that includes the trailer&#;s manufacturer name, year of production, place of production, and other specialized characteristics. 

To help make the VIN distribution process more streamlined, the NHTSA contracts with a company called SAE International. It is the job of this private firm to provide manufacturers with a selected portion of the VIN, called the World Manufacturing Identifier (WMI). Without the WMI, a trailer&#;s VIN is considered incomplete.

In order to obtain a WMI, you must first begin an application with SAE International, using its online application form. Manufacturers based outside of the United States who plan on doing business with U.S. fleets must obtain and submit a Non-US WMI Application. Take note: an additional one-time fee of $525 USD must be made payable to SAE International in order to successfully obtain a Non-US WMI.

NHTSA Registration and Data Plates

Now that the WMI has been obtained, the trailer manufacturer is ready to register its trailer&#;s VIN with the NHTSA. According to the Electronic Code of Federal Regulations Office, the General Requirements (§565.13) are as follows:

• Every vehicle manufactured in one stage must have a VIN assigned by the manufacturer.
• Vehicles manufactured in multiple stages must have a VIN assigned by the incomplete vehicle manufacturer.
• Any entities altering vehicles (specified in 49 CFR 567.7) should use the VIN assigned by the original vehicle manufacturer.
• VINs consist of 17 characters, including a check digit which appears in position 9 of the VIN. It must be present on the vehicle as well as any transfer documents.
• VINs must be unique: No two vehicles subject to the federal motor vehicle safety standards, manufactured within a 60-year period beginning with the model year, will share an identical VIN.
• Every vehicle&#;s VIN should appear clearly on a part of the vehicle (other than the glazing) that is not designed to be removed (other than for repair purposes), or on a separate plate or label permanently affixed to a part of the vehicle meeting the same requirements.
• For passenger cars, multipurpose passenger vehicles, low-speed vehicles, and trucks with a GVWR of kg or less, the VIN should be located inside the passenger compartment. The VIN must be &#;readable, without moving any part of the vehicle, through the vehicle glazing under daylight lighting conditions by an observer having 20/20 vision (Snellen) whose eye-point is located outside the vehicle adjacent to the left windshield pillar.&#; Each character in the VIN must be at least 4 mm in height.
• Each character in every VIN must be one of the letters in the set: [ABCDEFGHJKLMNPRSTUVWXYZ] or a number in the set: []. These must be assigned using the method outlined in §565.15. All spaces in the VIN must be accompanied by one of these characters.
• Capital, san-serif typeface must be used for the VIN.

Once a VIN that includes a WMI provided by SAE International is affixed to the vehicle, the trailer manufacturer must register the VIN with the NHTSA at least 60 days prior to the first sale of the trailer. There is currently no online portal available for this task. Instead, manufacturers must send the above information, along with any other applicable forms, to:

Administrator, National Highway Traffic Safety Administration
New Jersey Avenue, SE
Washington, DC
Attention: VIN Coordinator

In terms of data plate material, it is recommended that manufacturers select one that is built tough enough to withstand abrasion, UV exposure, and harsh weather elements. Metalphoto® photosensitive anodized aluminum is the top choice for identification and asset tracking purposes as its heavy-duty enough to display the information, even with frequent exposure.

Third-Party Safety Verification Programs

Ostensibly, the aforementioned guidelines might seem complex to new trailer manufacturers, considering manufacturers must abide by all regulations with a number of different agencies before the trailer even hits the road. Because of this, some trailer manufacturers decide to consult third-party firms to ensure that they are in full compliance throughout the building, sales, and maintenance processes.

One such firm is the National Association of Trailer Manufacturers (NATM) Compliance Verification Program. NATM requires all of its member manufacturers undergo the program. In it, the members are provided a compendium entitled, Guidelines for Minimum Recommended Manufacturing Practices (Guidelines), a guide which is meant to provide easy access of the current federal regulations. In addition to this, members are also awarded technical support, as well as a biennial consultation that focuses, specifically, on the compliance of FMCSA safety standards.

According to NATM, each consultation comes with an up-to-date checklist featuring important trailer safety considerations, such as:

• VIN labels
• NHTSA registration
• Record keeping guidelines
• Safety cable/chain standards
• Breakaway system standards
• Lighting safety
• Conspicuity tape standards
• Personalized recommendations for easy compliance

Conspicuity Requirements for Trailers

In the FMCSA&#;s Conspicuity Requirements for Commercial Vehicles, the agency provides a long list of lighting safety guidelines for trailers manufactured on or after December 1, . This forces all trailer manufacturers to install red and white retroreflective sheeting and/or reflex reflectors to specific areas of the vehicle.

When purchasing this specialized sheeting, the trailer-maker must also ensure that it is manufactured by a firm that is FMVSS-certified (Federal Motor Vehicle Safety Standard-certified). This will be made evident by an &#;FMVSS No. 108&#; marked on the product. Any and all conspicuity materials that are in compliance with FMCSA will be labeled as such:

• DOT-C (Rectangular reflectors)
• DOT-C2 (50mm wide reflective material)
• DOT-C3 (75mm wide reflective material)
• DOT-C4 (100mm wide reflective material)

Trailers manufactured after December 1, must adhere to a strict range of conspicuity treatments on the sides of the trailer, the lower rear area of the trailer, and the upper rear area of the trailer. All rules concerning specific placement are stipulated in the Conspicuity Requirements for Commercial Vehicles guide. Manufacturers must carefully consult this information and conform to it depending upon the unique dimensions of the trailer.

Additionally, if the trailer exceeds 10,000 lbs., it may need further conspicuity treatments in the form of clearance lights, identification lights, brake lights, marker lights, and even license plate lights depending upon the state in which the trailer is operating. Manufacturers must reference all corresponding conspicuity treatment information as part of its safety compliance process.

Rules for Truck and Trailer Pairings

In FMCSA&#;s Section § 393.201: Frames, trailer manufacturers must pay close attention to §393.43 Breakaway and emergency braking. This section provides important information on the required braking systems for trucks towing trailers equipped with brakes:

(a) Towing vehicle protection system. Every motor vehicle, if used to tow a trailer equipped with brakes, shall be equipped with a means for providing that in the case of a breakaway of the trailer, the service brakes on the towing vehicle will be capable of stopping the towing vehicle. For air braked towing units, the tractor protection valve or similar device shall operate automatically when the air pressure on the towing vehicle is between 138 kPa and 310 kPa (20 psi and 45 psi).

(b) Emergency brake requirements, air brakes. Every truck or truck tractor equipped with air brakes, when used for towing other vehicles equipped with air brakes, shall be equipped with two means of activating the emergency features of the trailer brakes. One of these means shall operate automatically in the event of reduction of the towing vehicle air supply to a fixed pressure which shall not be lower than 20 pounds per square inch nor higher than 45 pounds per square inch. The other means shall be a manually controlled device readily operable by a person seated in the driving seat. Its emergency position or method of operation shall be clearly indicated. In no instance may the manual means be so arranged as to permit its use to prevent operation of the automatic means. The automatic and manual means required by this section may be, but are not required to be, separate.

(c) Emergency brake requirements, vacuum brakes. Every truck tractor and truck when used for towing other vehicles equipped with vacuum brakes, shall have, in addition to the single control required by §393.49 to operate all brakes of the combination, a second manual control device which can be used to operate the brakes on the towed vehicles in emergencies. Such second control shall be independent of brake air, hydraulic, and other pressure, and independent of other controls, unless the braking system be so arranged that failure of the pressure on which the second control depends will cause the towed vehicle brakes to be applied automatically. The second control is not required by this rule to provide modulated or graduated braking.

(d) Breakaway braking requirements for trailers. Every trailer required to be equipped with brakes shall have brakes which apply automatically and immediately upon breakaway from the towing vehicle. With the exception of trailers having three or more axles, all brakes with which the trailer is required to be equipped must be applied upon breakaway from the towing vehicle. The brakes must remain in the applied position for at least 15 minutes.

(e) Emergency valves. Air brake systems installed on towed vehicles shall be so designed, by the use of &#;no-bleed-back&#; relay emergency valves or equivalent devices, that the supply reservoir used to provide air for brakes shall be safeguarded against backflow of air to the towing vehicle upon reduction of the towing vehicle air pressure.

(f) Exception. The requirements of paragraphs (b), (c) and (d) of this section shall not be applicable to commercial motor vehicles being transported in driveaway-towaway operations.

Though the above rules might not always be an applicable compliance issue for all truck trailer manufacturers, they illustrate the responsibility of the trailer-maker; all should make inquiries about their customers&#; vehicles so that dangerous pairings are not established.

Additional Resources on DOT Regulations for Truck Trailer Manufacturers

For more information on how to stay on the right side of trailer manufacturing and safety compliance laws, visit the following resources:

Selecting an equipment trailer might seem straightforward, but there's actually a lot to consider. Knowing what you need from a trailer is crucial when starting the selection process.

When choosing a trailer for hauling equipment, rental businesses need to take into account their customer base and size as well as the type and weight of their equipment. For example, a customer base of professional contractors who drive ¾- and 1-ton pickups and who might rent a mini excavator with attachments would be best served with a tilt-bed trailer with a stationary deck, according to Chris Pokornowski, sales coordinator at Towmaster. This type of trailer would have a gross vehicle weight rating (GVWR) of around 16,000 pounds, hauling about 8,000 to 10,000 pounds of load with electric brakes. The stationary deck could carry the attachments and the main tilt deck would carry the mini excavator.

On the other hand, Pokornowski says, a customer with a less heavy-duty towing vehicle renting a small skid-steer loader with a pallet fork attachment might be best served with a ramp-style trailer with pallet fork holders. This trailer would have a GVWR of 9,990 pounds, hauling about 5,000 to 7,000 pounds, and possibly equipped with hydraulic surge brakes or remote controlled electric brakes.

Obviously it's important to know what you want from a trailer. In order to get the most value from your investment, it's best to look beyond the rated payload capacity to other factors that can impact an equipment trailer's performance.

According to Bill Dovey, product champion with JLG Industries Inc., versatility, capacity, quality and brake configurations should be at the top of your list when selecting a trailer. "You have to rent units that will meet the requirements of a variety of customers," he explains. "You have to consider the width and length of the equipment as well has how it will be loaded and unloaded at the site."

So, where should you start?

Capacity concerns

There are many factors to consider when selecting a trailer. Options can include the type of ramp, type of flooring, type of tongue jack, siderails and tailgates, tie-downs, winches, spare tires and more. Even the type of coupler will need to be decided: a 2-inch coupler is the most common, but one might need a 2 5/16-inch coupler because of the trailer load capacity.

Speaking of capacity, what will be carried on the trailer needs to be the first item considered. Be careful not to underestimate the weight of what you will be carrying. Take into account full gas tanks, accessories and added attachments that might be carried.

Size is also important. Be careful the trailer is not too small - dimension-wise it should carry your load. Take into account the configuration of the equipment or load to be carried. Because of the weight distribution of the equipment, which can vary significantly when attachments are added, you'll need a trailer large enough so that equipment can be positioned to give proper tongue loads. Insufficient tongue weight will cause dangerous swaying and unsafe towing.

Quality questions

Beyond the basic features, suppliers suggest comparing construction quality and design factors. Structural integrity in design, such as one-piece frames to limit the number of butt or joint welds, is important.

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Other quality factors include the maximum design width between the fenders, within the constraints of 102-inch overall legal limit width, which is important to allow a broad range of equipment to be hauled. Designs that allow the movement of the rear loading ramps to move in and out to accommodate varying wheel treads as well as spring-assisted lift devices on the ramps for the operator are helpful. Axle placement on the trailer is crucial to ensure proper and safe towing.

Because not all trailers are built alike, component specs should be checked to ensure the trailer is actually designed to handle the rigors of heavy hauling.

Component ratings can vary widely for models even within the same capacity class. For example, the axle wall thickness on a 25,000-pound axle might be .416, .625 or .750, depending on the manufacturer. Vertical travel on hydraulic removable goosenecks can range from 16 inches to as high as 45 inches. And flooring thickness can vary substantially. Nominal thicknesses can mean various things, so find out what the actual deck thickness of the flooring is and what kind of flooring is being used.

Cost-effective brakes

There are a variety of braking systems available on today's trailers: air, electric, electric/hydraulic, hydraulic/surge. The type of braking system available typically depends on the size (GVWR) of the trailer.

Air brakes are used on the larger trailers, usually those over 40,000-pound GVWR. This size has large brake shoes and various size air chambers to apply the brakes, giving the vehicle the stopping power needed.

Trailers between 26,000 and 40,000 pounds GVWR might have either electric or air brakes depending on the axles available. This is usually determined by the towing vehicle the customer is planning on using.

Electric brakes are the most common from 3,000- to 26,000-pound GVWR. They can be used with a variety of towing vehicles via the use of an electric brake controller that is independent of the tow vehicle brakes.

With electric/hydraulic brakes, you'll need an electric controller in the tow vehicle, which controls an electric pump on the trailer, which in turn applies hydraulic pressure to the brake shoes.

Hydraulic surge brakes become operative when the towing vehicle decelerates, causing the trailer to apply a pushing force against the hitch. The pushing force actuates the hydraulic cylinder in the hitch, transferring high-pressure brake fluid to the trailer wheel cylinders.

Hydraulic surge brakes have been the industry's standard braking system on trailers up to 12,000-pound GVWR for many years and are desired by many rental businesses because of their ease of hook-up (no wiring, no separate actuators, no delays). With electric brakes, a brake kit or electrical hook-up is necessary.

Maintenance factors

A trailer must be serviced like any other piece of equipment, therefore maintenance features need to be considered when purchasing.

Maintenance-related features include items such as rubber-ride axles, which eliminate the need to maintain spring shackle bushings on a regular basis, and sealed modular wiring systems with internal ground wires and integral circuit breaker protection, which protect the trailer as well as the tow vehicle.

Additionally, a trailer design that lends itself to quick replacement of hitch couplers, jacks and "hydraulic brake controllers" - if allowed by individual state law - makes replacing these highly abused items a simple maintenance repair issue for rental businesses.

The supplier connection

A final consideration during the selection phase is the supplier itself. A knowledgeable trailer manufacturer that can match the trailer to your equipment and understands your industry is a must.

Purchasing from a manufacturer that provides experience along with knowledge of the industry, as well as consistency of parts and components goes a long way toward your benefit. More importantly, if you need an insurance liability policy, they'll be in the wings.

When buying trailers for your rental business, the first thing you should ask of a manufacturer is, "What is your liability coverage? Have you asked the DOT inspector into your plant? Does one of your management team attend the meetings provided by various truck and trailer organizations to stay abreast of changing laws?" Don't be afraid to ask some questions.

Suppliers should be your source of information for the trailer industry; after all, they are the experts. Ideally, the salesperson can make the customer feel comfortable enough to ask the questions needed to allow a better understanding of his/her needs, Pokornowski says.

Don Huber with Trail-Eze agrees. "The best thing the customer can do is ask questions."

Maximizing the payload

To maximize hauling efficiency, you might want to move two or more machines in a single payload. There are, however, some added considerations involved.

When sizing a trailer to haul multiple machines, first determine the dimensions of the longest machine the trailer will carry. You need to have adequate deck length and dimensions to ensure proper weight distribution. If in doubt, ask your trailer supplier to perform a weight distribution analysis to determine if specific machines can be safely transported in a single load.

The legal maximum gross weight can also be a limiting factor. A permit is required if the truck, trailer and payload exceeds 80,000 pounds. Technology that is helping in this area is known as an air scale system. Air scales are becoming more popular because operators will know where they are weight wise before they leave the rental yard.

A final factor to consider when hauling multiple pieces is how they are positioned on the trailer so that the tongue weight remains proper.

Off loading one piece of equipment from a trailer without repositioning the others can put undo strain on either the trailer or the tow vehicle. Having too much tongue weight might bottom out the springs on the tow vehicle, making it ride and drive extremely rough. In extreme cases, too much tongue weight might make the tow vehicle hard to control, because the weight might be lifting the front end of the tow vehicle off the ground. In the reverse, too much weight remaining behind the axles might cause the trailer to sway while towing. The swaying might not start until after the driver reaches posted speed limits on the highway, pushing him into a situation he can't safely recover from.

The best way for rental businesses to avoid overloading their trailers is to know the weight of what is being loaded. Every trailer must have a vehicle identification tag that will show the carrying capacity of the trailer. Employees must know the weight of any item they are loading. This can be found in the equipment owners manual or direct from the manufacturer. Be sure to take into account the total weight with fuel and attachments. Be cautious of renting a trailer by itself. Customers must know the same information and load the equipment on the trailer within the safe limits.

Many times trailers are taken for granted and treated as a secondary item. This shouldn't be the case. Be sure to buy a quality trailer of the design that best suits your applications, and your trailers will serve you well over many miles of roads.

Don't be misled by trailer ratings

There are different ways trailer manufacturers will "size" their trailers. But it's up to you to ensure the chosen trailer will safely handle your equipment. For example, a trailer manufacturer might give you a gross vehicle weight rating (GVWR) of 100,000 pounds (50 tons). But if you subtract the trailer weight - which on average for a 50-ton unit is going to be anywhere from 18,000 to 20,000 pounds - then you have a 40-ton carrying capacity. "You want to find out what the load rating is and if it is concentrated or if it is a distributed load," says Huber at Trail-Eze. "That is one of the biggest tricks in the industry. That is a big issue and it will make a big difference in your dollar figure." So the key words you need to use are hauling capacity.

You also need to know the weight capacity in a concentrated area. This is how much weight is going to be carried over a given area. This is especially important with certain types of equipment. For example, a forklift has a high concentrated load area. The entire weight of the machine is transferred to the trailer deck through the small contact areas of the wheels. With an excavator or a dozer, the amount of track in contact with the trailer helps determine the concentrated load.

Again, you have to be very careful when looking at the concentrated load rating. Some manufacturers might say concentrated at 10 feet, but if you read the fine print, it says the center of the deck only. If you're hauling an excavator, for example, your weight is going to be in the front, but if you're hauling a scraper, your weight will be in the rear and on the front.

Types of trailers

There are several types and classes of trailers typically used by the rental industry.

Lowbed trailers, sometimes referred to as "goosenecks," offer capacities from 25 to 55 tons or more. These trailers are towed by using a special coupler attachment inside the bed of a pick-up truck. Models feature a fixed gooseneck with ramps or a hydraulic "tail" for rear loading applications, or a hydraulic detachable goosneck for front loading. Costs vary depending on the size and configuration. A 25-ton fixed gooseneck might be priced at $20,000, while a 50-ton hydraulic detachable gooseneck can range from $40,000 to $50,000.

Tow-behinds can be pulled by a tow vehicle using a ball or pintle hitch coupler. These can be broken down ito five basic types:

Box trailers can be fully enclosed or have sides and a tailgate. They are generally used for hauling cargo.

Flatbeds are normally used to carry various types of equipment, which is loaded using ramps.

Tiltbeds have a flatbed but instead of using loading ramps, the bed tilts to the ground to allow equipment to be pulled or driven onto the trailer.

Dump trailers feature an open box trailer that is used primarily for bulk material such as sand and gravel. These units tilt hydraulically to allow easy loading.

Drop-deck trailers allow the complete trailer deck to remain level as it lowers flat to the ground for easy loading of equipment.

It's about making it last

Equipment takes a beating in a rental inventory. That's why it's particularly important to choose equipment that's built to last. But what are the earmarks of high-quality and durability?

"There are companies out there who will offer a low-dollar trailer, but will it last?" asks Chris Pokornowski, sales coordinator at Towmaster Inc. "A rental fleet manager needs a product that will last many years with minimal maintenance. In most cases, the low dollar trailer has a nice price tag at first, but in the long run, it tends to be a maintenance nightmare. What is the easiest way to find out if you are making the correct decision? Ask around - it's that simple."

Pokornowski adds, "The rental industry can't afford down time, so when making your decision, ask around to see what trailes will last. You will find your answer in a hurry."

Look for features that denote durability. These include the structure and suspension. To assess the structure, Pokornowski suggests crawling under a trailer to see what it's made of. "Take a look and see if there is plenty of steel and good cross member spacing. You will see right away if the trailer manufacturer has put time into producing the trailer or it appears that the trailer has been rushed through production."

With regard to the suspension, many companies use a spring suspension. "A standard spring suspension usually gives you a two-year warranty policy," Pokornowski says. "In addition, there are many wear areas that require frequent maintenance. Towmaster's Drop Deck Tilt trailers are produced with a Rubber-Ride Torflex suspension. This suspension has minimal wear areas and it comes with a standard five-year warranty policy."

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