The Federal Motor Carrier Safety Administration revised the guidelines for the yearly inspection, particularly those about rear impact guards, as of December 9, 2021. Rear impact guards are now included among the equipment that must be inspected yearly, according to the new ICC bumper requirements. The rules also outline additional labeling requirements and the exclusion of some cars from these standards.
Rear impact guards were to be placed on commercial vehicles in line with DOT bumper requirements that date back to 1952, as stated in a notice of proposed rulemaking in December 2020. Rear impact guards, however, were “not included on the Appendix G list of components that must be examined during the yearly CMV inspection. This indicates that a car might have previously passed an annual inspection even if the rear impact protection was missing or broken. This is no longer due to the new FMCSA ICC bumper requirements.
Requirements for rear impact guard inspection
So what has been changed in the specifications? The following would not pass inspection for trailers or semitrailers with a GVWR of 4,536 kg (10,001 lbs) or more that were created on or after January 26, 1998 (see exclusions in 393.86(a)(1)), as may be found in Appendix A to Part 396 – Minimum Periodic Inspection Standards:
- Missing guard.
- The guard is not properly fastened to the trailer due to missing or damaged fasteners, cracked welds, and other problems that make the guard’s attachment difficult or impossible.
- The horizontal guard part does not reach within 100 mm (4 inches) of either side extremity of the vehicle or extend beyond either.
- More than 560 mm (22 inches) above the ground is the horizontal guard element.
- More than 305 mm (12 inches) ahead of the vehicle’s rear extremities is where the horizontal guard member is located.
- Guard horizontal element is not at least 100 mm (4 inches) tall over its whole width in its cross-section.
Commercial motor vehicles produced after December 31, 1952—aside from trailers and semitrailers produced on or after January 26, 1998—would not pass inspection if any of the following conditions existed:
- Missing guard.
- Bolts, welding, or similar methods are not used to firmly attach the guard to the trailer.
- The horizontal guard element is elevated above the ground by more than 762 mm (30 inches).
- Guard horizontal member does not go as close as 457 mm (18 inches) to the vehicle’s side extremities.
- More than 610 mm (24 inches) ahead of the vehicle’s rear extremities is where the horizontal guard member is located.
Exclusions and Requirements for Rear Impact Guard Labeling
The DOT also implemented labeling and vehicle exclusion rules for trailer bumpers along with the inspection standards. The FMCSA’s proposed regulation changed the labeling requirements to:
- The FMVSS requires that the certification label for the rear impact guard be attached to the forward-facing surface of the horizontal component of the guard but allows it to be attached to the rear-facing surface as long as it does not cover any of the retroreflective sheeting (69 FR 67660)
The proposed regulation adds that RCC horizontal discharge semitrailers need to be exempt from this requirement. According to the exclusion’s justification, “installation of rear impact protection on RCC horizontal discharge trailers would conflict with the trailers’ intended function and was thus unfeasible owing to the particular design and purpose of such vehicles.”
As was previously stated, these ICC bumper requirements came into force on December 9, 2021. Thus, keep these updated inspection and labeling standards in mind while conducting your further inspections.
