Clarification on the rear impact guard as to how and what is to be so that we are legal on our bumpers.

The need to clarify the mfg. sticker that is paper and doesn't stay on once on the road as to why it is required and if it is to be required how do we get a replacement from the trailer manufactuer as right now they do not issue replacements.

If this is to be required have a mandate that it be mounted in a standard spot on the bumper and be required to be of a material secured so that it stays readable as well as on the bumper
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During the discussion in committee, there were concerns due to the lack of clarity on rear impact guards and what constitutes a legal manufacturer certification label.

If this is to be required by FMCSA, the committee felt there should be standardization as to where the label be mounted to keep it legible. FMCSA has yet to respond to CVSA’s petition to remove the requirement for a certification label. This requirement would set the same standards for the U.S., as Mexico and Canada currently do not require certification labels.

If FMCSA denies this petition, then the guidance to law enforcement not to cite when no manufacturing label is not present will need to be removed from Operational Policy 15. This creates a difficult situation for carriers as it will be a defect cited on roadside inspections that would not be able to be repaired.

Committee stressed to carriers in the room to reach out to FMCSA to support the petition to remove the requirement from regulation. This issue will be closed and the issue related to the CVSA Petition for the removal of the requirement from the regulations remains open pending the response from FMCSA.