Introduction – The Beginning of Modern Day Reflective Conspicuity Efforts
The Federal Motor Vehicle Safety Standards (FMVSS) were established to ensure safety in the design, construction, performance, and durability of motor vehicles. FMVSS No. 108, specifically addressing “Lamps, Reflective Devices, and Associated Equipment,” plays a crucial role in enhancing vehicle visibility and preventing accidents. One of the most impactful components of FMVSS No. 108 is the DOT C2 conspicuity tape requirement, which has significantly reduced nighttime and low-visibility accidents involving large trucks and trailers. This article delves into the history and development of FMVSS 108 and the DOT C2 conspicuity requirements.
Early Developments – Legislation to Set Safety Standards for Motor Vehicles
The roots of FMVSS No. 108 trace back to the National Traffic and Motor Vehicle Safety Act of 1966, which authorized the federal government to establish safety standards for motor vehicles. FMVSS No. 108 became effective on January 1, 1968, setting forth requirements for lighting and reflective devices on vehicles to improve visibility and safety. The initial standard addressed various aspects of vehicle lighting, including headlamps, tail lamps, and side markers.
Research and Proposal Stage (1980s – 1990)
In the early 1980s, the National Highway Traffic Safety Administration (NHTSA) began researching ways to reduce accidents involving large trucks and trailers, particularly those occurring at night or in low-visibility conditions. Studies indicated that enhancing the visibility of these vehicles could significantly reduce such accidents. Pilot programs and field tests conducted during this period assessed the effectiveness of reflective materials in improving vehicle conspicuity. One study that was instrumental in proving that reflective conspicuity could reduce accidents and save lives was the 1983 Vector Study. This study analyzed 2000 trucks, with one half unmarked, and one half marked with reflective tape. The study showed a significant decrease in collisions for the marked group of trucks.
On October 16, 1990, the NHTSA issued a Notice of Proposed Rulemaking (NPRM) to amend FMVSS No. 108 to require reflective tape on the sides and rear of large trailers and the rear of truck tractors. This proposal was based on extensive research and positive results from initial testing.
Final Rule and Initial Implementation (1992 – 1993)

After a period of public comment and further analysis, the NHTSA published the final rule on December 10, 1992. The rule mandated conspicuity treatments on the sides and rear of trailers and the rear of truck tractors, specifying that new trailers manufactured on or after December 1, 1993, must be equipped with DOT C2 reflective tape in a red white pattern. The tape was required to be a minimum of 2 inches wide, meet retro reflectivity standards, and bear the DOT C2 mark showing that it is a certified tape.
The final rule detailed the requirements for the tape, including its reflectivity, durability, and placement on the vehicle. The tape had to be red and white and applied in a specific pattern to ensure maximum visibility from various angles and distances.
Extension to Truck Tractors (2001)
Recognizing the benefits of enhanced conspicuity, the NHTSA extended the requirement to include truck tractors. As of June 1, 2001, truck tractors manufactured on or after this date were required to be equipped with conspicuity tape on their rears. This extension aimed to further reduce accidents by making the rear of truck tractors more visible to following drivers.
Technological Advancements and Ongoing Updates (2000s – Present)
The early 2000s saw significant advancements in lighting technologies, prompting the NHTSA to update FMVSS No. 108 to reflect these changes. High-intensity discharge (HID) headlamps, light-emitting diode (LED) lighting, and adaptive lighting systems were integrated into the standard, improving overall vehicle visibility and safety.
In 2012, the NHTSA undertook a major revision of FMVSS No. 108 to simplify and modernize the standard. These revisions aimed to make the standard easier to understand and enforce while accommodating new technologies and international harmonization efforts.
Impact and Compliance
The implementation of DOT C2 conspicuity tape has had a profound impact on road safety. Studies and real-world data have shown a significant reduction in nighttime and low-visibility accidents involving large commercial vehicles equipped with reflective tape. Compliance with these requirements is enforced by both the NHTSA and the Federal Motor Carrier Safety Administration (FMCSA), ensuring that commercial vehicles on the road adhere to the necessary safety standards.
Conclusion
The history of FMVSS 108 and the DOT C2 conspicuity requirements reflects a concerted effort to enhance vehicle safety through improved visibility. From initial research and proposals in the 1980s to the implementation of conspicuity tape requirements in the 1990s and early 2000s, these regulations have evolved to address emerging technologies and safety needs. The ongoing updates to FMVSS No. 108 ensure that it remains relevant and effective in reducing accidents and saving lives on the road.
