Rear Impact Guards Added to FMCSA Annual Inspection List
As of December 9, 2021, the Federal Motor Carrier Safety Administration updated the requirements for the annual inspection, specifically related to rear impact guards. These new ICC bumper regulations specify that rear impact guards are now on the list of items that need to be examined annually. Additionally, the regulations specify new labeling requirements as well as the exclusion of certain vehicles from these requirements.
Based on a notice of proposed rulemaking in December 2020, DOT bumper regulations, that were put in place back in 1952, have required that rear impact guards were installed on commercial vehicles. However, rear impact guards were “not included on the list of components in Appendix G that must be inspected during the annual CMV inspection. This means that a vehicle [could previously] pass an annual inspection with a missing or damaged rear impact guard.” Now, with the new FMCSA ICC bumper regulations in place, this is no longer the case.
Rear Impact Guard Inspection Requirements
So what are the new requirements? As seen in the Appendix A to Part 396 – Minimum Periodic Inspection Standards, trailers and semitrailers with a GVWR of 4,536 kg (10,001 lbs.) or more, manufactured on or after January 26, 1998 (see exceptions in § 393.86(a)(1)) would not pass inspection for any of the following:
- Missing guard.
- Guard is not securely attached to trailer, including broken or missing fasteners, any welds or parent metal cracked, or other damage that compromises secure attachment of the guard.
- Guard horizontal member does not extend to within 100 mm (4 inches) of each, or extends beyond either, side extremity of the vehicle.
- Guard horizontal member is more than 560 mm (22 inches) above the ground.
- Guard horizontal member is more than 305 mm (12 inches) forward of the rear extremity of the vehicle.
- Guard horizontal member does not have a cross sectional vertical height of at least 100 mm (4 inches) across its entire width.
Commercial motor vehicles manufactured after December 31, 1952 (except trailers and semitrailers manufactured on or after January 26, 1998) (see exceptions in § 393.86(b)(1) and § 393.86(b)(3)) would not pass inspection for any of the following:
- Missing guard.
- Guard is not securely attached to trailer by bolts, welding, or other comparable means.
- Guard horizontal member is more than 762 mm (30 inches) above the ground.
- Guard horizontal member does not extend to within 457 mm (18 inches) of each side extremity of the vehicle.
- Guard horizontal member is more than 610 mm (24 inches) forward of the rear extremity of the vehicle.
Rear Impact Guard Labeling Requirements and Exclusions
In addition to the inspection requirements, there are additional DOT trailer bumper regulations that went into effect regarding labeling and vehicle exclusions. According to the FMCSA proposed rule, the labeling requirements were amended to:
- Permit the rear impact guard certification label to be mounted on either the forward- or rearward-facing surface of the horizontal member of the guard, provided the label does not interfere with the retroreflective sheeting required by the FMVSS (69 FR 67660)
The proposed rule also states that RCC horizontal discharge semitrailers should be excluded from this requirement. This exclusion is due to the fact that “installation of rear impact guards on RCC horizontal discharge trailers would interfere with the intended function of the trailers and was therefore impracticable due to the unique design and purpose of those vehicles.”
As mentioned above, these ICC bumper regulations went into effect on December 9, 2021, so be sure to keep these new inspection and labeling guidelines in mind during your next inspection.