Compliance Labeling of Reflective Material for Trailer Conspicuity

Forms and Documents

Document	Type	Status	Availability
PRA_SS_PartA_RetroreflectiveTape_reinststatement_030221_V4.docx	Supporting Statement A	Uploaded 2021-08-19	Repair queued

IC Document Collections

IC ID	Collection	Type	Status	Form
26254	Compliance Labeling of Reflective Material for Trailer Conspicuity		Modified

ICR Details

OMB Control No: 2127-0569	ICR Reference No: 202106-2127-001
Status: Received in OIRA	Previous ICR Reference No: 201507-2127-001
Agency/Subagency: DOT/NHTSA	Agency Tracking No:
Title: Compliance Labeling of Reflective Material for Trailer Conspicuity
Type of Information Collection: Reinstatement with change of a previously approved collection	Common Form ICR:  No
Type of Review Request: Regular	Date Submitted to OIRA: 10/19/2021

	Requested	Previously Approved
Expiration Date	36 Months From Approved
Responses	66,333,333	0
Time Burden (Hours)	1	0
Cost Burden (Dollars)	4,000	0

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Abstract: This information collection is mandatory under 49 CFR 571.108 for manufacturers of retroreflective sheeting. This collection involves disclosure by requiring manufacturers of retroreflective sheeting to permanently mark the letters “DOT-C2”, DOT-C3”, or “DOT-C4” at least 3mm high at regular intervals on retroreflective sheeting material having adequate performance for certifications and identification purposes. This is an as-needed collection that manufacturers comply with labeling retroreflective sheeting as being compliant with NHTSA’s performance requirements. Manufacturers of trailers and truck tractors that are required to apply retroreflective sheeting to their vehicles use the information on the label as an assurance that the sheeting complies with the standard, and the Federal Motor Carrier Safety Administration (FMCSA) uses the information to ensure compliance with in-service requirements for regulated vehicle operators. Federal Motor Vehicle Safety Standard (FMVSS) No. 108, “Lamps, reflective devices, and associated equipment” specifies requirements for vehicle lighting for the purposes of reducing crashes and the injuries and deaths resulting from crashes by providing adequate roadway illumination, improved vehicle conspicuity, and appropriate information transmission through signal lamps, in both day, night, and other conditions of reduced visibility. To provide effective trailer conspicuity, FMVSS No. 108 requires the permanent marking of the letters “DOT-C2”, DOT-C3”, or “DOT-C4” at least 3 mm high at regular intervals on retroreflective sheeting material having adequate performance for certifications and identification purposes. The manufacturers of new truck tractors and trailers are required to certify that their products are equipped with retroreflective material complying with the requirements of the standard. FMCSA enforces this and other standards through roadside inspections of trucks. There is no practical field test for the performance requirements, and labeling is the only objective way of distinguishing trailer conspicuity grade material from lower performance material. Without labeling, FMCSA would not be able to enforce the performance requirements of the standard and the compliance testing of new tractors and trailers would be complicated. Labeling is also important to small trailer manufacturers, which might not have the capability to test the tape and therefore could rely on the certification provided by the retroreflective sheeting manufacturer to help them certify compliance. Because wider stripes or material of lower brightness also can provide the minimum safety performance, the marking system serves the additional role of identifying the minimum stripe width required for retroreflective conspicuity of the particular material. Since the last notice, the estimated number of respondents, burden hours and costs were revised. The number of respondents was revised from six respondents to three, based on the number of identified manufacturers of retroreflective tape. The total burden hours were revised from one hour to three hours based on the number of respondents and required reporting tasks. The labor cost associated with the burden hours was also revised to $102.57. The total annual cost burden was revised from $1,000 to $4,000 based on the number of trailers and truck tractors registered in the United States and updated

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Authorizing Statute(s): US Code: 49 USC 30111, 30112, 30117 Name of Law: National Traffic and Motor Vehicle Safety Act of 1966.
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	85 FR 40735	07/07/2020
30-day Notice:	Federal Register Citation:	Citation Date:
	86 FR 38528	07/21/2021
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Compliance Labeling of Reflective Material for Trailer Conspicuity

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ICR Summary of Burden

	Total Request	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	66,333,333	0	0	56,333,333	0	10,000,000
Annual Time Burden (Hours)	1	0	0	0	0	1
Annual Cost Burden (Dollars)	4,000	0	0	3,000	0	1,000

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement:

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Annual Cost to Federal Government: $0

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? No

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 10/19/2021

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