A few years ago when Congress updated the federal transportation regulations in a bill called MAP-21 (Moving Ahead for Progress in the 21st Century), there was a requirement embedded in the bill that requires the manufacturers of implements of husbandry to put reflective tape and lights on all trailers for equipment manufactured after June 22, 2017.  The lighting and markings must meet the American Society of Agricultural & Biological Engineers Standard S279.14.  

 

These new requirements apply to ammonia nurse tank trailers manufactured and sold after June 22, 2017.  The additional cost per trailer can run .75 cents per foot for the reflective tape and $50 for the light kit.  This requirement is NOT retroactive, it only applies to the equipment manufactured after June 22, 2017. 

 

IFCA believes this requirement is problematic for ammonia nurse tank trailers, since the in-field application conditions they are exposed to creates problems in terms of the light systems working consistently without a lot of maintenance and care.  At this point we are not sure what can be done to address this since the manufacturers are already implementing the requirements.  This is also a federal law, making it is difficult to address on a state-by-state basis especially from the perspective of the manufacturers.  IFCA has reached out to IDOT to determine what type of enforcement policy we can agree upon especially when these trailers are used in day-light only hours, which is what the industry promotes.  When operated in low light conditions and at night, Illinois rules already require an amber flashing light be mounted on the nurse tanks.  

 

To be fully transparent with you, when MAP-21 was being debated it appears that our industry (at both the national and state level) overlooked the inclusion of this requirement in the law and missed the opportunity to object at that time.  At least one good thing that came from MAP-21 was the broadening of the Hours of Service exemption and expanding that exemption from the driving time restrictions from 100 air miles to 150 air miles for ag inputs from all distribution points.  So with the good news now comes so bad news.  IFCA welcomes your input on this issue, please share any thoughts with John Rebholz at (309) 827-2774 or email John at john@ifca.com.