NTTC seeks pulsating brake lamp exemption renewal

National Tank Truck Carriers recently requested an extension of its exemption that authorizes fleets to install brake-activated pulsating lamps on the back of tank trailers. The Federal Motor Carrier Safety Administration published NTTC’s renewal petition in the Federal Register on Aug. 25.

“Safety is the cornerstone of our industry, and this exemption is a tool with proven results to protect tank truck drivers, their commodities, and the motoring public at large,” Will Lusk, NTTC director of education and government relations, said in a news release. “We look forward to continued engagement with FMCSA as we advocate for practical safety solutions.”

The public now has until Sept. 24 to comment on NTTC’s request for a five-year renewal of its exemption, which covers red or amber brake-activated pulsating lamps positioned in the upper center position or in an upper dual outboard position on the rear of tank trailers, in addition to the steady-burning brake lamps required by the Federal Motor Carrier Safety Regulations (FMCSRs).

“NTTC encourages industry stakeholders, particularly carriers and OEMs that install or utilize these lights, to review the notice and provide supporting comment,” the association said. “Comments that share the number of trailers operated with these lights, or any statistical analysis demonstrating the reduction of rear-end collisions because of these lights, would be welcomed.”

Proven results

FMCSA on Oct. 8, 2020, published a notice of final disposition granting NTTC’s original application for a five-year exemption to allow motor carriers operating tankers to install rear pulsating lamps on the rear of cargo tanks, in addition to the steady-burning brake lamps required by the FMCSRs (85 FR 63643). FMCSA determined that granting the exemption was likely to achieve a level of safety that was equivalent to or greater than that provided under existing regulations, the agency reported.

In its renewal application, NTTC reiterates its position that the use of these lamps enhances rear visibility and contributes to overall safety by reducing the likelihood of rear-end collisions. Since FMCSA granted the original exemption, NTTC and its member carriers have continued to implement the technology and track its impact. Notably, Groendyke Transport, an NTTC member, expanded installation of the pulsating brake lamps across its fleet from 38% in 2018 to 93% by 2023, FMCSA shared. During this time, Groendyke reported a significant reduction in rear-end accidents when vehicles were slowing or stopped—from 19 collisions in 2018 to only four in 2023—representing a 79% decrease. Groendyke attributes this safety improvement to the enhanced visibility provided by the auxiliary lamps.

See also: FMCSA grants Groendyke exemption

NTTC cites additional support for the exemption based on the experience of Trimac Transportation, another NTTC member and one of the largest tank truck carriers in North America by miles traveled. As of 2024, Trimac reported equipping 863 of its cargo tanks with pulsating brake lamps. NTTC states that since implementing this technology, Trimac has experienced roughly a 20% reduction in rear-end collisions. NTTC maintains these experiences suggest Groendyke and Trimac are not outliers but instead reflect broader industry-wide safety benefits associated with the use of this technology.

To further assess industry adoption, NTTC conducted an informal 2024 questionnaire and found that at least 34 motor carriers are currently using the exemption, representing a diverse cross-section of geographic regions, cargo types, and operational scales. These carriers reported bulk commodity transport ranging from 1.2 million to 510 million miles driven in 2024.

NTTC asserts failure to renew the exemption would impose “substantial financial and operational burdens” on carriers who have adopted the technology in good faith. Trailers would need to be pulled from service to remove the lamps, labor costs would be incurred, and the lamps themselves—many still operational—would become unusable. More importantly, NTTC believes that denying the renewal would undermine the safety gains achieved in recent years, increasing the risk of rear-end collisions for both CMV drivers and the motoring public.

Public support

NTTC’s petition already had received four comments as of Aug. 27—all from fleets in favor of granting the renewal request.

“Our company has operated with this exemption and found it to be a clear enhancement to roadway safety,” wrote Gemini Motor Transport, the primary fuel hauler for Love’s Travel Stops, and a three-time champion in NTTC’s North American safety contest. “The addition of pulsating lamps greatly improves rear-end visibility, particularly during low-visibility conditions or in heavy traffic.

“We have documented a decrease in close-following incidents and received positive feedback from both drivers and the motoring public, noting the improved recognition of braking activity, especially when stopped at railroad crossings.”

See also: Gemini wins first Intellistop exemption

Oakley Transport and Island Transportation echoed Gemini’s assessment in their comments.

“We use and have used the pulsating brake lights on our fleet for several years now and we believe it has helped us prevent rear-end collisions,” Oakley stated.

“We hope that continued use of this product is approved.”