Final-stage manufacturer/alterer liability in installing pulsating brake lamps under FMVSS 108

In October 2020, Federal Motor Carrier Safety Administration (FMCSA) granted a petition from National Tank Truck Carriers for a limited five-year exemption to allow motor carriers to install a red or amber brake-activated pulsating lamp on the rear of trailers. In December 2020, FMCSA granted a similar petition from Grote Industries that included van trailers and van body trucks. These exemptions have created understandable confusion for fleets/end users and builders/final-stage manufacturers/alterers.