Mud flap reflectors

Good afternoon,

I need clarity on FMCSA 393.11. Concerning reflectors on mud flaps on the rear of my 2007 Freightliner Columbia tractor. My employer and I are going around about this. I believe that all vehicles manufactured after 7/1/97 are required to have mud flaps with reflectors on them. In the FMCSA handbook, I read it as they are required, they read it as only pole trailers need them. Yet every truck that is new has them on from the factory, including the 30 or so we received in 06.

I am now reading the BASICs for the CSA Maintenance violations, and it says that No reflectors on mud flaps is a 3 point violation to me. Some one is confused here, is it me? Or my Employer, Oregon DOT and Penske Leasing. ( they all say I'm crazy )

Any and all help and more documentation than what is in the FMCSA Handbook would greatly help. They say the book doesn't say anything about mud flap reflectors.

I have tried to add attachments, hope they worked!

 

Received a PDF file from CVSA concerning this. Sent it to my safety director, who told me to "get a hobby". And the other information I have collected. He read it and now we are getting the tractors repaired. Half our fleet was missing one or both. I'm not trying to raise a stink, I just don't want a stupid reflector missing on my driverside for a reason to get pulled over.

(see attached PDF file)

Thanks for the inputs.