Question 1: If a high-profile COE truck or truck-tractor is equipped with a seat on the passenger’s side, must steps and handholds be provided for any person entering or exiting on that side of the vehicle?
Guidance: Yes, all high-profile COE trucks and truck tractors shall be equipped on each side of the vehicle where a seat is located, with a sufficient number of steps and handholds to comply with the requirements of §399.207(a).
Question 2: What does the foot accommodation rule mean when it states: "The step need not retain the disc at rest"?
Guidance: The note under §399.207(b)(4) states that the disc referred to is a measuring device. The step or rung does not have to be configured in such a manner as to keep the measuring disc from falling off the step or rung.
Question 3: In §399.207(b)(4), Illustration III, what does the unshaded area within the disc suggest?
Guidance: The unshaded area illustrates the height of the open area required for a driver to insert his or her foot.
Question 4: May the step be a rung? If so, what minimum diameter must the rung be?
Guidance: Yes, the step may be a rung. There is no minimum requirement for the diameter of a step rung. However, it must meet the performance requirements in §399.207(b)(5).