Interpretation ID: nht80-3.29

DATE: 08/04/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Baker Equipment Engineering Company

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. John Deeter Baker Equipment Engineering Company P.O. Box 25609 Richmond, Virginia 23260

Dear Mr. Deeter:

This is in reply to your letter of June 23, 1980, to Mr. Finkelstein of this agency.

You have enclosed a drawing showing clearance lamps mounted on the widest and highest part of a truck body but in that location their light causes undesirable reflections in the truck's rearview mirrors. You have asked if a relocation to the truck cab would be an acceptable substitution since many of the chassis-cabs you now receive have a combination turn signal/front side marker lamp mounted on the fenders, "which almost blocks the front clearance lamp on the body, and would seem to negate the requirement of this lamp".

We have no objection to relocation of the clearance lamps to the cab on the configuration you have described since the utility body is not higher than the truck cab and the position of the front lamp is, for all practical purposes, as wide as the utility body. This is a location frequently used for clearance lamps and we believe that they would be perceived as such, even though the truck body is slightly wider than the extremities of the cab. Because a potential hazard to the driver would be diminished by this relocation, we believe that this would better meet the needs of motor vehicle safety. Further, in the relocated position, the clearance lamps would not be blocked by the front fender mounted combination lamps.

Sincerely,

Frank Berndt Chief Counsel

June 23, 1980

Mr. Michael M. Finkelstein

U. S. Department of Transportation National Highway Traffic Safety Administration Washington, D. C. 20590

Dear Mr. Finkelstein:

I had previously written you concerning the subject of clearance lights on the front of utility bodies in my letter of October 19, 1980.

Your answer of November 19, 1979 indicated that this request would be considered along with a TBEA petition to revise FMVSS 108.

Have any changes or decisions been rendered? I'm particularly interested since many of the chassis / cabs we are now receiving have a combination turn and front side marker light mounted on the chassis / cab fender (position 4a.), which almost blocks the front clearance lamp on the body, and would seem to negate the requirement for this lamp.

Your comments will be greatly appreciated.

Cordially,

John Deeter Director of Operations

JD/cm Attachment