Interpretation ID: nht90-1.86

TYPE: INTERPRETATION-NHTSA

DATE: 03/27/90

FROM: LARRY F. WORT -- CHIEF BUREAU OF SAFETY PROGRAMS DIVISION OF TRAFFIC SAFETY ILLINOIS

TO: TAYLOR VINSON LEGAL COUNSEL UNITED STATES DEPARTMENT OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 03/27/90 FROM STEPHEN P. WOOD -- NHTSA TO LARRY F. WORT -- ILLINOIS DEPT OF TRANSPORTATION; REDBOOK A35; STANDARD 108; FORD RATIONALE FOR FMVSS 108 COMPLIANCE; BY CLARKS GORTE -- FORD; DATED 03/19/90

TEXT: The State of Illinois is requesting a legal interpretation of the federal requirements for front side marker lights on trucks. The truck model in question is a Ford low profile cab C-8000 cab over engine (see Exhibit A and B). These trucks were manufact ured with a reflex reflector at the location shown on exhibit A and do not have front side marker lights. The truck cab in question has been manufactured this way for more than 20 years.

The Division of Traffic Safety, Standard Engineer, has obtained telephone interpretations from Mr. Robert Hagan of the Bureau of Motor Carrier Safety and Mr. Kevin Cavey of the National Highway Transportation Safety Administration. Both of these gentleme n confirmed that the truck should be equipped with a front side marker light. (Exhibits A and B were telefaxed to Washington, D.C. for reference.)

Ford Motor Company has submitted a written opinion (Exhibit C) stating that they consider their vehicle to be in compliance. This information was telefaxed by Ford Motor Company to Mr. Richard Hunter in the Central Bureau of Maintenance.

A legal opinion is required on the following question of compliance (see Exhibit D);

Can the top of the cab clearance light (item six) be used to fulfill the requirements for front side marker lights (item two) on cab over engine vehicles?