Interpretation ID: nht91-2.10

DATE: March 6, 1991

FROM: Earl C. Lempke -- President, Delavan Industries Inc.

TO: Taylor Vinson -- NHTSA (Dot)

TITLE: None

ATTACHMT: Attached to letter dated 3-27-91 from Paul Jackson Rice to Earl C. Lempke (A37; VSA 1392(d); Std. 108)

TEXT:

You have been referred to us by Truck Lite Corporation as their contact with the Government concerning Trailer Lighting.

Delavan is the major Manufacturer of Automobile Transport Trailers and have been building this equipment for forty-five years.

Our question, is there any federal ruling stating that Trailer Clearance Lights are considered as Safety Equipment and as such are not to be included as part of the overall width of the vehicle?

Believe it or not, Truck Lite has nothing they can refer to us to substantiate this. Is there any ruling on this matter which you could send us?

Thank you for your help and please call me (800-258-2528) if you need any more information.

Attachment Copy of Federal Highway Administration Federal Motor Safety Regulations dated January, 1990, regarding S393.19 - S393.22, page 184. (Text omitted)