Interpretation ID: aiam1701
Jr.
Messrs. Patton
Boggs & Blow
1200 Seventeenth Street
N.W.
Washington
DC
20036;
Dear Mr. Verrill: This is in reply to your two letters of November 8, 1974, on behalf o Trailer Manufacturers Association, requesting interpretations of Standard No. 108 as it applies to boat trailers.; Standard No. 108 requires that clearance lamps be located 'on the rear (Table II) but 'boat trailers need not be equipped with both front and rear clearance lamps, provided an amber (to front) and red (to rear) clearance lamp is located so as to indicate its extreme width' (paragraph S4.1.1.9). You enclose a drawing showing front and rear clearance lamps imbedded in the trailer fender and ask for an interpretation that 'where locating the clearance lamp on the front and rear of the vehicle would not mark the extreme width of the vehicle, the manufacturer shall have the option of locating the clearance lamps as close to the front or rear as practicable in order to mark the overall width of the trailer.'; Paragraph S4.1.1.9 contemplates the use of a double-faced lamp. Thi lamp is generally mounted atop the fender so that the visibility requirements at 45 degrees inboard may be met. Separate lamps also 'located at or near the mid point' would meet the same need for vehicle safety, and would be acceptable, provided that the visibility requirements are also met. This does not seem likely from your proposed configuration, unless the lamps are located above the trailer frame.; You also present the problem of boat trailers on which 'apparatus t hold, load and unload the boat extends from two to four feet beyond the rear frame.' The apparatus overhang may prevent lamps mounted on the rear frame from meeting the visibility requirements of paragraph S4.3.1.1.'You ask for an interpretation 'that would permit the use of detachable light bars where necessary to comply with the visibility requirements of S4.3.1.1.'; There are two solutions to your problem permissible under Standard No 108. The apparatus itself appears to be a permanent and rigid part of the vehicle within the meaning of paragraph S4.3.1, so that the lamps in question could be mounted there and comply with the requirements of the standard. You may not wish to do so, however, because of damage that might be incurred through unloading the immersion in water. In that instance paragraph S4.3.1.1 provides the answer: 'However, if motor vehicle equipment. . . prevents compliance with this paragraph by any required lamp or reflective device, an auxiliary lamp or device meeting the requirements of this paragraph shall be provided'. A detachable light bar would be acceptable as an auxiliary, provided that it complies with the wiring requirements of paragraph S4.5, and the required lighting is retained (in your hypothetical, lamps located at the end of the frame).; We have also received your petition of November 8, 1974, on behalf o Trailer Manufacturers Association to amend Standard No. 108 with respect to boat trailers. You will be informed in due course whether it merits initiation of rulemaking.; Yours truly, Richard B. Dyson, Acting Chief Counsel