Interpretation ID: aiam3222
President
Bertolini Engineering Co.
Inc.
Star Route One
Vernon
NJ 07462;
Dear Mr. Bertolini: This is in reply to your letter of February 22, 1980, asking for a interpretation of Federal Motor Vehicle Safety Standard No. 108.; You have referenced our letter of May 5, 1977, to Mr. Dennis Moore o Dry Launch. That letter interpreted S4.3.1.1.1 with respect to a rear clearance lamp which indicated overall width though it was not located on the rear of the trailer. In that position it was not required to be visible at 45 degrees inboard. You have asked whether the same inboard visibility requirements may be eliminated for front clearance lamps 'for the same reasons'.; The answer is yes. If a front clearance lamp that indicates overal width is not located at the front of the trailer, S4.3.1.1.1 relieves it of the requirement that it be visible at 45 degrees inboard.; I hope this answers your question. Sincerely, Frank Berndt, Chief Counsel