Interpretation ID: 1982-2.24

DATE: 07/26/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Puerto Rico Marine Management, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

JULY 26, 1982

Mr. William Croix Technical Maintenance, Manager Puerto Rico Marine Management, Inc. G.P.O. Box 71306 San Juan, Puerto Rico 00936

Dear Mr. Croix:

This is in response to your letter of July 9, 1982, to Mr. Elliott of this agency.

You have asked about Federal requirements for lighting of portable containers secured to flat bed trailers. As those containers are the cargo of the trailers and not an integral part of them, the Federal lighting requirements (Motor Vehicle Safety Standard No. 108) apply only to the trailer. However, the individual States in which the trailers are operated may impose their own lighting requirements.

Sincerely,

Frank Berndt Chief Counsel

PUERTO RICO MARINE MANAGEMENT, INC. SAN JUAN, PUERTO RICO 00936

July 9, 1982

Department of Transportation Mr. Elliogt, Safety Standard Eng.

400-7th. Street South West, Room #5307 Routing NRM-11 Washington, D.C. 20590

Dear Mr. Elliogt:

I refer to our telephone conversation on July 7, 1982, in which my question pertained to lighting on the chassis of a container and chassis comnbination.

In transit our containers are secured to the cahssis for safety purposes. My prime question is are we in conformance with the lighting regulation set forth by your department with proper lighting on the chassis only, when the container is secured to the chassis.

Per your request I put in writing the substance of our conversation. Your response to this subject will be appreciated.

Cordially yours,

Mr. William Croix Technical Maintenance Manager

WC/umc

c: SAN JUAN - A. Colon, Executive J. Dillon, Corp. Maint.

W. Smith, Corp. Maint.