Interpretation ID: 1984-1.43

TYPE: INTERPRETATION-NHTSA

DATE: 05/01/84 EST

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: National Truck Equipment Association -- Steven D. Herringshaw, Coordinator of Technical Services

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Steven D. Herringshaw Coordinator of Technical Services National Truck Equipment Association 25900 Greenfield Road Oak Park, Michigan 48257

Dear Mr. Herringshaw:

This is in response to your letter of February 24, 1984, with respect to mounting requirements for clearance and identification lamps under Federal Motor Vehicle Safety Standard No. 108.

Your Exhibit A depicts a body mounted on a chassis-cab, with clearance lamps mounted both on the body and chassis-cab, but identification lamps mounted on only the chassis-cab. You have asked whether the truck body must have a set of identification lamps in order to meet Standard No. 108. The answer is yes. In order to comply with the requirements that identification lamps be located as closely as practicable to the top of the vehicle, a set of identification lamps must be provided for the truck body. You may be interested to know that there is a pending proposal which was published on February 22, 1982; a vehicle such as shown in Exhibit A would comply with a single set cf identification lamps mounted on the cab. enclose a copy of the proposal. The agency has taken no further action with respect to it.

In comparing the vehicles in Exhibit A and Exhibit B you have asked whether theone in Exhibit A is "compliant with the intentions of FMVSS 108." As I have just explained, this vehicle is currently noncompliant with the standard, but would comply if the proposal were adopted. The vehicle in Exhibit B meets the standard.

I hope that this answers your questions.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

February 24, 1984

Office of Chief Counsel Room 5219 National Highway Traffic Safety Administration 400 Seventh St., SW Washington, DC 20590

Dear Sirs:

The National Truck Equipment Association (NTEA) is a national trade association representing over 900 members of the truck body and truck equipment industry. Our members include manufacturers and distributors of truck bodies, chassis, and every imaginable type of truck accessories and equipment.

On behalf of one of our members, a rather substantial manufacturer of van bodies designed to be mounted on a chassis-cab, we would like to request a ruling or official interpretation cf FMVSS 108, Lights. The bodies in question are at least 80 inches wide, so that the vehicles do require both clearance and identification lamps. The issue being questioned is the clause "...as high as practicable".

Following are some specifics on both the bodies and the chassis. -- The bodies range from approximately 81 inches wide to 102 inches wide. -- The bodies range in height from 18 inches above the top of the cab to 75 inches above the cab (on a 13' 6" vehicle). -- The bodies range from 8 feet to 28 feet in length. -- The chassis used with the bodies in question come equipped from the manufacturer with both clearance and identification lights mounted on the roof of the cab.

The question being posed is: "If the chassis is equipped with clearance and identification lights, and the front of the body is equipped with clearance lights mounted at the highest point and the widest point of the vehicle (see exhibit A), is this a compliant vehicle with FMVSS 108, or does the body require an additional set of identification lights on its front end?"

FMVSS 108 allows the clearance lights on the front of the vehicle to be lower than the top of the vehicle if the widest point is lower (see exhibit B). FMVSS 108 also allows the rear clearance lights to be lower if the identification lights are at the top. The NTEA opinion in the past has been that the vehicle in exhibit A is a safer vehicle than the vehicle in exhibit B, and that the overallsize of the vehicle in exhibit A would be more easily recognizable to approaching motorists than a vehicle with lower clearance lights. This would seem to make vehicle A compliant with the intentions of FMVSS 108. Is this a just opinion?

One additional piece of information which may or may not be relevant is that the cost difference to the final customer could be upwards of $100 without the additional I.D. lights.

Thank you for your consideration.

Yours Truly,

Steven D. Herringshaw Coordinator of Technical Services