Interpretation ID: 20933.ztv

Mr. Richard H. Klein, P.E.
P.O. Box 527, Fairway Drive
Johnson, NY 10933

Dear Mr. Klein:

This is in reply to your letter of November 8, 1999. You ask for a citation to the equipment and visibility requirements in Federal Motor Vehicle Safety Standard No. 108 that require intermediate side marker lamps and reflectors on buses whose overall length is more than 30 feet.

Intermediate side lighting devices may be provided on all motor vehicles regardless of length, but "are not required on vehicles less than 30 feet in overall length." (S5.1.1.3). The lamps must meet the requirements of SAE Standard J592e, Clearance, Side Marker, and Identification Lamps, July 1972; the reflectors must comply with SAE Standard J594f, Reflex Reflectors, January 1977. These standards have been incorporated by reference in Standard No. 108. If the overall width of the vehicle is 80 inches or more, the devices must be located according to Table II of the standard; if less than 80 inches, according to Table IV. They must meet the photometric and visibility requirements specified in the SAE standards mentioned above.

If you have any further questions, you may call Taylor Vinson of this Office (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref: 108
d.2/28/2000