Interpretation ID: 9664
Trail Eze
1909 South Rowley
Mitchell, SD 57301
Dear Mr. Paradis:
We have received your letter of February 11, 1994 asking whether an intermediate side marker lamp is required on a trailer with a 24-foot bed and a 6-foot or longer tongue.
S5.1.1.3 of Standard No. 108 states that intermediate side marker devices are not required "on vehicles less than 30 feet in overall length." Although the term "overall length" is not defined, we interpret it literally: the length of a vehicle as measured from one extremity to the other. For a trailer, this would include the equipment that is part of it and by which it is towed, i.e., the tongue. Therefore, intermediate lighting devices are required on the trailer configuration you describe.
The fact that S5.1.1.15 refers to a trailer that is "less than 6 feet in overall length, including the trailer tongue" should not be interpreted as indicating that Standard No. 108 does not intend the tongue to be included in calculating a vehicle's "overall length" when the term appears elsewhere in the standard without reference to the tongue.
Sincerely,
John Womack Acting Chief Counsel ref:108 d:3/10/94