Interpretation ID: nht68-1.8

DATE: 04/24/68

FROM: NHTSA

TO: Utility Body Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 6, 1968, to Mr. George C. Nield, concerning the additional clearance lamps and reflectors that you have been requested to install on vehicles shipped to Hawaii.

Referring to the drawing attached to your letter, the use of clearance lamps as shown does not appear to impair the effectiveness of the lighting equipment required by Motor Vehicle Safety Standard No. 108, provided (1) the two lamps on front of the body are amberin color, and (2) the lamp on the rear of the body is red in color. Also, use of the amber reflex reflector on front of the body would not appear to impair the effectiveness of the required equipment. Paragraph S3.1.2 of the Standard states: "No additional lamp, reflective device, or associated equipment shall be installed if it impairs the effectiveness of the required equipment." This requirement applies to all applicable vehicles, including those owned by a State.

On your drawing, it appears that you have inadvertently indicated a red color for the clearance lamps on the front of the body. Use of red lamps at the locations shown would impair the effectiveness of the required equipment, since red lamps are used, in accordance with the standard, to designate the rear of the vehicle.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the Standard.

Thank you for writing.

Sincerely,

March 6, 1968

George C. Nield -- Deputy Director, Motor Vehicles Safety Performance Services, U.S. Department of Transportation, Federal Highway Administration National Highway Safety Bureau

Dear Mr. Nield:

I certainly enjoyed the meeting held in Washington last week concerning the new Federal Motor Vehicle Safety Standards as sponsored by the Truck Body & Equipment Association.

I particularly enjoyed the afternoon panel discussion that you moderated.

If I may, I would like to request an interpretation on lighting, as covered under Standard 108.

Section 103 (D) of Public Law 89-563, of course, spells out that no state shall require additional lamps unless they are identical to the Federal standards. Standard S.3.1.1 confirms this fact in spelling out the "in the number" or quantity. Section S.3.1.2 states no additional lamps from Standard 108 unless, of course, the vehicle is owned by the state.

You will find enclosed a copy of our drawing describing lighting on an open bed service line construction body which we manufacture. Item 10, as shown, is the rear face clearance lamp. Item 11, rear marker reflector. Item 12, rear red marker lamp.

On units we ship to the State of Hawaii, we are still being asked to furnish lighting per their state law, which was written basically around the ICC standard. They have asked that we add additional clearance lamps, as shown in the three red rectangular boxes that I have added as No. 10. One on the front face of the body at the top corner; one at the front side top of the body corner; and one at the rear side face of the body. They have also asked that we add an additional reflector, as shown as Item No. 8 at the lower side front corner of the body.

Of course, the same lighting configuration would be duplicated on the other side of the vehicle.

In your interpretation, by the addition of these three lights and one reflector per side, are we impairing the effectiveness of the Motor Vehicle Standards as specifically spelled out by number and location under Standard 108?

I would appreciate your comments.

Yours very truly,

UTILITY BODY COMPANY

Dick Romney,

Sales Manager

Enclosure - Drawing

TYPICAL EQUIPMENT INSTALLED

(Graphics omitted)