Interpretation ID: nht68-2.43

DATE: 06/17/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Consumers Power Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 9, 1968, to Mr. J. E. Leysath of this Bureau, requesting our comments on the rear lighting arrangements you plan to use on several of your service vehicles.

With reference to the rear lighting arrangements only and with exceptions as noted below, the lighting installations shown on your standard lighting drawing appear to meet the requirements of Federal Motor Vehicle Safety Standard No. 108 with respect to location and number of lamps.

1. The rear clearance lamps on vehicles designated by Specification Numbers (50)(54), (49), (52) and (53) do not appear to be located as near as practicable to the upper left and right extreme edges of the vehicle. Clearance lamps located on or immediately forward of the rearmost post on vehicle (50)(54) and the dump truck (54 + 74) shown on your photograph would be more in accordance with the requirements of the standard. Location of rear clearance lamps at greater heights on the rear of vehicles (50)(54), (49), (52) and (53) appears to be practicable.

2. Assuming that vehicles (27), (42) and (22)(28)(29) are less than 80 inches in overall width, Standard No. 108 requires that such vehicles manufactured on or after January 1, 1969, be equipped with either rear side marker lamps or rear side reflex reflectors. Vehicles manufactured on or after January 1, 1970, must be equipped with both rear side marker lamps and rear side reflex reflectors. If these vehicles are 80 inches or more in overall width, additional lighting requirements as specified in Standard No. 108, effective January 1, 1968, apply.

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 your interest in the Motor Vehicle Safety Standards.