Interpretation ID: nht69-2.2
DATE: 05/02/69
FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA
TO: Reliance Trailer and Truck Company Inc.
TITLE: FMVSS INTERPRETATION
TEXT: Thank you for your letter of March 12, 1969, to the Director of the National Highway Safety Bureau concerning your questions on mounting of clearance and identification lamps on your open top bulk commodity trailers. In response to your question no. 1, identification lamps mounted below the bottom edge of the tarp as shown on your attached marked print no. 2 appear to be in compliance with Standard No. 108. With the identification lamps to mounted the rear clearance lamps may be mounted at the extreme edge of the rear lower structure as shown on print no. 2.
The answer to question numbers 2 and 3 is that the front clearance lamps should be mounted as high as practicable to clear the bottom edge of the tarp as shown on your attached marked print no. 2.
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.