Interpretation ID: nht74-1.38

DATE: 01/03/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Truck-Lite Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 20, 1973, concerning the placement of rear identification lamps on the header of Fruehauf trailers.

I enclose a copy of a recent exchange of correspondence between Fruehauf and this agency on this question which I believe is in point. It is our view that if a lamp is available which may be installed in a narrow header area, the upper location is "practicable" even though the lamps may not be the one specified by the vehicle's purchaser.

Yours truly,

ATTACH.

December 20, 1973

Larry Schneider -- Chief Counsel, National Highway Traffic Safety Administration

Subject: Placement of Rear Identification Lights

Dear Mr. Schneider:

We have a customer at the present time who finds it impractical to mount the three rear red identification light at the high level.

Due to the special high door construction on the dry van, the upper door header does not lend itself to the installation of the standard lights that are now used on his equipment.

These trailers are being manufactured by Fruehauf Corporation, and the present quantity is 400 trailers.

In consideration of the large number of containers that are now on the highways with no upper lights and the hardship involved in endeavoring to place improvised lights at this level, we are requesting an opinion from your office as a guide for our future action.

Thank you very much for your consideration.

Yours very truly,

TRUCK-LITE COMPANY; H. A. Sage, Director -- Research Development

Enclosure

CC: R. V. Tarr; J. J. Vicario