Interpretation ID: nht78-2.8

DATE: 06/19/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Highway Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 1, 1978, to Mr. Vinson of this office asking whether marker lamps on your new "bevel designed front Van Trailer" comply with Federal Motor Vehicle Safety Standard No. 108. Specifically, instead of providing two amber clearance lamps, on the trailer front and two amber side marker lamps at the trailer's leading edge, you would install a combination clearance-side marker lamp at 45 degrees on the beveled leading edge of the trailer.

Paragraph S4.4.1 of Standard No. 108 permits a side marker lamp to be combined with a clearance lamp "if the requirements for each lamp . . . are met . . . ." This means that the combination lamp in position on the vehicle must meet the requirements of SAE Standard J592e, Clearance, Side Marker, and Identification Lamps, July 1972. This standard addresses specific photometric requirements for combination clearance and side marker lamps and I enclose a copy for your information.

SINCERELY,

March 1, 1978

National Highway Traffic Safety Administration

Attn: Taylor Binson Chief Consul

Dear Sir:

We would like to have a ruling on location of marker lights on our new bevel designed front Van Trailer. At present we use four (4) amber lights; two (2) on front and two (2) on side at front. Would it be permissible to use two (2) amber lights on the 45 degree front bevel corner and eliminate two (2) lights?

Enclosed is a sketch showing front of trailer marked per above.

HIGHWAY MANUFACTURING COMPANY A Division of MOTAC, INC.

LaVerne L. Kruckenberg -- Engineer

(Graphics omitted)