Interpretation ID: nht79-2.42

DATE: 07/31/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Truck-Lite Co. Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 19, 1979, to Mr. W. M. Elliott of this agency requesting clarification of Paragraph S4.3.1.1.1 of Federal Motor Vehicle Safety Standard No. 108.

This Paragraph states:

"Clearance lamps may be mounted at a location other than on the front and rear if necessary to indicate the overall width of a vehicle, as for protection from damage during normal operation of the vehicle, and at such a location they need not be visible at 45 degrees in board."

You have asked the following questions:

"1. Is the decision to use another mounting location made at the discretion of the manufacturer?"

Yes. The manufacturer determines whether placement of the lamps in accordance with Standard No. 108 will indicate overall width or whether they are susceptible to damage if so placed, and there is no requirement that it obtain the concurrence of this agency in its decision.

"2. Are there any specific conditions that are required in order to consider it 'necessary' to mount clearance lamps in other location?"

No. The agency has established no criteria of necessity and questions on variations from front and rear mounting requirements are treated on an ad hoc basis.

"3. When the decision is made to mount the clearance lamps in another location, can a manufacturer use combination clearance/side marker lamps mounted on the side of vehicle to fulfill the clearance lamp requirements."

Yes, as long as the clearance lamp function is visible from the rear and indicates the overall width of the vehicle.

"4. Section S4.1.1.1 states that in 'such a location they need not be visible at 45 degrees inboard'. Does this mean that they need not be visible from 0 to 45 degrees inboard?"

No. SAE Standard J592e, Clearance, Side Marker, and Identification lamps, July 1972, requires clearance lamps to be visible at the H Point at 10 R and L, 20 R and L, 30 R and L, and at 45 R and L. Paragraph S4.3.1.1.1 specifies that under the alternate mounting positions the lamps need not be visible at the 45 degrees positions. They must, however, be visible at the other positions. I hope this answers your questions.

SINCERELY,

June 19, 1979

National Highway Traffic Safety Administration Dept. of Transportation

Attention: W. M. Elliott

Subject: Federal Motor Vehicle Safety Standard 108, Paragraph S4.3.1.1.1 which states that "Clearance lamps may be mounted at a location other than on the front and rear if necessary to (Illegible Word) the overall width of a vehicle, or for protection from damage during normal operation of the vehicle, and at such a location they need not be visible at 45 degrees inboard".

Dear Mr. Elliott:

We would appreciate some clarification as to the proper application of the paragraph above which is Section S4.3.1.1.1 of FMVSS 108.

More specifically, it would be most helpful if you might be able to provide information that would help us answer the following questions:

1. Is the decision to use another mounting location made at the discretion of the manufacturer?

2. Are there any specific conditions that are required in order to consider it "necessary" to mount clearance lamps in another location?

3. When the decision is made to mount the clearance lamps in another location, can a manufacturer use combination clearance/sioemarker lamps mounted on the side of vehicle to fulfill the clearance lamp requirements?

4. Section S4.3.1.1.1 states that in "such a location they need not be visible at 45 degrees inboard". Does this mean that they need not be visible from 0 to 45 degrees inboard?

Any insight (official or otherwise) that you might be able to provide regarding these questions would be most appreciated. If you or someone in the department would like to contact us, feel free to telephone collect at 716/665-6214, ext. 32.

Thank you for your consideration.

A. L. Bragg Laboratory Manager

CC: J. BENNETT; R. TARR; C. POWLEY