Interpretation ID: nht89-2.17

TYPE: INTERPRETATION-NHTSA

DATE: 06/21/89

FROM: WAYNE KRAUSE -- WALTCO TRUCK EQUIPMENT COMPANY

TO: STEVEN T. WOOD -- ACTING CHIEF COUNSEL NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 07/24/89 FROM STEPHEN P. WOOD -- NHTSA TO WAYNE KRAUSE -- WALTCO; REDBOOK A33; STANDARD 108

TEXT: Dear Mr. Wood,

We are asking for comments on whether or not our proposed tail light arrangement complies with FMVSS-108.

The enclosed drawings show our RGL-Series tail gate lift with the platform stored below floor level of a truck or trailer for transmit.

The platform in this position, would of course, block from view any normal tail light arrangement. In order to comply with the 45 degree visibility requirements of FMVSS-108, we propose to use two sets of tail lights (tail, stop and turn lights) as show n on drawings.

Light Set 1 is installed above floor level (not to exceed 72" for ground) and inside of tail gate rails.

Light Set 2 will be installed under the vehicle body, slightly forward of the rear of the body and approximately flush with the side of the vehicle.

Both lights of Set 1 would be visible from the rear of the vehicle and would act as the primary tail lights.

Light Set 2 would act as auxiliary tail lights that would be visible from the side of the vehicle as shown in drawings. We feel this is permissible under FMVSS-108; 49 CFR 571.108 (section 4.3.1.1.1) and SAE J585e.

While we feel this light arrangement meets all of the requirements set forth in FMVSS-108 with respect to location of tail lights, we would like your comments.

We would also appreciate a speedy reply if at all possible.

Sincerely,

Enc.: Drawing 80100693

Drawing 80100694