Interpretation ID: nht90-2.42

TYPE: INTERPRETATION-NHTSA

DATE: 05/08/90

FROM: JACK RADEMACHER -- CHIEF ENGINEER, POLAR TANK TRAILER, INC.

TO: STEPHEN P. WOOD--NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 8-22-90 TO J. RADEMACHER FROM P. J. RICE; (A36; STD. 108)

TEXT:

Recently you released an interpretation of Federal Motor Vehicle Safety Standard No. 108 which stated that rear turn, stop and tail lamps mounted 27 inches from the rear edge of the vehicle are not mounted "on the rear." In this interpretation, it was al so obvious that the 45 degree visibility requirements were not met.

It has long been the practice of the Truck Trailer Manufacturers Association (TTMA) and its members to interpret standard No. 108 as meaning that if the 45 degree visibility requirements of these lights were met "on the rear" of the trailer both inboard and outboard, the manufacturer met the intent of the standard. The liquid bulk transport industry is especially affected by your interpretation. Over the years thousands of tank transports have been built with rear lights mounted as far as 36 inches fo rward from the rear of the bumper. These tankers still maintain the 45 degree visibility requirements.

The following are some of the reasons for this type of high and set back type of lighting:

1.) Eliminating clutter in an area where hazardous materials are being dispensed. 2.) Better visibility because of high mounting. 3.) Protection of lens from chemical vapors and/or drips from hose tubes. 4.) Accident damage protection. 5.) Protection of lens from road dirt.

We (especially the cargo tank transport industry), therefore, request reconsideration of your interpretation allowing set back rear lights if 45 degree visibility requirements are met.

If there are any questions, please feel free to contact me at the above listed number.