Interpretation ID: nht90-3.13

TYPE: Interpretation-NHTSA

DATE: July 12, 1990

FROM: M. Michael Mascho -- Safety & Compliance Specialist, Kenworth Truck Company

TO: Taylor Vinson -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8-30-90 from P.J. Rice to M.M. Mascho (A36; Std. 108)

TEXT:

I am requesting an interpretation of Federal Motor Vehicle Safety Standard No. 108; Lamps, reflective devices, and associated equipment. My concern is with Identification and Clearance Lamps listed in Table I, Required Motor Vehicle Lighting Equipment O ther Than Headlamps; and Table II, Location of Required Equipment. I have attached three (3) photos to better explain my concern.

Kenworth Truck Company is a manufacturer of Class 7 & 8 trucks that are over 80" in overall width, thus falling into the requirements of the above mentioned tables. We manufacture a conventional model truck with a Aerodynes sleeper. The Clearance and I dentification Lamps are mounted on the top of the cab. (see the right hand truck in photo 1).

We have been asked to build trucks that also include an extra set of Clearance and Identification Lamps on top of the sleeper. (see left hand truck in photo 1, and photos 2 & 3). The requirements of Tables I & II for Identification Lamps are three (3) amber lamps mounted as close as practicable to the top of the vehicle, or alternatively as close as practicable to the top of the cab. Identification Lamps are to be two (2) amber lamps mounted as near the top as practicable to indicate overall width.

By mounting the extra lamps on top of the sleeper, we now have six (6) Identification Lamps and four (4) Clearance Lamps. This vehicle when viewed from the front at night would resemble a typical Class 8 truck pulling a trailer with front mounted Cleara nce and Identification Lamps.

Would this vehicle be considered to be in compliance with Federal Motor Vehicle Safety Standard 108?

Photographs attached to letter (graphics omitted).