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Interpretation ID: 00183.ztv

    Mr. Don Weidman
    Standards & Regulatory Affairs Manager
    Grote Industries, LLC
    2600 Lanier Drive
    Madison, IN 47250

    Re; Number of Identification Lamps

    Dear Mr. Weidman:

    This is in reply to your letter of August 20, 2002, asking "how many lamps can be installed as identification lamps on a vehicle . . . and still be in compliance with Standard No. 108."

    You related that a customer wishes to have a five-lamp array of lamps rather than the cluster of three identification lamps specified in Standard No. 108. It is your opinion that these additional lamps are not allowed because they would detract from the purpose of the three-lamp array to identify a large vehicle in the roadway.

    We confirm your interpretation. Late in 1973, we were asked by Darrell Gambill of Crane Carrie Company whether a system of four identification lamps would be permissible.I enclose a copy of our response stating that only the three-lamp system specified by Standard No. 108 is permissible.


    Jacqueline Glassman
    Chief Counsel