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Ms. Melinda Dresser
Manager Contracts/Transportation
Carlin Manufacturing, Inc.
3714 N. Valentine
Fresno, CA 93722

Dear Ms. Dresser:

We have received your letter of November 28, 1994, asking whether the exterior lighting of six Oscar Mayer "Wienermobiles" that your company is manufacturing conforms to applicable Federal motor vehicle safety standards. You have enclosed diagrams showing the location of the exterior lighting devices.

Under 49 U.S.C. Chapter 301 - Motor Vehicle Safety, the determination of whether a vehicle conforms with all applicable Federal motor vehicle safety standards is that of the manufacturer who, pursuant to 49 U.S.C. 30115, must certify compliance of the vehicle with those standards upon completion of manufacture. NHTSA has no authority to approve or disapprove specific vehicle designs. We do, however, provide interpretations of our standards to manufacturers upon request. The appropriate standard here is Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment.

Your letter does not state whether Carlin has classified the Wienermobile as a "passenger car" or as a "truck". We believe that the vehicle is a "truck" within the meaning of 49 CFR 571.3(b) because it appears to be "designed primarily for the transportation of property or special purpose equipment", rather than for the transportation of passengers, and that its overall width of 94 inches makes it more appropriate for the Wienermobile to meet wide vehicle lighting requirements. Therefore, the Wienermobile must be equipped with the lighting equipment specified in Table I of Standard No. 108, and located as specified in Table II, the requirements for trucks whose overall width is 80 inches or more. This means that they must be equipped with the front and rear clearance and identification lamps that Table I requires for wide trucks; these lamps do not appear on your drawings.

In addition, all four-wheeled motor vehicles are required to have hazard warning/turn signal lamps and we don't see these

lamps either on the drawings. With respect to front lighting equipment that is depicted, we note that supplementary lighting equipment such as fog lamps and the "front marker light" are permissible under Standard No. 108 if the manufacturer determines that they do not impair the effectiveness of the lighting equipment required by Standard No. 108, in this instance, the headlamps. In the absence of a clearly erroneous determination, NHTSA will accept the manufacturer's judgment on impairment. Trucks that are subject to Table II need not be equipped with a center high- mounted stop lamp or parking lamps, if that is the purpose of the front marker lamp.

We hope that these comments will be helpful. If you have any other questions, please contact Mr. Taylor Vinson of my staff at this address or by phone at (202) 366-2992.


Philip R. Recht Chief Counsel ref:108 d:1/9/95