Mr. Tommy Reeder
Loadcraft Manufacturing Corp.
P.O. Box 431
Brady, TX 76285

Dear Mr. Reeder:

This responds to your FAX of November 13, 1995, to Dave Coleman of this agency, with questions relating to rear lights on trailers, and a schematic drawing of the tilt bed trailer that is your concern.

Your first question is this: if the lights are placed on the extreme end of the tilt bed trailer, you say that they will be damaged when the trailer bed is tilted. In its original configuration as a farm trailer, the lamps were mounted on the furthermost crossmember facing the rear of the trailer. You have asked whether the lamps have to be mounted at the extreme end of the trailer.

Standard No. 108, the Federal standard governing lighting requirements, specifies that lamps and reflectors at the back of a trailer shall be located "on the rear". This generally means at the end of the trailer body or bed, or of the rear fender if the trailer is so equipped. It is not necessary to locate lamps literally on the extreme end provided that the photometric and visibility requirements of Standard No. 108 for rear lamps are met in the location chosen. We deem it highly unlikely that the lamps mounted on the rearmost crossmember as shown in your drawing would comply with the photometric and visibility requirements of Standard No. 108.

You have also informed us that you "have started using a drop bar in addition to the lights on the crossmember to increase visibility of the taillights in traffic", and have asked whether this is permissible. The drop bar location for all rear lighting equipment (reflex reflectors, stop lamps, taillamps, and turn signal lamps) would be an improvement, but it is still not certain that such a location would bring the rear lighting array into compliance. There is a 10-degree upward visibility requirement in Standard No. 108, and, depending on the exact mounting angles, the rear edge of the trailer could restrict compliance with this requirement.

There would be a greater likelihood of compliance if the drop bar could be moved rearward to the approximate area where one structural member of the bed begins to angle upward (in your sketch, at the left of the 16 3/4-inch dimension).

If you have any further questions, you may refer them to Taylor Vinson of this Office.

Sincerely,

Samuel J. Dubbin Chief Counsel ref:108 d:1/29/96