Mr. Jerry Clay
Secretary-Treasurer
Best Fender Products, Inc.
P.O. Box 1258
Hwy 49, East
Mt. Pleasant, Texas 75455

Dear Mr. Clay:

We have received your letter of January 22, 1996, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108. Your company has developed a fender for trailers which incorporates front and rear clearance lamps, and you would like our opinion whether, when the fender is installed on a trailer, the trailer will then comply with the clearance lamp location requirements of Standard No. 108.

You state, and the drawings which you enclose indicate, that "the clearance light is located midway up the wheel well radius of the fender, both front and rear, and as close to the outside lip radius of the fender as physically possible."

Table II of Standard No. 108 requires that clearance lamps be located "to indicate the overall width of the vehicle . . . and as near the top thereof as practicable." For the trailers shown in the drawings, where the outer edge of the fender is the widest part of the vehicle, your chosen location places the lamp in a location that indicates the overall width of the trailer. In that location, the lamp may also be "as near the top thereof as practicable." Indication of overall width is the primary requirement that must be met, as shown in the drawings. A location of the lamp on the trailer body where it might be closer to the top but would not indicate overall width as the fender lamps do would not be a conforming location under Table II.

We call your attention to the requirement that the trailer manufacturer must also certify that the clearance lamp as

installed on the fender meets the photometric requirements of SAE Standard J592e July 1972. These are incorporated by reference in Standard No. 108.

If you have further questions, you may refer them to Taylor Vinson of this Office with whom you have previously spoken (202-366-5263).

Sincerely,

Samuel J. Dubbin Chief Counsel ref:108 d:3/4/96