Mr. Ben Reginella, P. Eng.
Algonquin Automotive
1 Crescent Road
Huntsville
Ontario P1H 1Z6
Canada

Dear Mr. Reginella

This is in reply to your letter of April 29, 1997, requesting an interpretation of the term "overall width" as the phrase is used in Federal Motor Vehicle Safety Standard No. 108.

You have asked whether "the painted flexible flares" you describe qualify as "flexible" and hence may be excluded from the calculation of overall width. You are developing a trim kit for the Dodge T300 Ram Truck which includes painted flexible flares along with running boards, and have enclosed photos of the flare in question..

"Overall Width" is defined in Note 1 to Standard No. 108 as "the nominal design dimension of the widest part of the vehicle, exclusive of signal lamps, marker lamps, outside rearview mirrors, flexible fender extensions, and mud flaps, determined with doors and windows closed and the wheels in the straight-ahead position." We confirm that the "flexible flare" shown in your photographs is a "flexible fender extension" within the meaning of the term as used in Standard No. 108's definition of overall width, and may be excluded from the calculation of the overall width of any vehicle upon which it is installed.

If you have any questions, you may call Taylor Vinson of this Office (202-366-3820).

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d:5/22/97